By David Fischer and Teresa Abney (August 17, 2020, 6:06 PM EDT) -- Beginning this fall, taxpayers should expect to see IRS enforcement efforts with respect to their Section 965 repatriation tax liabilities. The IRS has announced that it will soon start sending soft letters to taxpayers and placing other taxpayers in its audit pipeline. After some background on the repatriation tax, we discuss five things taxpayers should know about the upcoming Section 965 enforcement efforts.
In general, Section 965 required U.S. shareholders owning 10% or more of the vote or value of a specified foreign corporation to pay a one-time toll charge, or repatriation tax, on offshore profits accumulated since 1986.
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