The Tax Cuts and Jobs Act completely rewrote Section 965 to force a one-time repatriation of deferred earnings and profits in foreign corporations. It forces income recognition in the 2017 tax year, so there is not a lot of time to figure this one out!
I call this a workshop because the intention is for Rufus to talk a bit about the new law, then we will open it up for questions and input. Some of you out there are smart about Section 965, so please share with us. We can all pool our collective ignorance to become individually brighter. 🙂
Along those lines, it is important to bring in as many resources and perspectives as possible. I learn from reading what others write, and listening to what they say.
Here are some links I have collected from Out There on the Interwebs. I have omitted anything that requires a subscription.
If you know of other good Section 965 discussions, please tell me so I can update this page. Email = phil “at” hodgen.com.
You learn from slides? Here you go.
Here are better-than-average overviews, or deep dives on a particular slice of Section 965.