IRS releases publication on how to calculate Section 965 amounts and make elections
On April 6, the IRS issued Publication 5292
explaining how to calculate the Section 965 transition tax enacted by the tax reform legislation, the so-called Tax Cuts and Jobs Act.
Section 965 generally requires U.S. shareholders to pay a transition tax on the untaxed earnings of certain specified foreign corporations. The information contained in the publication provides a summary of various components and computations contained in Section 965. The publication is consistent with items described in previously issued notices and other administrative guidance released by the IRS.
Among other things, the publication:
- Explains who may be required to report Section 965 amounts
- Defines numerous key items for purposes of Section 965
- Summarizes what elections can be made under Section 965
- Provides a detailed workbook to assist taxpayers in calculating Section 965 amounts
For more information on Section 965, check Grant Thornton’s prior coverage of Notice 2018-07
; Notice 2018-13
; Notice 2018-26
; Revenue Procedure 2018-17
, and the FAQ
Partner, Washington National Tax Office
+1 202 861 4104
Managing Director, Washington National Tax Office
+1 202 521 1543
Tax – Exp. Manager, Washington National Tax Office
+1 202 521 1509
Tax professional standards statement
This content supports Grant Thornton LLP’s marketing of professional services and is not written tax advice directed at the particular facts and circumstances of any person. If you are interested in the topics presented herein, we encourage you to contact us or an independent tax professional to discuss their potential application to your particular situation. Nothing herein shall be construed as imposing a limitation on any person from disclosing the tax treatment or tax structure of any matter addressed herein. To the extent this content may be considered to contain written tax advice, any written advice contained in, forwarded with or attached to this content is not intended by Grant Thornton LLP to be used, and cannot be used, by any person for the purpose of avoiding penalties that may be imposed under the Internal Revenue Code.
The information contained herein is general in nature and is based on authorities that are subject to change. It is not, and should not be construed as, accounting, legal or tax advice provided by Grant Thornton LLP to the reader. This material may not be applicable to, or suitable for, the reader’s specific circumstances or needs and may require consideration of tax and nontax factors not described herein. Contact Grant Thornton LLP or other tax professionals prior to taking any action based upon this information. Changes in tax laws or other factors could affect, on a prospective or retroactive basis, the information contained herein; Grant Thornton LLP assumes no obligation to inform the reader of any such changes. All references to “Section,” “Sec.,” or “§” refer to the Internal Revenue Code of 1986, as amended.