IRS Announced that they Intend to Issue Future Regulations, Applying Sections 951, 951A To Certain S Corporations With Accumulated E&P

In Notice 2020-69 the IRS announced that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue regulations addressing the application of §§ 951 and 951A of the Internal Revenue Code (Code) to certain S corporations with accumulated earnings and profits.  

For those S corporations electing this treatment, global intangible low-taxed income (GILTI) inclusions would create AAA. 

This notice also announces that the Treasury Department and the IRS intend to issue regulations addressing the treatment of qualified improvement property (QIP) under the alternative depreciation system (ADS) of § 168(g) for purposes of calculating qualified business asset investment (QBAI) for purposes of the foreign-derived intangible income (FDII) and GILTI provisions. 

These rules when issued would implement recent clarifications enacted as part of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).  All of these provisions were originally part of the 2017 Tax Cuts and Jobs Act (TCJA). Notice 2020-69 will be published in Internal Revenue Bulletin 2020-39 on Sept. 21, 2020.

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