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IRS Releases Proposed Regulations and Other Guidance Under Section 965
Posted by Barret Pinto on Mon, Dec 17, 2018 @ 12:09 PM

In October, the IRS released its proposed regulations interpreting Section 965, the provision in the Tax Cuts and Jobs Act (TCJA) that imposes a one-time “transition tax” to U.S. shareholders on the accumulated earnings and profits of certain U.S. owned foreign corporations. The transition tax is effected through a deemed repatriation mechanism. Not surprisingly, Section 965 continues to be a hot topic.

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Topics: Tax Cuts and Jobs Act, TCJA, Barret Pinto, Section 965, cfc, transition tax

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