Brian Davis Quoted on IRS Withdrawal of Proposed Regulations

News / October 21, 2022

Partner Brian Davis was quoted by TaxNotes about the withdrawal of proposed IRS regulations on previously taxed earnings and profits (PTEP). Titled “IRS Officially Withdraws PTEP Proposed Regs” the Oct. 21, 2022, article addresses the history of the proposed regulations, the possible reasoning for their withdrawal and the impact they might have had.

The regulations “could have been considered a source of authority” in a couple of ways, Davis told the publication, including for the position that “a shareholder had a PTEP account in respect of a distributing company, or that section 959(b) protection exists.”

Read the article (subscription required).

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