: Taxpayers could elect to pay the transition tax over an eight-year period.
Section 965 fundamentally changed how foreign earnings are taxed in the U.S. by shifting from a "deferral" system to a "participation exemption" system. 965.rar
: 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. : Taxpayers could elect to pay the transition
The IRS has established strict guidelines for managing examinations and audits involving Section 965, as detailed in the Internal Revenue Manual (IRM) . : 965.rar
: Earnings were treated as if they were brought back to the U.S. (repatriated), regardless of whether they actually were.
: Impacted U.S. shareholders with at least a 10% stake in "specified foreign corporations."