SECTION 1. OVERVIEW

This notice announces that the Department of the Treasury (“Treasury Department”) and the Internal Revenue Service (“IRS”) intend to issue regulations addressing certain issues arising from the enactment of the Tax Cuts and Jobs Act, Pub. L. 115–97 (2017) (the “Act”), on December 22, 2017, with respect to foreign corporations with previously taxed earnings and profits (“PTEP”). Section 2 of this notice provides background on section 959 of the Internal Revenue Code (“Code”) and other relevant Code provisions. Section 3 of this notice describes proposed regulations that the Treasury Department and the IRS intend to issue concerning PTEP arising under provisions of the Act (the “forthcoming regulations”). Section 4 of this notice describes the proposed applicability date of the forthcoming regulations. Section 5 of this notice requests comments and provides contact information; as explained in that section, the Treasury Department and the IRS intend to address additional PTEP issues in separate guidance.