Section 965 FAQ Updates
In general, IRC section 965 requires United States shareholders, as defined under section 951(b) of the Code, to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States. The IRS has added more information to the Section 965 FAQs
webpage. In addition, Publication 5292, How to Calculate Section 965 Amounts and Elections Available to Taxpayers
, now reflects Tax Cuts and Jobs Act changes and includes the "Workbook to Assist in Calculating Section 965 Amounts."