The US IRS’s Large Business and International (LB&I) division on November 4 announced the addition of a new compliance campaign focusing on the Section 965 transition tax. Section 965 requires US shareholders of some foreign corporations to pay a tax on previously untaxed foreign earnings in a deemed repatriation.
The Sevice explains the new campaign as follows:
The treatment stream will include conducting examinations as well as providing technical assistance to teams on 965, with a focus on identifying and addressing taxpayer populations with potential material compliance risk. The campaign will start with 2017 returns and generally require looking at both the 2017 and 2018 tax returns. It is anticipated that returns selected as part of the 965 campaign will also be risked and, if appropriate, examined for other material issues, especially issues related to TCJA planning.
LB&I currently has 53 compliance campaigns underway.
Be the first to comment