US Cross-Border Tax Blog

Published by W.L. Dueck LLP

Posts filed under ‘Transition Tax’

Steven Flynn

US Transition Tax – A Fourth Update

In mid-April, there is usually a race against time by taxpayers and accountants to meet US tax filing deadlines. The normal US tax filing deadline for the 2017 year for individuals and certain US entities is Tuesday, April 17th (a few days later than the usual April 15th due to weekends and a US holiday on Monday).  Entering the “race against time” this year is the Internal Revenue Service itself, who on Friday April 13th published more guidance on the… Read More

Steven Flynn

US Transition Tax – Next Update

On April 2nd, the IRS and US Treasury issued more guidance on the US Transition Tax enacted by the Tax Cuts and Jobs Act (“TCJA”) in December 2017.  As the US moves to a territorial tax system for profits earned outside the US, this provision assesses a tax rate on accumulated earnings and profits in specific non-US corporations owned by certain US corporations and US individuals. Our previous blog entries explaining the tax and IRS/US Treasury updates can be found… Read More

Steven Flynn

US Transition Tax – Update

On March 13th, the Internal Revenue Service provided further guidance on how US taxpayers should report activity subject to the US Transition Tax on their 2017 US income tax returns.  Our previous blog describing the tax and its impact to US taxpayers can be found HERE. This IRS guidance references earlier IRS updates and provides instruction on how to complete US federal income tax returns, file elections and make US federal income tax payments.  Full details of the IRS’s guidance… Read More

Steven Flynn

US Transition Tax

In December 2017, the US enacted The Tax Cuts and Jobs Act (“TCJA”). Amongst many changes to US tax law is a move to a territorial tax system where US corporate shareholders of non-US corporations can repatriate profits earned outside the US without additional US tax. As part of this transition, many US shareholders are now subject to US federal income tax on past profits remaining in certain non-US corporations commonly referred to as Transition Tax (or Repatriation Tax). The… Read More