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Tax Planning › Internal Revenue Code (IRC) › Foreign Earned Income

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Proskauer - Tax Talks

Tax Proposals Potentially Being Considered by the U.S. House Budget Committee in Reconciliation

Proskauer - Tax Talks on

On January 17, 2025, multiple news outlets and other sources reported the existence of a memorandum circulated by the U.S. House of Representatives Budget Committee to the House Republican Caucus (the “Memorandum”) containing...more

McDermott Will & Schulte

[Webinar] Virtual Tax Forum | GILTI and Subpart F High Tax Exception Regulations: Practical Aspects and Implications (New Guidance...

McDermott Will & Schulte on

The final and proposed regulations under sections 951A and 954 of the US Internal Revenue Code contain certain rules that may present planning opportunities—or possibly onerous results—depending on a taxpayer’s specific fact...more

McDermott Will & Schulte

Weekly IRS Roundup May 4 – May 8, 2020

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

Foodman CPAs & Advisors on

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

McDermott Will & Schulte

Tennessee Joins Other States in Excluding GILTI and 965 Income from the Tax Base

McDermott Will & Schulte on

On May 8, Governor Bill Lee (R) signed SB 558, which provides for the exclusion of 95% of Global Intangible Low-Taxed Income (GILTI) and foreign earnings deemed repatriated under IRC section 965 (965 Income) from the tax base...more

Foodman CPAs & Advisors

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

Foodman CPAs & Advisors on

On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more

Pierce Atwood LLP

Maine Revenue Services Explains IRC § 965 Deferred Foreign Income Taxation

Pierce Atwood LLP on

Maine Revenue Services (MRS) issued guidance and amended the Maine corporate income tax return instructions last week to explain Maine’s conformity to federal taxation of deferred foreign income, also called deemed...more

Foodman CPAs & Advisors

Taxpayers may have to pay Section 965 Transition Tax when filing their 2017 Tax Returns

Foodman CPAs & Advisors on

Section 965 of the Internal Revenue Code requires certain U.S. Shareholders to pay a transition tax on the untaxed foreign earnings of certain Specified Foreign Corporations as if those earnings had been repatriated to the...more

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