IRS To Extend Transfer Agreement Deadline

Section 965, enacted by the TCJA, imposes a one-time transition tax on certain U.S. shareholders. The proposed regulations under section 965 require corporations that have elected to make transition tax payments pursuant to an eight-year installment plan and have transferred substantially all of their assets to another corporation file certain transfer agreements by October 9. At the ABA Tax Conference, Daniel McCall, IRS deputy associate chief counsel, stated that the IRS plans to release imminently additional guidance on how and where to file such agreements, and thus, taxpayers will not be required to file by the October 9 deadline.

Read more:  Transition Tax Guidance Will Extend Transfer Agreement Due Date

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