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KPMG report: Payment-acceleration events for section 965 installment payments and transfer agreements

Payment-acceleration events for section 965

Many taxpayers elected under section 965(h) and Reg. section 1.965-7(b) to pay their section 965(a) liability under the installment method, over a period of eight years. Nevertheless, if an “acceleration event” occurs, the taxpayer’s section 965(a) liability becomes immediately due and payable.


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Taxpayers that elected to spread out their transition tax payments over the eight-year period are in danger of triggering all remaining payments. A report from KPMG considers both common and less visible acceleration events, describes the use of transfer agreements to protect installment treatment, and warns taxpayers to exercise caution.


Read a February 2019 report [PDF 94 KB] prepared by KPMG LLP: What’s News in Tax: Slow Down and Avoid Payment Acceleration Events for Section 965 Installment Payments and Transfer Agreements

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