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On 1 August 2018 the US Treasury and the IRS released proposed regulations under Section 965 (the Proposed 965 Regulations). The Proposed 965 Regulations provide guidance relating to the ‘toll tax’ due upon the mandatory deemed repatriation of certain deferred foreign earnings. The Proposed 965 Regulations are the latest guidance with respect to Section 965 as amended by the 2017 tax reform legislation (the Act). 

Tax payers subject to Section 965 should immediately review the Proposed 965 Regulations and determine the impact, if any, on their toll tax liability.

In this video, Mike DiFronzo, International Tax Services leader for PwC’s Washington National Tax Services practice, looks at what's in the regulations and how taxpayer's tax returns might be affected.