Future Regulations. In the Proposal, Treasury and the IRS stated that they will continue to study the issues related to these documentation regulations and may propose in the future a modified version of them. Such future regulations would be substantially simplified and streamlined to reduce the burden on U.S. corporations and yet would still require sufficient documentation and other information for tax administration purposes. Any such regulations would be proposed with a prospective effective date to allow sufficient lead-time for taxpayers to design and implement systems to comply with those regulations. While the Proposal is only in proposed regulations form and not yet finalized, it states that taxpayers may rely on the Proposal until it is formally adopted.
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