Previously Taxed Earnings and Profits and Related Basis Adjustments

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Published

May 16, 2025

Issuing agencies

Treasury DepartmentInternal Revenue Service

Abstract

This document reopens the period to submit comments for a notice of proposed rulemaking (REG-105479-18), which was published in the Federal Register on Monday, December 2, 2024. The proposed regulations address previously taxed earnings and profits of foreign corporations and related basis adjustments. The proposed regulations affect foreign corporations with previously taxed earnings and profits and their shareholders.

Full Text

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<title>Federal Register, Volume 90 Issue 94 (Friday, May 16, 2025)</title>
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[Federal Register Volume 90, Number 94 (Friday, May 16, 2025)]
[Proposed Rules]
[Page 20977]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-08743]



[[Page 20977]]

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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[REG-105479-18]
RIN 1545-BO61


Previously Taxed Earnings and Profits and Related Basis 
Adjustments

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking; reopening of comment period.

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SUMMARY: This document reopens the period to submit comments for a 
notice of proposed rulemaking (REG-105479-18), which was published in 
the Federal Register on Monday, December 2, 2024. The proposed 
regulations address previously taxed earnings and profits of foreign 
corporations and related basis adjustments. The proposed regulations 
affect foreign corporations with previously taxed earnings and profits 
and their shareholders.

DATES: The comment period to submit written or electronic comments for 
the notice of proposed rulemaking, REG-105479-18, 89 FR 95362 (December 
2, 2024) is reopened until July 14, 2025.

ADDRESSES: Commenters are strongly encouraged to submit public comments 
electronically via the Federal eRulemaking Portal at <a href="https://www.regulations.gov">https://www.regulations.gov</a> (indicate IRS and REG-105479-18) by following the 
online instructions for submitting comments. Once submitted to the 
Federal eRulemaking Portal, comments cannot be edited or withdrawn. The 
Department of the Treasury (Treasury Department) and the IRS will 
publish for public availability any comments submitted to the IRS's 
public docket. Send paper submissions to: CC:PA:01:PR (REG-105479-18), 
Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin 
Station, Washington, DC 20044.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, 
Elena M. Madaj at (202) 317-3576; concerning submissions of comments, 
the Publications and Regulations Section of the Office of Associate 
Chief Counsel (Procedure and Administration) at (202) 317-6901 (not a 
toll-free number).

SUPPLEMENTARY INFORMATION: A notice of proposed rulemaking and request 
for comments that appeared in the Federal Register on Monday, December 
2, 2024 (89 FR 95362) announced that written or electronic comments 
must be received by March 3, 2025. Comments requested more time to 
submit comments on the proposed regulations. To give all interested 
parties an additional opportunity to comment on the proposed 
regulations, the period of time to submit comments has been reopened. 
Comments must be received by July 15, 2025. No request for a public 
hearing on the proposed regulations was received before the closing of 
the initial comment period on March 3, 2025. Accordingly, there will 
not be a public hearing scheduled in connection with the notice of 
proposed rulemaking (REG-105479-18).

Oluwafunmilayo A. Taylor,
Section Chief, Publications & Regulations Section, Associate Chief 
Counsel (Procedure and Administration).
[FR Doc. 2025-08743 Filed 5-15-25; 8:45 am]
BILLING CODE 4830-01-P


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