IRS Issues Guidance on Measuring Overseas Cash Earnings


David Noren said that provisions related to debt in IRS guidance for companies calculating their repatriated overseas earnings under the new tax bill “will have the effect of increasing the effective rates on transition tax inclusions for many taxpayers.” Because the IRS did not address situations in which a company has cash-equivalent holdings that are restricted from payouts for a year, “the result is a bit of an asymmetry in the government’s favor,” Mr. Noren added.