[ Offshore Tax ] Could the Section 965 Transition Tax Lead to a Wealth Tax? скачать в хорошем качестве

[ Offshore Tax ] Could the Section 965 Transition Tax Lead to a Wealth Tax?

[ Offshore Tax ] Could the Section 965 Transition Tax Lead to a Wealth Tax? On December 22, 2017, IRC 965 was 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 (Tax Cuts and Jobs Act [“TCJA”]). As a result of the amendment, certain taxpayers are required to include in income an amount (section 965 (a) (inclusion amount) based on the accumulated post-1986 deferred foreign income of certain foreign corporations that they own either directly or indirectly through other entities. Other taxpayers may have inclusions in income under IRC 951(a) because of IRC 965 due to ownership of deferred foreign income corporations (“DFICs”) through pass-through entities that are themselves U.S. shareholders of DFICs. In general, IRC 965 requires United States shareholders, as defined under IRC 951(b), to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States. Very generally, IRC 965 allows taxpayers to reduce the amount of such inclusion based on deficits in earnings and profits (“E&P”) with respect to other specified foreign corporations. The effective tax rates applicable to such income inclusions are adjusted through a participation deduction set out in IRC 965 (c). A reduced foreign tax credit applies to the inclusion under IRC 965(g). Generally, a specified foreign corporation means either a controlled foreign corporation (“CFC”), as defined under IRC 957, or a foreign corporation (other than a passive foreign investment company, as defined under IRC 1297, that is not also a CFC) that has a United States shareholder that is a domestic corporation. Certain taxpayers may make certain elections with respect to IRC 965. These elections include: An election to pay the section 965 net tax liability over eight years. An election by S corporation shareholders to defer payment of the section 965 net tax liability with respect to such S corporation until a triggering event. An election by real estate investment trusts to take both section 965(a) inclusions and the corresponding section 96 (c) deductions into account over eight years. An election not to apply a net operating loss. An election to use an alternative method to calculate post-1986 earnings and profits (post-1986 E&P). An election to use basis adjustments under Treas. Reg. 1.965-2(f). TIMESTAMPS: 0:00 INTRO 1:03 Section 965 Transition tax 2:45 Control Foreign Corp Taxes 4:10 Case of Charles G. Moore and Kathleen Moore 5:22 Supreme Court decision on appeal 7:20 The 16th amendment constitutional 8:52 OUTRO --------------------------------------- OUR CHANNEL OFFERS: Updated daily, we help 6, 7, and 8-figure International Entrepreneurs, Expats, Digital Nomads, and Investors legally minimize their global tax burden and protect their wealth. Join Amazon's best-selling author, Derren Joseph, in exploring the offshore financial world. SUBSCRIBE TO OUR CHANNEL FOR MORE FREE INFORMATION: https://www.youtube.com/c/TaxesforInt... -------------------------------------------------- WATCH OTHER VIDEOS:    • [ Offshore Tax ] Is Earned Income tax-free...      • [ Offshore Tax ] What is the main tax adva...      • [ Offshore Tax ] Taxation of Crypto in Can...   -------------------------------------------------- Here are 4 ways we can help you: SIGN UP for free webinars on US Expat Taxes and International Entrepreneur Taxes: https://htj.tax/events/ STREAM premium educational videos: https://htj.tax/youtube/ CONTACT us for tax optimization consults over Zoom: https://www.htj.tax/contact/ High Net Worth? We can QUOTE for doing your "US-International" tax returns. FOR MORE DETAILS, CONNECT WITH US: ✉ Contact us at help@advancedamericantax.com -------------------------------------------------- FOLLOW US ON:. 🌍 Check our website: https://htj.tax/ 🎙️ Listen to our podcast: https://podcast.htj.tax/ 📸 Add us on Instagram:   / htj.tax   🐦 Add us on Twitter:   / derren43   📕 Add us on Facebook:   / htj.tax   💼 Contact Derren on LinkedIn:   / derren-joseph-ea-0345332   #LiveThatInternationalLife #TransitionTax #WealthTax #InternationalTax #internationaltax #taxplanning #taxes #internationalbusiness #offshore #expats #investors #offshorecitizen