A brief look at what’s been going on in North America.
The US Internal Revenue Service (IRS) has launched a transition tax compliance campaign. The campaign aims to check companies' compliance with the s.965 transition tax.
Section 965, included in the Tax Cuts and Jobs Act 2017, deems untaxed foreign earnings of US companies' foreign subsidiaries to have been repatriated, and imposes a one-time tax on them. The rules also apply retroactively to a foreign corporation's last tax year that began before 1 January 2018 and to a US shareholder's tax year in which the foreign corporation's year ends.
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