Tax Warrior Chronicles

IRS OFFERS PENALTY AND FILING RELIEF ON TRANSITION TAX

Posted on Fri, Jun 08, 2018

By: Yi Yang, CPA, MBA

 

Since our last post on the mandatory Section 965 Transition Tax, the IRS has provided additional guidelines on the reporting procedures for 2017 tax returns.  In today’s post, we’ll delve deeper into the guidelines and learn how you may secure some penalty and filing relief.

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Part IV (of 4) MANDATORY TRANSITION TAX ON CERTAIN DEFERRED FOREIGN INCOME

Posted on Wed, Apr 11, 2018

By: Yi Yang, CPA, MBA and Steven Braun, CPA

 

Here we are at the final part of this four-part series on the Mandatory Transition Tax.  The first three parts, explained which taxpayers are subject to the Transition Tax, the due dates of the Transition Tax for different taxpayers, the complexity in determining taxable income for the Transition Tax, and two key components in determining taxable income subject to the Transition Tax: accumulated post-1986 deferred foreign income (DFI) and U.S. shareholder’s aggregated foreign cash position. In Part IV, we provide examples illustrating the calculations of the Transition Tax.

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Part III (of 4) MANDATORY TRANSITION TAX ON CERTAIN DEFERRED FOREIGN INCOME

Posted on Tue, Mar 27, 2018

By: Yi Yang, CPA, MBA and Steven Braun, CPA

 

So, if the title of our blog didn’t bore you, the topic is likely relevant, and you read Parts I and II where we explained which taxpayers are subject to the Transition Tax, the due dates of Transition Tax for different taxpayers, and the complexity in determining taxable income for Transition Tax.  Today, in Part III, we address two key components in determining taxable income subject to Transition Tax:

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Part II (of 4)- Mandatory Transition Tax on Certain Deferred Foreign Income 

Posted on Tue, Feb 13, 2018

By: Yi Yang, CPA, MBA and Steven Braun, CPA

 

In Part I of this four-part series, we explained which taxpayers are subject to the new Transition Tax and the due dates for different taxpayers.  Today, in Part II, we discuss the complexity in determining taxable income for the Transition Tax. 

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Mandatory Transition Tax on Certain Deferred Foreign Income - Part I

Posted on Tue, Jan 23, 2018

By: Yi Yang, CPA, MBA and Steven Braun, CPA

 

As of January 1, 2018, the 2017 Tax Cuts & Jobs Act (TCJA) changes the taxation regime for U.S. multinational corporations, especially U.S.-owned controlled foreign corporations (CFC).  The international provisions in TCJA introduce a new territorial system for the taxation of foreign company income.  Before these new tax provisions take effect, the new law imposes a mandatory one-time tax (the “Transition Tax”) on certain foreign company earnings traditionally not subject to U.S. federal income tax until distributed as a dividend to U.S. shareholders.

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