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Baker McKenzie's North American Tax Practice Group has prepared a Tax News and Developments Client Alert examining the recently released proposed regulations under Section 965, the mandatory deemed repatriation provision added to the Code in the Tax Cuts and Jobs Act. This alert provides analysis and observations of the proposed guidance and covers key issues affecting taxpayers such as:

  • Calculating the inclusion and cash position
  • Addressing resulting E&P and basis adjustments
  • Navigating anti-avoidance and double counting provisions
  • Determining the foreign tax credit consequences of the inclusion
  • Applying payment and election rules
  • Considering the impacts to affiliated groups, individuals, and passthroughs
  • Anticipating state and local tax implications
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