IRS Provides an Update on Certain Transfer Agreements under Section 965

October 2018


Recently, the Internal Revenue Service (IRS) updated its website. The website included the following:
Special Update
The proposed regulations in 1.965-7 call for certain transfer agreements to be filed by October 9, 2018 in accordance with rules provided in forms, instructions, or other guidance. The IRS is aware that taxpayers need more guidance on where and how to submit these agreements and plans to provide further guidance in the near future. Transfer agreements filed in accordance with this future guidance will still be considered timely filed notwithstanding the October 9, 2018 date mentioned in the proposed regulations.
Once future guidance is issued, another tax alert discussing such guidance will be published.

Joe Calianno
Partner and International Tax Technical Practice Leader
National Tax Office
  Monika Loving
Partner and International Tax Practice Leader

Annie Lee
  Chip Morgan

Robert Pedersen
  Jerry Seade

Natallia Shapel
  Sean Dokko
Senior Manager
National Tax Office