On 4 November 2019, the IRS Large Business and International (LB&I) Division published a new compliance campaign on its active campaigns webpage regarding the IRC 965 transition tax.
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Internal Revenue Code (IRC) 965, Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation, was part of the Tax Cuts and Jobs Act (TCJA) enacted on December 22, 2017. In general, IRC 965 requires United States shareholders, as defined under IRC 951(b…