965 tax liability definition - EAS

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  1. Net tax liability

    Section 965 Liability means the “ net tax liability ” of the Merck Group under Section 965 (h) (6) (A) of the Code. Sample 1 Sample 2 Sample 3 Based on 4 documents Examples of Section 965 Liability in a sentence Section 2.5 Certain Transaction Taxes, Section 965 Liability, and Breaches of Representations or Covenants.
    www.lawinsider.com/dictionary/section-965-liability
    www.lawinsider.com/dictionary/section-965-liability
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  2. People also ask
    What is section 965 transition tax?
    What is section 965? Section 965 requires United States shareholders (as defined under section 951 (b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States.
    www.irs.gov/businesses/section-965-transition-tax
    What is IRS Form 965?
    Form 965 (Schedule G) Foreign Taxes Deemed Paid by Domestic Corporation for tax years of foreign corporations whose last taxable year, beginning before January 1, 2018, ends during the U.S. shareholder's 2017 tax year. 2019. Form 965 (Schedule H) Amounts Reported on Forms 1116 and 1118 and Disallowed Foreign Taxes.
    www.irs.gov/forms-pubs/about-form-965-a
    What is a 965 loss?
    Section 986(c) on section 965(a) PTI – Gain or loss on section 965(a) PTI is measured based on fluctuations between 12/31/17 and the distribution date. Such gain or loss is haircut in the same proportion as the reduction by a section 965(c) deduction amount.
    www2.deloitte.com/content/dam/Deloitte/global/Docume…
    What is IRC 965?
    What is the Repatriation Tax (IRC 965): With the introduction of the Tax Cuts and JOBS Act back in 2017/2018 – came the introduction of the repatriation act under Internal Revenue Code Section 965. The idea behind the repatriation act, was that the US government would tax all of the previously untaxed income of a foreign corporation from 1986 through 2017 — which was then submitted by Taxpayers to IRS with their 2017 or 2018 tax return.
    www.goldinglawyers.com/what-is-the-repatriation-tax-act …
    Search for: What is IRC 965?
  3. https://www.irs.gov/businesses/section-965-transition-tax

    Section 965 requires United States shareholders (as defined under section 951(b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States. Very generally, a specified foreign corporation means either a controlled forei… See more

    IRS is working to alert potentially impacted taxpayers about new tax filing and tax payment obligations arising under recently revised Internal Revenue Code section 965.An overview of sectio… See more

    Taxpayers should be aware of their income tax obligations under section 965. See irs.gov for details on the manner of computation and reporting of the new section 965 tax(including i… See more

    It is important that all potentially impacted taxpayers are aware of the requirements under section 965. U.S. shareholders of specified foreign corporations need to be aware that an income inclusion may be required for 2017 and certa… See more

  4. https://www.irs.gov/newsroom/general-section-965...
    • Eligible section 965(h) transferors and transferees may enter into Transfer Agreements (see Q2) with the IRS to defer payment of the remaining amount of the section 965(h) net tax liability or section 965(i) net tax liability that would otherwise become due as a result of certain acceleration or triggering events. See §§1.965-7(b)(3)(iii) and 1.965...
    See more on irs.gov
  5. Calculating & Reporting: Sec. 965 Toll Tax Liability

    https://gtmtax.com/tax-insights/articles/sec-965-toll-tax-liability

    Jun 28, 2018 · A taxpayer’s Sec. 965 net tax liability is defined in Sec. 965 (h) (6) (A) as the excess of: “ (i) such taxpayer’s net income tax for the taxable year

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      What is a 965 liability?
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    • https://www.lawinsider.com/dictionary/unadjusted-section-965-tax-liability

      Define Unadjusted Section 965 Tax Liability. means, with respect to a Sub-Group and a U.S. federal income tax year of the DowDuPont U.S. Consolidated Group, the liability under Section …

    • https://www.lawinsider.com/dictionary/pro-forma-section-965-tax-liability

      Define Pro Forma Section 965 Tax Liability. means, with respect to a Sub-Group and a U.S. federal income tax year of the DowDuPont U.S. Consolidated Group, the notional Tax liability under …

    • https://www.irs.gov/forms-pubs/about-form-965-a

      Sep 21, 2022 · About Form 965-A, Individual Report of Net 965 Tax Liability. Form 965-A is used by individual taxpayers and entities taxed like individuals to report a taxpayer's net 965

    • https://www.lawinsider.com/dictionary/section-965-liability

      Section 965 Liability means the amount representing the “net tax liability” of HII under Section 965(h)(6)(A) attributable to the SpinCo Business, as determined by HII. Promptly following the …

    • https://www.irs.gov/instructions/i965a

      In addition, this form is used to report the determination of a taxpayer’s net 965 tax liability, whether or not to be paid in installments; the payments of a net 965 tax liability to be paid in …

    • https://www.cpajournal.com/2018/11/14/demystifying...

      Nov 14, 2018 · The old section 965 was the one-year Temporary Dividends Received Deduction introduced as part of the American Jobs and Creation Act of 2004. The new section 965, enacted by the Tax Cuts and Jobs Act of 2017 …

    • https://www.irs.gov/pub/irs-pdf/i965a.pdf

      This form is used to report a taxpayer’s net 965 tax liability for each tax year in which a taxpayer must report or pay section 965 amounts. In addition, this form is used to report the …



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