irs section 965 - EAS
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- Transition taxThe "transition tax" per section 965 of the Internal Revenue Code generally treats the accumulated post-1986 deferred foreign income (DFI) of a Specified Foreign Corporation (SFC) as Subpart F income. Section 965 (a) defines DFI as the greater of the DFI of such SFC determined as of November 2, 2017 or December 31, 2017.
www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-pr… - People also ask
- 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
It is important that all potentially impacted taxpayers are aware of the requirements under section 965. U.S. shareholders of specified foreign corporati… 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 … See more
Explore further
- https://www.irs.gov/instructions/i965
Any person that is required to include amounts in income under section 965(a) of the Code in …
- https://www.law.cornell.edu/uscode/text/26/965
- For purposes of sections 951 and 961, a foreigncorporation described in paragraph (1)(B) shall be treated as a controlled foreign corporation solely for purposes of taking into account the subpart F income of such corporation under subsection (a) (and for purposes of applying subsection (f)).
- https://www.usglobaltax.com/what-is-section-965
Oct 15, 2018 · Section 965 forms part of the US tax code, and deals specifically with US …
- https://home.kpmg/us/en/home/insights/2021/03/tnf...
Mar 23, 2021 · A reduced foreign tax credit applies to the inclusion under section 965(g). …
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