New IRS Form 965 Line-by-Line: Reporting Section 965 Transition Tax Inclusions, Deductions, and Deferrals
Tying Forms 965 and 965-A to Required Schedules and 2017 Transition Tax Statement
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to reporting the repatriation provisions of the transition tax on new Form 965. The webinar presumes the attendees already are versed in the provisions of Section 965 and will bypass the fundamentals of the statute to offer a line-by-line review of reporting transition tax amounts, E&P and basis adjustments, and foreign tax credit calculations.
PLEASE NOTE: This is an advanced-level webinar; it assumes the attendee is already well-versed in the initial transition tax rules.
Outline
- 2017 tax year filings, calculations, and elections
- New Form 965 and instructions
- Schedules
- Schedule A calculates a U.S. shareholder's Section 965(a) inclusion amount
- Schedule B lists the accumulated post-1986 earnings and profits (E&P) of a deferred foreign income corporation
- Schedule C reports a U.S. shareholder's pro-rata share of the aggregate foreign E&P deficits from E&P deficit foreign corporations
- Schedule D determines the U.S. shareholder's pro-rata share of the cash position of each specified foreign corporation (SFC)
- Schedule E sets out the cash position of each SFC
- Schedule F (2018 tax year) and Schedule G (2017 tax year) compute the foreign taxes deemed paid
- Schedule H determines the foreign tax credits disallowed with respect to the section 965(a) inclusion
- Tying 2017 transition statement to Form 965 Filing
- 2019 Final and Proposed Section 965 Regulations
Benefits
The panel will discuss these and other important topics:
- Tying 2017 transition tax statement to subsequent years' Form 965 filings
- How the 2019 regulations impact prior and current years' transition tax reporting
- Breaking down the individual schedules attached to Form 965
- How to handle prior year's errors in completing Form 965
Faculty

Josh Gelernter
International Tax Senior Manager
Withum Smith+Brown
Mr. Gelernter's specialties are international tax services, primarily reorganizations and restructurings.
| Read MoreMr. Gelernter's specialties are international tax services, primarily reorganizations and restructurings.
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Dominick Warner, CPA
Managing Director - International Tax
BDO USA
Mr. Warner has over 14 years of experience specializing in all phases of U.S. and international taxation with... | Read More
Mr. Warner has over 14 years of experience specializing in all phases of U.S. and international taxation with concentrations in international consulting, U.S. and global compliance, and tax provision work. He has worked on a variety of international planning solutions for multinational companies. Specifically, the planning focusing on foreign cash tax reduction, effective tax rate planning, foreign cash repatriation, foreign cash management, and U.S. tax attribute management. Mr. Warner has experience working with inbound and outbound clients on global tax planning strategies. He also has experience managing large compliance engagements for clients.
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