Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!

Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965 “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight. The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More! →

Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax

In recent years, one of the most hotly debated tax issues in the United States has been the imposition by Internal Revenue Code Section 965 of the “transition tax” or “mandatory repatriation tax”, a provision of the Tax Cuts and Jobs Act (TCJA) enacted in 2017. The Supreme Court's recent decision to review the 9th … Continue reading Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax →

Section 965 Transition Tax – Enforcement & Audits Begin Next Month

By now most of my readers will have some familiarity with Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by the Tax Cuts and Jobs Act (“TCJA”) in 2017. My earlier blog post provided significant detail about this new tax law provision which is intended to move the US international tax … Continue reading Section 965 Transition Tax – Enforcement & Audits Begin Next Month →

Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief

NEWS FLASH! The Internal Revenue Service (IRS) announced today that there are limited circumstances in which it may be appropriate to provide relief from "double taxation" resulting from application of the repatriation tax under Internal Revenue Code Section 965, as amended by the Tax Cuts and Jobs Act (TCJA). The IRS has determined that in … Continue reading Repatriation/Transition Tax: IRS Announces Limited “Double Taxation” Relief →

Section 965 “Transition Tax”: It’s Time to Pay the Piper

Copied below is my post as it appeared (March 21 2018) on my former blog "Let's Talk About US Tax" when hosted by Anglo Info. By now I suspect many of my readers have heard about (and are shedding tears over) new Internal Revenue Code Section 965, and the “deemed repatriation” or “transition tax” introduced by … Continue reading Section 965 “Transition Tax”: It’s Time to Pay the Piper →