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B-330821 1 (2019-03-11)

handle is hein.gao/gaobadvqs0001 and id is 1 raw text is: G U.S. GOVERNMENT ACCOUNTABILITY OFFICE 441 G St. N.W. Washington, DC 20548 B-330821 March 11, 2019 The Honorable Chuck Grassley Chairman The Honorable Ron Wyden Ranking Member Committee on Finance United States Senate The Honorable Richard Neal Chairman The Honorable Kevin Brady Ranking Member Committee on Ways and Means House of Representatives Subject: Department of the Treasury, Internal Revenue Service: Regulations Regarding the Transition Tax Under Section 965 and Related Provisions Pursuant to section 801 (a)(2)(A) of title 5, United States Code, this is our report on a major rule promulgated by the Department of the Treasury, Internal Revenue Service (IRS) entitled Regulations Regarding the Transition Tax Under Section 965 and Related Provisions (RIN: 1545-B051). We received the rule on February 25, 2019. It was published in the Federal Register on February 5, 2019. 84 Fed. Reg. 1838. The effective date of the final rule was February 5, 2019. The final rule implements section 965 of the Internal Revenue Code. Specifically, this final rule provides general rules and definitions under section 965, including general rules concerning section 965(a) inclusion amounts, general rules concerning section 965(c) deduction amounts, and rules concerning the treatment of certain specified foreign corporations as controlled foreign corporations (as defined in section 957) and certain controlled domestic partnerships as foreign partnerships. The Congressional Review Act (CRA) requires a 60-day delay in the effective date of a major rule from the date of publication in the Federal Register or receipt of the rule by Congress, whichever is later. 5 U.S.C. § 801(a)(3)(A). The final rule was published in the Federal Register on February 5, 2019. 84 Fed. Reg. 1838. The rule was received by the Senate on February 26, 2019, and by the House on February 27, 2019. 165 Cong. Rec. H2310, S1591. The rule has a stated effective date of February 5, 2019. Therefore the final rule does not have the required 60-day delay in its effective date.

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