IRS LB&I Division Announces Section 965 Compliance Campaign
On November 4, the IRS Large Business and International Division (LB&I) announced a new compliance campaign directed at promoting compliance with section 965. Section 965, enacted by the Tax Cuts and Jobs Act, generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of certain foreign corporations. The LB&I campaign will involve conducting examinations and “focus on identifying and addressing taxpayer populations with a potential material compliance risk.”
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