Section 965 Repatriation (Completed)

Date: Thursday, June 20, 2019
Instructor: Rita M. Ryan, Tonya S. James
Begin Time:  12:00pm Pacific Time
1:00pm Mountain Time
2:00pm Central Time
3:00pm Eastern Time
CPE Credit:  2 hours for CPAs
2 hours Federal Tax Related for EAs and OTRPs
2 hours Federal Tax Law for CTEC

The Section 965 repatriation provisions of the TCJA required U.S. shareholders of specified foreign corporations to report and pay a one-time transition tax on previously untaxed foreign income. This one-time repatriation tax was the initial step in the shift to a more territorial tax and posed immediate challenges for tax preparers and advisors with clients with offshore holdings as the provisions required reporting on 2017 tax filings.

This webinar will provide tax advisors with a practical guide on the deemed repatriation provisions of Section 965. The webinar will address the calculation of the 965 inclusion and deduction, the reporting of the transition tax on 2017 and 2018 returns, the IRS’ final regulatory guidance, foreign tax credit calculations, and the guidance related to three specific areas of noncompliance: where a taxpayer incorrectly applies carryforward of overpayment credits under Sections 6654 and 6655; where a taxpayer fails to make a correct first installment payment under a 965(h) election; or where a taxpayer fails to timely make the 965(h) election.

Who Should Attend
Tax preparers and advisors with clients with offshore holdings as the provisions required reporting on 2017 tax filing.

Topics Covered

  • Practical guide on the deemed repatriation provisions of Section 965
  • Calculation of the 965 inclusion and deduction
  • Reporting of the transition tax on 2017 and 2018 returns
  • IRS' final regulatory guidance
  • Foreign tax credit calculations
  • Guidance related to three specific areas of noncompliance

Learning Objectives

  • Identify deemed repatriation provisions of Section 965

Level
Basic

Instructional Method
Group: Internet-based

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
None

Advance Preparation
None

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