Did You Overpay the Section 965 2017 Transition Tax?

Our comprehensive, no risk reviews deliver solutions for capturing Section 965 refunds and reducing installment payments. We offer our multinational clients a no-risk service and success-based fee engagements.

We provide final assurance that the section 965 transition tax was done correctly, calculation of Earning and Profits, net of all available foreign tax credits, to the fullest extent permissible.

What was Transition Tax -

Section 965 requires United States shareholders to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States. Very generally, a specified foreign corporation means either a controlled foreign corporation or a foreign corporation that has a United States shareholder that is a domestic corporation. Section 965 allows U.S. shareholders to reduce the amount of the income inclusion based on deficits in earnings and profits with respect to other specified foreign corporations.

The effective tax rates applicable to income inclusions are adjusted by way of a participation deduction set out in section 965(c). A reduced foreign tax credit applies to the inclusion under section 965(g). Taxpayers may elect to pay the transition tax in installments over an eight-year period

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