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Expert Analysis

Heads IRS Wins, Tails Taxpayers Lose In Section 965 Notice

By Ellen McElroy, Mike Resnick and Danielle Lowe (July 2, 2018, 2:52 PM EDT) -- The U.S. Department of the Treasury and the Internal Revenue Service recently issued Notice 2018-26,[1] which provides guidance under Section 965 — referred to as the transition tax — of the Internal Revenue Code. Section 965 was added by Public Law 115-97, commonly known as the Tax Cuts and Jobs Act of 2017.[2] Section 965 imposes a transition tax on previously untaxed foreign earnings of foreign subsidiaries of U.S. companies by deeming those earnings to be repatriated....

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