Remedying Incorrect Section 965 Inclusions After Final Regulations
Determining How to Make Forward Adjustments to 965(h) Installment Amounts Absent IRS Guidance
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to remedying late or incorrect deemed repatriation filings required under Section 965 in the absence of detailed guidance from the IRS. The panel will describe recent IRS guidance offering relief from estimated tax penalties for failure to accurately calculate tax on deemed repatriation after making a Section 965(h) election, and discuss strategies for requesting relief for missed elections, as well as correcting defective calculations and adjustments of incorrect carryforwards of 2017 overpayments.
- Section 965(h) elections
- IRS guidance finalized in January 2019 and adjustments to prior proposed regulations
- Consolidated return provisions
- Exemptions to cash positions
- Anti-avoidance rule application
- Fiscal year taxpayers with initial payments due in 2019
- Treatment of incorrectly applied overpayments
- Correcting underpaid installments before receiving notice from IRS
- Responding to notice of underpayment under Sections 6654 or 6655
- Requesting abatement
- Correcting 965(h) installment underpayments and making forward adjustments to correct 2017 filing on Form 965
The panel will discuss these and other essential topics from IRS guidance:
- How will overpayments on transition tax installments be treated?
- When are taxpayers eligible for temporary relief from underpayment penalties?
- Correcting transition tax underpayments
- Filing Amended Tax Return Form 1040-X to make 965(h) installment election correctly
- How fiscal year taxpayers must handle initial deemed repatriation payments
International Tax Senior Manager
Mr. Gelernter's specialties are international tax services, primarily reorganizations and restructurings.| Read More
Mr. Gelernter's specialties are international tax services, primarily reorganizations and restructurings.Close
Patrick J. McCormick, J.D., LL.M.
Drucker & Scaccetti
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting... | Read More
Mr. McCormick specializes in the areas of international taxation, tax compliance, and offshore reporting obligations. He published national articles and given numerous national and local presentations on assorted areas of tax and estate planning law, including international tax and offshore compliance issues. His latest article on PFICs is titled Tax Reporting Implications of Foreign Mutual Funds. He is licensed to practice in the States of New Jersey, Florida, and Georgia, and the Commonwealth of Pennsylvania.Close