Video

  • 9 minutes

Pre-2018 Accumulated Earnings

 

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