AICPA submits comments on PTEP basis adjustments regulations
The American Institute of CPAs (AICPA) has submitted comments to the US Department of the Treasury and the Internal Revenue Service (IRS) on proposed regulations concerning Previously Taxed Earnings and Profits (PTEP) and related basis adjustments.
The regulations under Sections 959 and 961 of the Internal Revenue Code are designed to prevent double taxation of US shareholders with income from controlled foreign corporations (CFCs).
The proposed regulations aim to clarify the rules governing the PTEP regime, including stock basis adjustments, foreign currency gains or losses, and the allocation of foreign tax credits.
The AICPA's recommendations seek to improve these regulations for taxpayers.
One key suggestion from the AICPA is to explicitly allow taxpayers to rely on the proposed regulations until they are finalised.
Additionally, the AICPA recommends extending the model for PTEP distributed through partnerships to foreign nongrantor trusts under Section 959.
The AICPA also proposes to coordinate the rules of subchapter J with subpart F by treating PTEP as distributed from the CFC to the foreign nongrantor trust.
Subsequent distributions to beneficiaries should be considered recoveries of that PTEP.
If the above recommendation is not adopted, the AICPA suggests that distributions of excludable PTEP to beneficiaries be treated similarly to tax-exempt income or trust principal, which would not trigger current taxation under the distributable net income model or the throwback anti-deferral regime.
Furthermore, under Section 961, the AICPA advises extending the concept of derived basis to foreign nongrantor trusts, allowing these entities to have a derived basis in CFC shares.
AICPA Tax Policy & Advocacy senior manager Reema Patel said: 'There is some uncertainty regarding taxpayer's continued reliance on Notice 2019-01 and the portions of the proposed regulations that apply the 2019 Notice provisions.'
'The lack of an express statement in the proposed regulations creates uncertainty among taxpayers about which aspects of the proposed regulations may be viewed as a reasonable interpretation of the statute and existing final regulations. Therefore, we recommend that Treasury and the IRS expressly allow taxpayers to rely on the proposed regulations in their entirety until they are finalised.'
Meanwhile, in a recent move, AICPA named Rahul Gupta as the chairman of its Financial Reporting Executive Committee.
"AICPA submits comments on PTEP basis adjustments regulations" was originally created and published by The Accountant, a GlobalData owned brand.
The information on this site has been included in good faith for general informational purposes only. It is not intended to amount to advice on which you should rely, and we give no representation, warranty or guarantee, whether express or implied as to its accuracy or completeness. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.
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Zanidatamab is currently under regulatory review in the EU for second-line BTC and is being evaluated in multiple global clinical trials as a potential best-in-class treatment for patients with multiple HER2-expressing cancers. Zymeworks is rapidly advancing a robust pipeline of wholly-owned product candidates, leveraging its expertise in both antibody-drug conjugates and multispecific antibody therapeutics targeting novel pathways in areas of significant unmet medical need. Phase 1 studies for ZW171 and ZW191 are now actively recruiting with an investigational new drug application for ZW251 planned for mid-2025. In addition to Zymeworks' pipeline, its therapeutic platforms have been further leveraged through strategic partnerships with global biopharmaceutical companies. For information about Zymeworks, visit and follow @ZymeworksInc on X. 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Investors should not place undue reliance on forward-looking statements. The above assumptions, risks and uncertainties are not exhaustive. Forward-looking statements are made as of the date hereof and, except as may be required by law, Zymeworks undertakes no obligation to update, republish, or revise any forward-looking statements to reflect new information, future events or circumstances, or to reflect the occurrences of unanticipated events. Investor inquiries: Shrinal Inamdar Senior Director, Investor Relations (604) 678-1388 [email protected] Media inquiries: Diana Papove Senior Director, Corporate Communications (604) 678-1388 [email protected] _________________________________ 1 According to publicly available information, as of the approval announcement on May 29, 2025, zanidatamab is the only HER2-targeting bispecific antibody approved by the National Medical Products Administration (NMPA) for HER2-high-expression biliary tract cancer (BTC). 2 Chinese Society of Clinical Oncology (CSCO). Diagnosis and Treatment Guidelines for Biliary Malignant Tumors (2024). 3 Vogel A, Bridgewater J, Edeline J, et al. Biliary tract cancer: ESMO Clinical Practice Guideline for diagnosis, treatment, and follow-up. Ann Oncol. 2023;34(2):127-40. doi:10.1016/ 4 Chakrabarti, S., 5 Choong-kun Lee, et al. 2025 ASCO GI Abstr. #629. 6 Hiraoka N, et al. Hum Pathol. 2020 Nov:105:9-19. 7 Vivaldi C, et al. Oncologist. 2020 Oct;25(10):886-893. 8 Meric-Bernstam, F., Beeram, et al. Zanidatamab, a novel bispecific antibody, for the treatment of locally advanced or metastatic HER2-expressing or HER2-amplified cancers: a phase 1, dose-escalation and expansion study. The Lancet Oncology. 2022; doi: 10.1016/S1470-2045(22)00621-0. 9 Chinese Society of Clinical Oncology (CSCO) Biliary Tumor Expert Committee Expert consensus on precise detection and molecular diagnosis of biliary malignant tumors [J]. Journal of Clinical Oncology, 2024, 29 (8): 797-804. 10 Weisser NE, Sanches M, Escobar-Cabrera E et al. An anti-HER2 biparatopic antibody that induces unique HER2 clustering and complement-dependent cytotoxicity. Nature Communications. 2023 Mar 13;14(1):1394. doi: 10.1038/s41467-023-37029-3. Disclaimer: The above press release comes to you under an arrangement with GlobeNewswire. Business Upturn takes no editorial responsibility for the same.
