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IOWA WORKFORCE DEVELOPMENT UNEMPLOYMENT INSURANCE APPEALS BUREAUCRACY M CLARKE ClaimantAPPEAL 16AUI12323CLT ADMINISTRATIVE LAW JUDGE DECISIONFRAUENSHUH HOSPITALITY GROUP OF M Employer OC: 10/16/16

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What is section 965?

Section 965 is a provision of the Internal Revenue Code that requires certain US shareholders of specified foreign corporations to pay a one-time transition tax on untaxed foreign earnings.

Who is required to file section 965?

US shareholders of specified foreign corporations are required to file section 965 if they meet the criteria outlined in the provision.

How to fill out section 965?

To fill out section 965, taxpayers must report information related to their specified foreign corporations and calculate the transition tax owed based on the rules provided in the provision.

What is the purpose of section 965?

The purpose of section 965 is to transition to a new territorial tax system and prevent the erosion of the US tax base by taxing previously untaxed foreign earnings of US shareholders.

What information must be reported on section 965?

Taxpayers must report information such as the amount of post-1986 foreign earnings and profits of specified foreign corporations and the US shareholders' pro rata share of those earnings.

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