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Repatriation Tax Audits: Managing IRS Enforcement Actions and Strategies for Tax Professionals

Calculating Section 965 Inclusions, IRS Regulations, Cash vs. Non-Cash or Non-Liquid Assets, Foreign Tax Credits

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Wednesday, November 4, 2020

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel and professionals an in-depth analysis of the challenges of repatriation tax audits and techniques for handling IRS enforcement actions. The panel will discuss recent IRS initiatives and standards for the repatriation of foreign sourced income, calculating Section 965 inclusions, issues regarding cash vs. non-cash or non-liquid assets, and determining taxpayers' foreign tax credits, as well as offer best practices for handling repatriation tax audits.


The IRS announced the enforcement of Section 965's repatriation tax. Taxpayers must focus on their calculation of earnings and profits, classification of assets, and methodology used to determine foreign tax credits to identify potential audit triggers and avoid unintended tax liability.

Under current tax law, U.S. taxpayers have the opportunity to defer U.S. tax on foreign income and profits. However, many individuals and companies--even the largest multinational firms--will need to repatriate some of or all foreign-source earnings. The tax consequences of repatriating income depend upon not only the character of the gain or income held abroad but also the nature of the foreign entity that earned the income.

The IRS will start conducting repatriation tax audits focused on certain issues with taxpayers' calculation of Section 965 inclusions. Tax counsel and advisers must have a thorough grasp of tax rules and operational implications of repatriating foreign-source income held offshore to avoid costly tax consequences.

Listen as our experienced panel provides a practical guide to the tax opportunities, pitfalls, and strategies of repatriating foreign-source income. The panel will also offer strategies for tax counsel and advisers for handling IRS enforcement actions and audits.



  1. The tax regime for foreign-source income and gains
  2. Impact of foreign entity classification on repatriation treatment
  3. Repatriation options
    1. Cash vs. non-cash or non-liquid assets
    2. Deductions and calculations
  4. Audit triggers and handling IRS enforcement actions


The panel will review these and other key issues:

  • Repatriation issues for individual and small business taxpayers
  • Identifying deductions and credits which would reduce taxable income on repatriation
  • Recognizing repatriation audit triggers
  • Navigating IRS enforcement actions and audits


Jiang, Yan
Yan Jiang, CPA, CFA

Senior Manager
Green Hasson & Janks

Mr. Jiang focuses his practice on providing tax consulting and compliance services to private equity entities,...  |  Read More

Marshall, S. Starling
S. Starling Marshall

Crowell & Moring

Ms. Marshall focuses her practice on litigation, complex IRS audits, and administrative appeals. She also regularly...  |  Read More

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