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IRS reminder: Q&As provide guidance about section 965 transition tax

IRS reminder: Q&As provide guidance about section 965

The IRS today issued a release that summarizes previously released IRS guidance concerning how taxpayers can comply with the transition tax under section 965 that is imposed on certain foreign earnings.


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Today’s IRS release—IR-2019-128 (July 16, 2019)—refers to a set of “questions and answers” (Q&As) concerning certain general issues about the section 965 transition tax, and specifically concerning: (1) how to make subsequent installment payments when the transition tax is paid over eight years; and (2) the filing of transfer agreements and consent agreements. These Q&As (last updated June 27, 2019) were previously reported in TaxNewsFlash (June 28, 2019).

The IRS release also notes that regulations have been issued as guidance under section 965 and related provisions of the 2017 U.S. tax law.

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