Proposed regulations addressing the amendment and application of section 965 of the Internal Revenue Code of 1986, as amended, were recently issued. Section 965 generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of a specified foreign corporation. The proposed regulations provide specific requirements for making elections regarding the application of section 965, which generally are required to be made with a taxpayer’s 2017 federal income tax return for calendar-year See more +
Proposed regulations addressing the amendment and application of section 965 of the Internal Revenue Code of 1986, as amended, were recently issued. Section 965 generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of a specified foreign corporation. The proposed regulations provide specific requirements for making elections regarding the application of section 965, which generally are required to be made with a taxpayer’s 2017 federal income tax return for calendar-year taxpayers (or by October 9, 2018, for taxpayers that did not file for extensions).
This Bottom Line videocast discusses:
two important examples in the proposed regulations addressing the application of the gain reduction and basis adjustment rules for distributions from a specified foreign corporation during an inclusion year
the election to shift basis to reflect the sharing of deficits under section 965
the implication of variations to fact patterns See less -
