IRS provides guidance on Section 965 ‘toll tax’ calculation and elections

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April 2018


The IRS has issued Publication 5292, ‘How to Calculate Section 965 Amounts and Elections Available to Taxpayers’ (the Publication), dated April 6, 2018, to assist taxpayers with calculating their 2017 ‘toll tax’ due upon the mandatory deemed repatriation of certain deferred foreign earnings.  The 18-page Publication also addresses certain aspects of the toll tax, such as who is required to report, pay, and make certain elections. The Publication is the latest administrative guidance related to amended Section 965 under the 2017 tax reform reconciliation act (the Act).

Taxpayers should consult the Publication as they consider elections related to the toll tax, and as they begin preparing their 2017 tax returns. 

The takeaway

The Publication is the latest IRS guidance intended to assist taxpayers in calculating the toll tax under amended Section 965.     

Taxpayers subject to amended Section 965 should review the Section 965 Workbook in order to calculate their overall toll tax liability.  Taxpayers also should review the Publication in order to better understand certain aspects about who is required to report, pay, and make certain elections under amended Section 965.

Contact us

Michael DiFronzo

Partner, Washington National Tax Services ITS Leader, PwC US

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