The U.S. IRS has released an international practice unit, IRC 965 Transition Tax Overview. The general overview of the practice unit includes the following:
On December 22, 2017, IRC 965 was amended by "An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018," P.L. 115-97 (Tax Cuts and Jobs Act ["TCJA"]). As a result of the amendment, certain taxpayers are required to include in income an amount (section 965(a) inclusi…