Page 264 - International Taxation IRS Training Guides

IRS Objective: Understanding US MNE’s

Tax Planning Strategies

in absence of Indefinite Reinvestment
 Pre-TCJA

Assertion (IRA):

• Securities
and Exchange Commission (SEC) reporting
would need to estimate how much of their
companies
foreign earnings
would eventually be repatriated

• A tax accrual was made for earnings which were designated
to be repatriated
in the future
tax expense increased ETR
– This

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