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IRC Section 965 Transition Tax Services

The Internal Revenue Code (IRC) Section 965 was amended as a result of the U.S. tax reform and imposed mandatory repatriation (transition tax) on many individual and corporate U.S. Shareholders of foreign corporations. The tax is retroactive for some U.S. shareholders and punitive. Limited guidance has been issued by the Department of Treasury and the Internal Revenue Service (IRS), with more guidance and regulations to come.

U.S. Tax IQ is here to help. We have both U.S. tax lawyers and U.S. accountants on the team, which puts us in a unique position to assist our clients in navigating the complex world of international taxation and, more specifically, the IRC Section 965 transition tax. Whether you are a U.S. shareholder of a Canadian or foreign corporation, a Canadian tax accountant or Canadian lawyer who believes your clients may be subject to the transition tax, but may benefit from a better understanding of how the new law operates, we are here to help.

IRC Section 965 Transition Tax


Determination of the tax year with respect to which the transition tax should be calculated;
Review of client’s organizational and corporate structures to identify tax planning opportunities;
Review of client’s facts, organizational and corporate structures, to determine if the transition tax applies;
Determination of foreign tax credit applicable percentage amount and its availability for reducing the IRC Section 965 transition tax, if applicable;
Earnings and profits studies, a determination of post-1986 accumulated earnings and profits for U.S. federal income tax purposes to ensure correct amount of IRC Section 965 inclusion;
Planning strategies on mitigating the tax impact of the transition tax;
Preparation and filing of U.S. tax returns for all categories of filers subject to the IRC Section 965 transition tax;
Developing and documenting tax filing positions for the 2017 and 2018 tax years relevant to the IRC Section 965 reporting and elections;
Assistance with elections under IRC Section 965;
Representation of clients on IRS audit and at Appeals.
Determination of the tax impact of the IRC Section 965 transition tax on U.S. tax expatriation, relevant to U.S. citizens renouncing or relinquishing their U.S. citizenship or Green card holders (long-term residents) abandoning their Green cards;
Developing tax positions and documenting them in memoranda and tax opinions to protect clients from penalties;

Please feel free to set up a consultation on the top right corner of our website, to speak with one of our tax professionals. We can assist in supplementing your tax knowledge to assist your clients, help prepare the calculations and help create the necessary statements that are required to be filed with your tax return.

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