FROM THE OFFICE OF PUBLIC AFFAIRS To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®. January 13, 2005 Treasury and IRS Announce Guidance on Repatriation WSHINGTON DC – The Treasury Department and IRS today announced the first in a series of notices that will provide guidance for Internal Revenue Code Section 965, enacted as part of the AJCA in October 2004, allows Section 965 contains several limitations on the repatriated dividends that are eligible for the reduced tax rate. One key requirement is that the repatriated funds must be invested by the company in the Today's notice provides detailed guidance regarding the parameters for a domestic reinvestment plan and the kinds of investments in the "Given the importance of the new repatriation provision to U.S. companies, coupled with the immediate effective date of the provision and its temporary nature, issuance of prompt guidance was a major priority," said Eric Solomon, Treasury's Acting Deputy Assistant Secretary for Tax Policy. "In today's notice we focused on addressing the most urgent questions, particularly the required "This guidance will allow taxpayers to be able to comply with the new provision regarding the repatriation of earnings while at the same time giving the IRS examination function the necessary roadmap to ensure compliance with the new rules," said IRS Chief Counsel Don Korb.
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