Prop. Treas. Reg. § 1.312-6 Earnings and profits.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 312 · Would amend § 1.312-6

Par. 4. Section 1.312-6 is amended by adding paragraph (f) to read as follows:

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(f) An amount included in a corporation's gross income under section 951(a) or 951A(a) for a particular period is taken into account in computing the corporation's earnings and profits for that period. See also § 1.312-8(c) (domestic corporation's receipt of previously taxed earnings and profits does not increase earnings and profits). This paragraph (f) applies to a taxable year of a corporation beginning on or after [date of publication of final regulations in the Federal Register ]. This paragraph (f) also applies to a taxable year of a domestic corporation that is a shareholder in a foreign corporation, if a taxable year of the foreign corporation that is an early application year (as described in § 1.959-12(d)) ends with or within the taxable year of the domestic corporation.