Audits May Increase For US Shareholders Of Foreign Cos.

Law360 (June 21, 2019, 1:45 PM EDT) -- Although taxpayers have already calculated and reported their Section 965 deemed repatriation tax, Section 965 will have a continuing impact. First, taxpayers are well advised to review their approach to estimated taxes. The IRS refuses to issue refunds of overpaid income taxes to taxpayers who elected to pay Section 965 taxes in annual installments, effectively penalizing taxpayers who conservatively overpay estimated taxes. Second, the IRS plans extensive enforcement efforts. A recent U.S. Treasury Inspector General for Tax Administration report highlights these issues, including recommendations for the IRS concerning the IRS enforcement plan.

Overview: The Deemed Repatriation Tax

Section 965 of the...

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