Sunday, January 23, 2005
Margie Rollinson, Michael Mundaca & Jose Murillo (all with Ernst & Young, Washington, D.C.) have published Notice 2005-10: Welcome (Mostly) Guidance on the New Repatriation Provisions (also available on the Tax Analysts web site as Doc 2005-1237, 2005 TNT 13-34). Here is the Conclusion:
Notice 2005-10 provides welcome guidance regarding the repatriation provisions of section 965, and is mostly good news for taxpayers. Although some may be disappointed that stock redemptions and dividend payments are not permitted investments and that cash equivalents are not considered cash, the notice does provide some very generous rules regarding permitted investments, including broad rules on worker compensation and benefits, debt repayment, qualified plan funding, business acquisitions, and advertising. The notice also provides rational and administrable rules regarding the development and implementation of the DRIP, as well as reasonable general administrative and compliance rules.