News & Analysis as of

Internal Revenue Code (IRC) Transition Tax Foreign Earned Income

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Foodman CPAs & Advisors

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

Foodman CPAs & Advisors on

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

McDermott Will & Emery

IRS Issues Transition Tax Compliance Campaign

McDermott Will & Emery on

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more

Foodman CPAs & Advisors

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

Foodman CPAs & Advisors on

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

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