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I.R.S. Offers Additional Guidance on Code §965 Transition Tax

Volume 5 No 3    /    Read Article

By Rusudan Shervashidze and Stanley C. Ruchelman

On the way toward a dividends received deduction for certain dividends paid by foreign subsidiaries, Congress enacted a one-shot income inclusion of all post-1986 earnings from C.F.C.’s and foreign corporations having 10% U.S. Shareholders that are corporations. In March, the I.R.S. issued an F.A.Q. providing additional guidance on open issues for 2017 tax returns. Rusudan Shervashidze and Stanley C. Ruchelman explain the mechanics of the income inclusion and an election to defer payments for eight years, sometimes more.    See more →