The 2017 tax reform act (the Act) includes significant international tax provisions, including Section 965, which imposes a ‘toll charge’ on deemed repatriated earnings. On August 1, Treasury and the IRS released a 249-page set of proposed regulations under Section 965, addressing a wide range of issues regarding the toll charge. PwC on August 9 hosted a webcast featuring PwC specialists who discussed the proposed Section 965 regulations. This Insight highlights some of those discussions.
Taxpayers should evaluate which provisions in the proposed regulations affect their Section 965 liability and recompute their Section 965 calculations accordingly. They should have a plan for the next three months, and determine staffing needs and how to collect the required information.
