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ON DEMAND: Tax Audits and Litigation Series: A Closer Look at Section 965 Campaigns

Credit: 0 Credit Hours
Run Time: 78 Minutes
**This is a previously recorded program, originally recorded on December 2, 2020.
Join Orrin Byrd, Director of Field Operations East for LB&I’s Cross Border Activities and practitioners Kat Gregor of Ropes & Gray LLP and Robert Russell of Kostelanetz & Fink, LLP for a discussion of the IRS’s Section 965 campaigns. Under the TCJA, Section 965 requires that US shareholders, including individuals, that directly or indirectly own at least 10% of the stock of a specified foreign corporation, include in gross income their share of the corporation’s accumulated deferred foreign income. Panelists will discuss how the IRS is approaching Section 965 compliance through the campaigns, methodologies for calculating and reporting tax under Section 965, privilege issues, and potential penalties for noncompliance.
Sponsored by: Tax Audits and Litigation Committee of the D.C. Bar Taxation Community
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  • Orrin D. Byrd, Director Field Operations East LB&I Cross Border Activities (CBA)
  • Robert M. Russell, Kostelanetz & Fink, LLP
  • Kathleen Saunders Gregor, Ropes & Gray LLP
On Demand Registration Fees:
$0  D.C. Bar Community Member - Premium
$15 D.C. Bar Law Student Community Member
$20 D.C. Bar Community Member
$20 Government/Nonprofit
$40 D.C. Bar Member
$60 Non-member
Please select Individual Registration to register.

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