On August 8, 2018, Friedemann Thomma and Lauren Keller published "Proposed US deemed repatriation regulations provide clarity but reject taxpayer suggestions" in MNE Tax. Here is an excerpt:
The IRS and Treasury on August 1 released comprehensive proposed regulations on the Section 965 deemed repatriation "toll charge" imposed on US persons with foreign earnings accumulated offshore, generally following guidance announced in three prior notices and a revenue procedure.
While the new regulations provide greater certainty on several issues flagged as requiring additional clarity, they do not incorporate many taxpayer suggestions to improve upon the prior guidance. The regulations slightly diverge from the earlier guidance in a few areas, such as the anti-avoidance and the foreign tax credit coordination rules.