Page 694 - Large Business IRS Training Guides
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Why Section 965 Exists:

                                                                                              Overview








        •	  Before tax reform,
                                                     international taxation was generally a
                                                          taxation with a deferral
              worldwide system                          of

              component.







                                 reform, the system is generally a territorial or
        •	  After tax
              exemption system
                                                         of taxation.






        •	  Section 965 taxes
                                                     certain deferred foreign income that

              has accumulated over time.













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