Reporting Related to IRC Section 965 on 2017 Returns


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

Section 14103 of the Tax Reform Act of 2017, P.L 115-97, enacted on December 22, 2017, introduced Internal Revenue Code section 965. Pursuant to section 965, US shareholders are required 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. Therefore, certain taxpayers may have to pay tax under Section 965 when filing their 2017 tax returns. The IRS has published guidance to help taxpayers determine if they need to pay tax under Section 965 for tax year 2017, and how to report and pay such tax. See Questions and Answers about Reporting Related to Section 965 on 2017 Returns and Publication 5292, 2017 Reporting Instructions Under Section 965PDF, for information on who is required to report amounts under section 965 on a 2017 return. For specific reporting and filing instructions, please see Appendix: Q&A2.