Section 965 Archives - Schwartz International

Schwartz International, as a Unique International Tax Firm, Loves Challenges!

Leave a Comment / Uncategorized / By Marc Schwartz

For those interested in tax treaty implications of the latest US tax reform, we recently published an article with Tax Notes International that took a specific position on an issue being highly contested in the international tax community. While we did not request anyone to “challenge” our conclusion, we stated that we would love to […]

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New Guidance on Forced / Deemed Repatriation Under IRC Section 965

Leave a Comment / News & Blog / By Marc Schwartz

By Marc Schwartz So naïve of me. When will I learn? When Congress passed the December 2017 tax legislation, it created such complexity that my head still hurts. Focusing on the international provisions didn’t reduce the complexity. While I’ll get to the point in a minute, I still feel somewhat bad for the IRS.

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International Tax Reform 4.0 – Transition Tax on Foreign Earnings – New Guidance

Leave a Comment / News & Blog / By Marc Schwartz

In Notice 2018-07 (“Notice”), the IRS has moved quickly to provide preliminary guidance under Internal Revenue Code Section (“§”) 965, as 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, enacted on December 22, 2017. We’re impressed by

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