New Section 965: Deemed Repatriation of Foreign-Source Income

Determining Deferred Foreign Income, Cash vs. Cash Equivalent Assets, Shareholder Liability, Use of NOLs and More

A live 90-minute CLE/CPE webinar with interactive Q&A

Thursday, June 21, 2018

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, May 25, 2018

or call 1-800-926-7926

This CLE/CPE webinar will guide counsel and tax professionals on the deemed repatriation provisions of the new tax reform bill, focusing on the specific compliance aspects requiring U.S. shareholders to recognize all post-1986 deferred foreign-source income. The panel will discuss the necessary steps and legal requirements of determining deferred foreign-source income, the taxation of cash vs. cash equivalent assets, the use of NOLs and other mechanisms to ensure compliance, and potential benefits under the new tax law.


The new tax law requires U.S. shareholders to report their share of the previously untaxed deferred income of foreign corporations. Due to revised international tax provisions under the new tax bill, this transition tax seeks to balance the switch to a territorial tax system, possibly allowing certain income of U.S. based corporations derived through foreign subsidiaries to be exempt from U.S. taxation.

The new law enacts a deemed repatriation of income, requiring that U.S. shareholders report as income all post-1986 earnings from any deferred foreign income corporation. The applicable tax rate on this income is calculated by way of a deduction that ensures a 15.5% rate on cash and an 8% rate on all other deferred income. The tax bill also allows a taxpayer to pay the tax without interest over an eight-year period.

The IRS has issued guidance in an attempt to provide answers to lingering questions, primarily focusing on the determination and reporting of deferred foreign-source income in compliance with Section 965. Counsel and tax professionals must be aware of the intricacies of this transition tax such as determining its applicability to specific U.S. shareholders, cash vs. cash equivalent assets, the use of NOLs and other items to ensure compliance and potential benefits.

Listen as our panel discusses the complex provisions regarding deemed repatriation of foreign-source income, its applicability to defined U.S. shareholders and best practices in ensuring compliance.



  1. Implications and requirements of Section 965 deemed repatriation provisions
  2. U.S. shareholders subject to the recognition of foreign source-income
  3. Determining and reporting deferred foreign-source income under the new tax rules
  4. Best practices and tax planning methods for counsel to ensure compliance and obtain tax benefits


The panel will review these and other key issues:

  • Determining the applicability of Section 965 to specific U.S. shareholders
  • Identifying what is cash vs. non-cash for purposes of foreign-source income and applicable tax rates
  • The issues presented by new international tax provisions and IRS guidance
  • The use of NOLs and determining taxable foreign-source income
  • Best practices to ensure compliance and planning methods for potential tax benefits


Santa, Mishkin
Mishkin Santa, JD LLM

International Tax Director
The Wolf Group

Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift &...  |  Read More

Carmichael, Holly
Holly Carmichael

Of Counsel, Tax
Grellas Shah

With 25+ years of experience serving multinational clients, Ms. Carmichael has extensive experience in corporate...  |  Read More

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