965.rar

: Generally applied to the last taxable year of the foreign corporation beginning before January 1, 2018. Key Compliance and IRS Procedures

Section 965 fundamentally changed how foreign earnings are taxed in the U.S. by shifting from a "deferral" system to a "participation exemption" system.

Taxpayers had specific elections to manage the potentially high tax liability resulting from Section 965. 965.rar

For taxpayers facing adjustments or disputes regarding their 965 tax liability, the IRS provides several resolution tools.

: A process to expedite the resolution of tax disputes while the case is still under the jurisdiction of the Large Business and International (LB&I) division. : Generally applied to the last taxable year

: Certain S-corporation shareholders were allowed to defer payment of the tax until a "triggering event" occurred.

: Aimed at resolving unagreed issues more quickly through the Independent Office of Appeals. Taxpayers had specific elections to manage the potentially

The IRS has established strict guidelines for managing examinations and audits involving Section 965, as detailed in the Internal Revenue Manual (IRM) . :