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IRC 965 Transition Tax Overview

Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States

IRC 965 is a provision of the Tax Cuts and Jobs Act (TCJA) of 2017 that requires certain taxpayers to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States.

The following persons/entities reported amounts under section 965 of the code on their tax return:

US shareholders of a deferred foreign income corporation.

Certain direct/indirect domestic partners in domestic partnerships that are United States shareholders of specified foreign corporations.

Shareholders in a S corporation that is a United States shareholder of a specified foreign corporation.

Certain beneficiaries of another pass-through entity that is a United States shareholder of a specified foreign corporation.

Certain beneficiaries of a cooperative association that is a United States shareholder of a specified foreign corporation.

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▸Contents — Internal Revenue Manual Part 3. Submission Processing

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