On March 2, TEI submitted comments regarding the long-awaited proposed previously taxed earnings and profits (PTEP) regulations.
TEI’s comments focused on the need to eliminate double taxation of PTEP by recommending a change to the proposed regulations’ “share-by-share” approach to Section 961 basis increases. TEI recommended that Section 961 basis increases should be allocated on a pro rata basis across all of a US shareholder’s shares in a controlled foreign corporation.
TEI’s comments were prepared by members of its US International Tax Committee and Tax Reform Task Force. Benjamin Shreck, TEI tax counsel, coordinated the preparation of TEI’s comments.
