The IRS today issued an advance version of Rev. Proc. 2018-47 to provide excise tax relief for certain regulated investment companies (RICs) that have inclusions under section 951(a)(1) by reason of section 965 for the excise tax year ended on December 31, 2017.
Rev. Proc. 2018-47 [PDF 21 KB] applies to any amount that section 965 would (but for this revenue procedure) require a RIC to include in gross income under section 951(a)(1) for the RIC’s excise tax year ended on December 31, 2017 (a "2017 inclusion").
Rev. Proc. 2018-47 states that IRS will not challenge a RIC’s treatment of a 2017 inclusion if the RIC:
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