On December 2, 2020, Robert M. Russell participates in a panel entitled “A Closer Look at Section 965 Campaigns” at D.C. Bar Taxation Community Tax Audits and Litigation Series.

Description: Under the TCJA, Section 965 requires that US shareholders, including individuals, that directly or indirectly own at least 10% of the stock of a specified foreign corporation, include in gross income their share of the corporation’s accumulated deferred foreign income. Panelists will discuss how the IRS is approaching Section 965 compliance through the campaigns, methodologies for calculating and reporting tax under Section 965, privilege issues, and potential penalties for noncompliance. 

Speakers:

Robert M. Russell, Kostelanetz & Fink, LLP

Orrin D. Byrd, Director Field Operations East LB&I Cross Border Activities (CBA)

Kathleen Saunders Gregor, Ropes & Gray LLP

Click here for more information and to register.