Statute section
IRC section 965
Treatment of deferred foreign income
Country
United States
Section
965
Updated
2026-05-20
Operative text
Section 965, enacted by TCJA, required U.S. shareholders of certain foreign corporations to include in income their share of post-1986 accumulated deferred foreign earnings as a one-time transition tax. The headline rates were 15.5 percent for cash and equivalents and 8 percent for non-cash assets.
Amendment history
2017-12-22
Pub. L. 115-97
TCJA enacted Section 965 as the one-time transition tax.
Cross-references
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Related citations
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This entry cites
- StatuteIRC §951
Cited by
Primary sources
- 26 U.S.C. section 965Verified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.