Prop. Treas. Reg. § 1.962-1 Limitation of tax for individuals on amounts included in gross income under section 951(a).

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 962 · Would amend § 1.962-1

Par. 29. Section 1.962-1 is amended by: 1. Removing the last sentence in paragraph (a)(3); and 2. Adding paragraph (a)(4). The addition reads as follows:

(a) * * *

(4) See section 959 and the regulations in this part issued under section 959 for rules regarding previously taxed earnings and profits, including previously taxed earnings and profits assigned to the taxable section 962 PTEP subgroup (as defined in § 1.959-2(b)(2)(ii)(A)).

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