On March 2, 2025, TEI submitted comments regarding the long-awaited proposed previously taxed earnings and profits ("PTEP") regulations. TEI's comments focused on the need to eliminate double taxation of PTEP by recommending a change to the proposed regulations' "share-by-share" approach to section 961 basis increases. TEI recommended that section 961 basis increases should be allocated pro-rata across all a U.S. shareholder's shares in a controlled foreign corporation. TEI's comments were prepared by members of its U.S. International Tax Committee and Tax Reform Task Force. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.
TEI Comments on Proposed PTEP Regulations
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