In 2017, Congress passed the most significant 税 legislation since 1986 – the 税 Cuts and Jobs Act of 2017 (TCJA). 根据TCJA，美国.S. shareholders were required to pay a transition 税 on un税ed foreign earnings of certain specified foreign corporations, as if those earnings had been repatriated to the U.S.
The “transition 税” per Section 965 of the Internal Revenue Code generally treats the accumulated un税ed post-1986 deferred foreign income of a specified foreign corporation as Subpart F income.
Under Section 965, corporations are expected to pay 15.5% transition 税 on accumulated earnings and profits (E&P) related to cash 资产. Other 资产 are subject to an 8% transition 税. Slightly higher rates apply to individuals.
The purpose of the IRS Streamlined Filing Compliance Procedures is to bring 税payers into U.S. 税 and reporting compliance. 具体地说, it is to bring non-willful applicants with foreign income, 资产, 账户, and investments into compliance. Generally, this includes the 最近的 3 years for which the U.S. 税 return due date (or properly applied for extended due date) has passed.
The IRS has updated the guidelines for the Streamlined Filing Compliance Procedures so that now the 税payers that own foreign entities and have a Section 965 inclusion using the Streamlined Filing Compliance Procedures must come into compliance with the Section 965 transition 税 in their submission and include the 税 year in which the transition 税 inclusion might occur (generally 2017 and/or 2018) even if that 税 year would not be within the standard three-year lookback Streamlined period. 换句话说, the lookback period for any submission to the Streamlined Filing Compliance Procedures involving 税payers with a Section 965 inclusion in 2017 must include 税 year 2017 and include all subsequent 税 years.
也, the election to pay net 税 liability in installments under Section 965(h)(1) is not available for 税payers 提交ting delinquent returns under the Streamlined Filing Compliance Procedures.
The program still provides 税payers a way to come into compliance with increasingly stricter requirements. For more information on how you might qualify for the Streamlined procedures, please contact your current Schneider Downs representative for additional information.
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