Section 965 Foreign Deemed Repatriation Transition Tax: Final Regulations
Identifying Cash Positions, Treatment of Consolidated Entities, Loss Treatments, Correcting Underpayments, Anti-Avoidance Rules
This program is postponed. New date TBD.
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide corporate tax advisers with a detailed and practical guide to the repatriation provisions of the Section 965 transition tax in the wake of the most recent IRS final regulatory guidance. The panel will discuss E&P and basis adjustments, foreign tax credit calculations, and special rules governing affiliated groups and consolidated returns.
- Shareholders subject to new foreign provisions
- Definition of "specified foreign corporations"
- Identifying and calculating accumulated E&P subject to deemed repatriation transition tax
- Netting provisions
- Calculating tax
- 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
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 use of NOLs and determining taxable foreign-source income
- New guidance governing consolidated returns and loss allocations
- Application of anti-avoidance rules to E&P reducing transactions