Shareholders, Internal Revenue Code (IRC), Foreign Corporations

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

Supreme Court Rules Against Taxpayers in IRC Section 965 Case

McDermott Will & Emery on 6/24/2024

On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more

Not the Day We Are Waiting For - SCOTUS Today

Epstein Becker & Green on 6/21/2024

With a significant mass of cases left to decide and only a few weeks to issue the opinions, the U.S. Supreme Court has reduced the backlog by four yesterday. None of them, however, resolves the future of Chevron deference or...more

Supreme Court to Decide: No Realization Means No Moore Income Tax?

Rivkin Radler LLP on 10/13/2023

Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...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

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

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

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