IRS Practice Unit: Transition Tax Overview (IRC §965)

Overview of tax code Section 965 transition tax, the IRS Large Business and International Concept Unit outlined in a practice unit released March 23. The IRS explains the rules under Section 965, who is subject to such rules, and which taxpayers may make certain elections. Section 965 requires U.S. 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, the IRS noted. Examples providing diagrams are provided. [IRS Practice Unit IRC 965 ...