1545-AY54 202210 The Regulatory Plan and the Unified Agenda of Federal Regulatory and Deregulatory Actions 1545 Internal Revenue Service IRS 1500 Department of the Treasury TREAS Exclusion From Gross Income of Previously Taxed Earnings and Profits, and Adjustments to Basis of Stock in Controlled Foreign Corporations and of Other Property

The regulations will address exclusions from income of previously taxed earnings and profits under section 959, accounting for previously taxed earnings and profits, and basis adjustments under section 961 related to previously taxed earnings and profits. The regulations will generally include the rules described in Notice 2019-01.

]]> Substantive, Nonsignificant Previously Published in The Unified Agenda Proposed Rule Stage No No 26 CFR 1 26 U.S.C. 959 26 U.S.C. 7805 No NPRM 08/29/2006 71 FR 51155 NPRM Comment Period End 11/27/2006 Second NPRM 04/00/2023 REG-121509-00 Drafting attorney: Joshua P. Roffenbender (202) 317-6934 Reviewing attorney: Melinda E. Harvey (202) 317-6934 Treasury attorney: Brenda Zent (202) 622-6894 CC:INTL No No None No No No No Joshua Roffenbender P. Attorney 1545 Internal Revenue Service IRS 202 317-6934 855 584-5146 joshua.p.roffenbender@irscounsel.treas.gov 1111 Constitution Avenue NW, Room 4706, Washington DC 20224