June 17, 2020 we posted LB&I Add New TCJA Compliance Campaign Including §965 Transition Tax & IRC §962 Election! where we discussed that IRS LB&I has added a new compliance campaign that will examine TCJA issues.
This new campaign will examine TCJA issues on a select pool of returns and then share what is learned by these examinations throughout the IRS.
Issues could include computation of:
- IRC §965 Transition Tax,
- IRC §951A GILTI Tax,
- IRC §250 50% Deduction for Corporate Taxpayer's,
- IRC §960 80% Deamed Paid Foreign Tax Credit and
- IRC §962 Election to be taxed as a Corporation.
Now Douglas O' Donald, Commissioner IRS Large Business and International division said on during a webcast hosted by the American Bar Section of Taxation, that:
The IRS Will Begin Distributing Letters and Placing People Into Its Audit Pipeline in "October" To Enforce The Transition Tax On Overseas Profits Included In The 2017 Tax Law!
The IRS expects to send thousands of letters to people who the agency expects may need to comply more fully with repatriation tax. Hundreds of others, who have flouted their related compliance responsibilities, will likely be placed into the agency's purview.
Offshore Voluntary Disclosures, if the IRS has initiated a civil examination of taxpayer's returns for any taxable year, regardless of whether the examination relates to undisclosed foreign financial assets, the taxpayer will not be eligible to use the Voluntary Disclosure Procedures.
Have a 2017 TCJA International Tax Problem?