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www.irs.gov

Section 965 transition tax - Internal Revenue Service

Section 965 requires United States shareholders (as defined under section 951 (b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatr...

www.goldinglawyers.com

What is Section 965 Transition Tax? What is Deferred Income?

Section 965 requires United States shareholders (as defined under section 951 (b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatr...

www.taxexecutive.org

Part V: Section 965Transition Tax | Tax Executive

Section 965 (g) has made foreign tax credits available to offset the transition tax subject to a “haircut.” Under Section 965 (h), taxpayers are permitted to elect to pay the transition tax in installments over eight years.

freemanlaw.com

The Section 965 Transition Tax - Freeman Law

Section 965 generally requires that shareholders pay a “transition” tax on their pro rata share of the untaxed foreign earnings of certain “specified foreign corporations.”