Feb 18 2019 38 mins 1
Doug McHoney (PwC's US ITS Leader) interviews Prae Kriengwatana (WNTS- ITS Director) about the Section 965 Final Regulations which were published in the Federal Register on February 5, 2019. Doug and Prae discuss the background of Section 965, review the changes from the proposed regulations, and highlight the possible impacts to taxpayers. Among other topics, they cover the modifications to cash positions, revisions to the five-step ordering rule for E and P adjustments, basis adjustment elections, previously taxed earnings and profits (PTEP), and transfer agreements.
