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Tax Notes Today International, August 17, 2020, published by Tax Analysts

RFA, PRA Changes Followed Subpart F High-Tax Regs

"Eleventh-hour changes to the preamble of the subpart F high-tax exception proposed regs may illustrate an IRS grappling with what and how much information to disclose under the Regulatory Flexibility Act (RFA) and Paperwork Reduction Act (PRA)."

"Addressing the final regs, American Citizens Abroad previously expressed disappointment at the IRS’s attempts to brush off the requirements of the RFA by stating that the data needed was not available and that taxpayers could simply choose not to apply the election."