The U.S. IRS announced on 17 January 2020 that it is willing to consider requests for relief from double taxation related to repatriation tax under section 965, as amended by the Tax Cuts and Jobs Act (TCJA).
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IR-2020-16, January 17, 2020
WASHINGTON — The IRS announced today that the agency has become aware of limited circumstances in which it may be appropriate to provide relief from double taxation resulting from application of the repatriation tax under section 965, as amended by the…