IRS Provides Additional Q&A Guidance on Section 965
On July 16, 2019, the IRS released additional guidance in a Q&A format with respect to section 965. Enacted by the Tax Cuts and Jobs Act, section 965 generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of certain foreign corporations. The guidance includes information on making subsequent installment payments and filing transfer and consent agreements.
View the Q&A: General Section 965 Questions and Answers