Mandatory repatriation (transition tax)
Mandatory repatriation (transition tax)
KPMG reports
- Feb 11, 2019 - KPMG report: Payment-acceleration events for section 965 installment payments and transfer agreements
- Jan 18, 2019 - KPMG report: Final regulations relating to “transition tax” under section 965
- Dec 12, 2018 - KPMG report: Initial impressions, FAQs on “transition tax” under section 965 for 2018 returns
- Aug 10, 2018 - KPMG report: Issues and analysis of section 965 proposed regulations
- Apr 2, 2018 - Initial impressions on Notice 2018-26 and guidance under section 965; special elections, reporting and paying the “transition tax”
Final regulations
Apr 9, 2019 - Corrections to final regulations under section 965
Feb 4, 2019 - Final regulations released to Federal Register, "transition tax” under section 965
Jan 30, 2019 - Final regulations under section 965; new version reflects changes
Jan 18, 2019 - KPMG report: Final regulations relating to “transition tax” under section 965
Jan 15, 2019 - Final regulations under section 965, text is released by IRS
Dec 6, 2018 - Final regulations pending OIRA review, section 965 transition tax
Proposed regulations
Oct 12, 2018 - Proposed regulations under section 965; public hearing on October 22
Aug 10, 2018 - KPMG report: Issues and analysis of section 965 proposed regulations
Aug 3, 2018 - Proposed regulations under section 965 released for publication in Federal Register
Aug 1, 2018 - Text of regulations, section 965 “transition tax”
Jul 16, 2018 - Status of expected regulations; section 965 “transition tax”
Notices
Oct 9, 2018 - Notice of additional guidance under section 965
Oct 1, 2018 - Notice 2018-78: Basis adjustment election under section 965 proposed regulations
Apr 2, 2018 - Notice 2018-26: Special elections under section 965, reporting and paying the “transition tax”
Jan 19, 2018 - Notice 2018-13: Additional guidance about “transition tax” on foreign earnings (new Code section 965)
Revenue procedures
Sep 6, 2018 - Rev. Proc. 2018-47: Excise tax relief for RICs with section 965 inclusions
Feb 15, 2018 - Rev. Proc. 2018-17: Effects of prohibited tax year changes for “specified foreign corporations”
Feb 14, 2018 - Rev. Proc. 2018-17: Initial impressions, section 965 and “specified foreign corporations” changing tax years
Feb 13, 2018 - Rev. Proc. 2018-17: Requests by foreign corporations changing tax year, application of section 965
IRS Chief Counsel Memoranda
Aug 3, 2018 - IRS Chief Counsel memo: Overpayments and section 965(h)
FAQs, forms, and other developments
Jun 28, 2019 - IRS provides Q&As concerning section 965 (including transfer and consent agreements)
Feb 11, 2019 - KPMG report: Payment-acceleration events for section 965 installment payments and transfer agreements
Jan 7, 2019 - IRS final forms, instructions for implementing U.S. tax law changes
Dec 18, 2018 - IRS releases draft instructions for Form 965 series
Dec 12, 2018 - IRS provides draft version of Form 965 instructions
Dec 12, 2018 - KPMG report: Initial impressions, FAQs on “transition tax” under section 965 for 2018 returns
Dec 12, 2018 - IRS provides FAQs, “transition tax” under section 965 for 2018 returns
Nov 7, 2018 - IRS adds FAQs on filing transfer agreements relating to Code section 965
Oct 8, 2018 - IRS allows more time for filing transfer agreement under section 965
Sep 6, 2018 - IRS provides draft versions of schedules for Form 965
Sep 5, 2018 - IRS provides draft versions of Form 965 and Schedule H
Jul 2, 2018 - IRS new “compliance campaigns” include section 965 transition tax (under new tax law)