IRS Guidance on Section 965 Toll Tax Calculation, Elections

The IRS has issued Publication 5292, "How to Calculate Section 965 Amounts and Elections Available to Taxpayers," dated Apr 6, 2018, to assist taxpayers with calculating their 2017 'toll tax' due on the mandatory deemed repatriation of certain deferred foreign earnings. The 18-pa...

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Bibliographic Details
Published in:Journal of International Taxation 2018-07, Vol.29 (7), p.33-35
Main Authors: DiFronzo, Michael, Sotos, David, Collins, Marty, Perez, Ruth, Curran, Kevin
Format: Article
Language:English
Subjects:
Amendments
Earnings
Foreign tax credits
Government agencies
Internal Revenue Code
International taxation
Liability
Reporting requirements
Stockholders
Tax controversies
Tax credits
Tax Cuts & Jobs Act 2017-US
Tax elections
Tax reform
Tax returns
Tax services
Taxes
Taxpayers
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Summary:The IRS has issued Publication 5292, "How to Calculate Section 965 Amounts and Elections Available to Taxpayers," dated Apr 6, 2018, to assist taxpayers with calculating their 2017 'toll tax' due on the mandatory deemed repatriation of certain deferred foreign earnings. The 18-page Publication also addresses certain aspects of the toll tax, such as who is required to report, pay, and make certain elections. The Publication is the latest administrative guidance related to amended Section 965 under the Tax Cuts and Jobs Act. Taxpayers should consult the Publication as they consider elections related to the toll tax, and as they prepare their 2017 tax returns. The Publication is the latest IRS guidance intended to assist taxpayers in calculating the toll tax under amended Section 965. Taxpayers subject to amended Section 965 should review the Section 965 Workbook to calculate their overall toll tax liability and review the Publication to better understand certain aspects about who is required to report, pay, and make certain elections under amended Section 965.
ISSN:1049-6378