Shareholders, Foreign Earned Income

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on 3/31/2025

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

The Federal Anti-Deferral Rules For Foreign Income –Just A Reminder, There’s No Easy Way Out

Farrell Fritz, P.C. on 7/20/2020

It’s Complicated- Coming to grips with the U.S. tax treatment of the foreign-sourced income of a closely held domestic business, and of commercial transactions involving such a business and its related foreign entities,...more

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

Foodman CPAs & Advisors on 11/27/2019

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

Relief on the Way to U.S. Individuals Owning Stock in a "Controlled Foreign Corporation" - Treasury Department's Proposed...

Holland & Knight LLP on 3/6/2019

• The U.S. Department of the Treasury has released proposed regulations dealing with the application of the recent U.S. tax reform to U.S. shareholders of a "controlled foreign corporation" (CFC). • A foreign corporation...more

IRS releases Notice 2018-26 - retroactively disregarding certain accounting method changes and entity classification elections

Eversheds Sutherland (US) LLP on 4/10/2018

The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more

House of Representatives Releases First Draft of Tax Reform Bill

Jones Day on 11/7/2017

The Situation: On November 2, 2017, the House Ways and Means Committee released its first draft of much-anticipated comprehensive U.S. tax reform legislation as the "Tax Cuts and Jobs Act." Chairman Brady’s markup of the bill...more