United States

Tax Reform: Proposed Section 965 Regulations’ “Transition Tax”

Friday August 17, 2018 12:00 PM - 1:00 PM EDT
From KPMG TaxWatch

KPMG TaxWatch

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The 2017 tax reform legislation introduced a “transition tax” under section 965 that requires the mandatory repatriation of previously untaxed earnings of U.S. multinationals’ “specified foreign corporations.” On August 1, 2018, the U.S. Treasury Department and IRS released much-anticipated proposed regulations —almost 250 pages in length—on calculating and reporting this tax. The proposed regulations implement prior government guidance with greater detail, some unexpected results, and some further unanswered questions. 

KPMG LLP (KPMG) is pleased to invite you to a TaxWatch Webcast that will discuss the potential implications of the proposed section 965 regulations. Professionals from KPMG’s Washington National Tax practice, including Seth Green, Doug Holland, and Steve Massed, will discuss:

  • Open questions answered by the proposed regulations
  • Lingering uncertainties and potential areas for comments to address
  • The impact of the proposed regulations on legal positions and 2017 tax year returns.

Seth Green

Principal, Co-lead of International Tax, Washington National Tax, KPMG LLP

Douglas G. Holland

Managing Director, International Tax, Washington National Tax, KPMG LLP

Stephen M. Massed

Managing Director, International Tax, Washington National Tax, KPMG LLP