On January 19, 2018, the Department of the Treasury and the Internal Revenue Service (collectively, “Treasury”) issued Notice 2018-13 (the “Notice”). The Notice provides additional guidance under Section 965, Treatment of deferred foreign income upon transition to participation exemption system of taxation, as amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97 (known as the Tax Cut and Jobs Act), which was enacted on December 22, 2017. See Notice 2018-07, for prior guidance issued under Section 965. In addition, the Notice provides guidance in connection with the repeal of Section 958(b)(4).