Andersen Managing Director Joe Calianno's comments were included in the recent Tax Notes article,Basis Adjustment Letter Ruling Portends Good News for Taxpayers.The article covers IRS Letter Ruling 202304008 (January 30, 2023) regarding the calculation of Sec. 961(b)(2) gain and distributions from a controlled foreign corporation (CFC). Joe was quoted in the article as saying that he agrees with the result of the letter ruling and that it may signal the approach IRS will take on forthcoming regulations on previously taxed earnings and profits (PTEP).