Proposed rule · 2025-08743

Previously Taxed Earnings and Profits and Related Basis Adjustments

This document reopens the period to submit comments for a notice of proposed rulemaking (REG-105479-18), which was published in the Federal Register on Monday, December 2, 2024. The proposed regulations address previously taxed earnings and profits of foreign corporations and related basis adjustments. The proposed regulations affect foreign corporations with previously taxed earnings and profits and their shareholders.