The End of Eternity: Anomalies in Transition to Territoriality

20 Pages Posted: 8 Nov 2018 Last revised: 6 Dec 2018

Date Written: April 30, 2018


The law formerly known as the Tax Cuts and Jobs Act of 2017 imposed a U.S. tax on the undistributed foreign earnings of certain foreign corporations. This tax on deemed repatriation income, under new section 965 of the Code, has some broad and surprising effects, particularly for individual shareholders of foreign corporations.

This Special Report in Tax Notes discusses some issues under section 965, such as the shareholders and corporations affected by the tax, the amount of the section 965(c) deduction in 2017 and 2018, and the various elections to defer the tax.

Keywords: section 965, deemed repatriation

Suggested Citation

Zhang, Libin and Rabinovits, Joshua, The End of Eternity: Anomalies in Transition to Territoriality (April 30, 2018). Tax Notes, Vol. 159, No. 5, 2018. Available at SSRN:

Libin Zhang (Contact Author)

Fried Frank ( email )

One New York Plaza
New York, NY NY 10004
United States

Joshua Rabinovits

Roberts & Holland LLP ( email )

United States

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