What, if anything, should have been done with respect to income that was accumulated but not distributed before the new rules kicked in?
Congress did not want the new favorable 100% DRD provisions of Section 245A to apply to income the U.S. tax on which had been deferred. Section 965 provides special rules for the accumulated earning of a deferred foreign income corporation accumulated in taxable years beginning before January 1, 2018. This video reviews the way the new Section 965 works.
Runtime: 9 minutes
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