Corporate Taxes, IRS, Transition Tax

Weekly IRS Roundup July 15 – 19, 2019

McDermott Will & Emery on 7/22/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15 – 19, 2019. July 16, 2019: The IRS issued a news release concerning its provision of...more

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

Foodman CPAs & Advisors on 12/10/2018

On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more

IRS Extends Date for Section 965 Liability Transfer Agreement

Orrick, Herrington & Sutcliffe LLP on 10/16/2018

Code section 965 establishes a transition tax (the “Transition Tax”), which applies to U.S. corporations (and in certain cases, U.S. partnerships and individuals) having control over unrepatriated offshore earnings as of the...more

Treasury Provides Details on Transition Tax

Jones Day on 8/16/2018

Just in time for tax return filing, much-needed guidance has been issued on the application of the transition tax on foreign subsidiaries' earnings imposed under last year's tax reform. On August 1, 2018, proposed...more

Section 965 Proposed Regulations Issued

Butler Snow LLP on 8/3/2018

On August 1, 2018, the Internal Revenue Service and the Department of the Treasury issued proposed regulations on the Section 965 transition tax, which was enacted under the Tax Cuts and Jobs Act. Section 965 levies a...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

LB&I adds new campaigns on virtual currency and transition tax

Eversheds Sutherland (US) LLP on 7/11/2018

On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more

Corporate Taxes › Internal Revenue Service › Transition Tax