By David Sites and Cory Perry ( November 13, 2018, 4:16 PM EST) -- The Internal Revenue Service released Notice 2018-78 on Oct. 1, giving taxpayers additional time to make the basis adjustment election under the Internal Revenue Code Section 965[1] proposed regulations. For a limited time only, the basis adjustment election may allow taxpayers to transfer tax basis in the stock of certain foreign entities with losses over to the stock of certain profitable foreign entities. Taxpayers will now have up to 90 days after publication of the final regulations to make the basis election if their tax returns were otherwise due before the final regulations are published. Taxpayers may also revoke an election previously made up to 90 days after the publication of the final regulations. Additional time is only provided to determine whether to make the basis adjustment election. It has not been extended to other Section 965 elections....