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IRS LETTER 6311 WARNS ABOUT SECTION 965 COMPLIANCE

We give a brief overview of IRC Section 965 and the transition tax, discuss the impact of the Letter 6311 warnings, and give our take on how to respond to the IRS.

NEW IRS COMPLIANCE CAMPAIGN FOCUSES ON DEFERRED FOREIGN INCOME

The IRS has just announced its newest compliance campaign – focusing on transition tax compliance for foreign company owners. The new campaign will home in on whether a company’s “deferred foreign income” was correctly determined for purposes of applying the transition tax.

TRANSITION TAX RATES

We review the basics of the transition tax and its calculation and demonstrate why the transition tax rate should increase next year.
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