• Monte Silver, Tax lawyer

US Treasury & IRS grant expats relief for the June 15 Repatriation tax payment!

Hi All

I am very pleased to advise you that after three months hard work, the U.S. Treasury & IRS has granted expats certain relief from making the first payment under the Repatriation tax due by June 15.


The relief is as follows:


An US living abroad who is an individual US shareholder of a controlled foreign corporation shall incur no acceleration of the 8 year payment plan, or other penalties, for failing to make the June 15, 2018 payment, if the total tax due from the expat under the Repatriation tax (i.e. in all the eight years) is less than $1,000,000.


In other words, if an expat has less than total Repatriation tax liability of $1,000,000, there is no real reason to make the June 15, 2018 payment! To obtain this relief all that is required is to make the 965(h) election. See Q&A #7 in the IRS link below so see how and when to make the election.


This is very meaningful relief. To reach $1,000,000 in total tax liability, an expat must have at least $6.5M in earnings and profits held in cash form, or $12.5M in non-cash form. Chances are that after taking into account foreign tax credits possibly available, expats with more than these cash/non-cash amounts will be covered by the relief.


The relief has no impact on filing and 965 election deadlines, which remain unchanged – June 15 or October 15 2018. Thus one might consider the benefits of filing for the Oct 15 extension by June 15, 2018


To read the text of the relief from Treasury, see the attached. It is also available at: https://www.irs.gov/newsroom/questions-and-answers-about-reporting-related-to-section-965-on-2017-tax-returns

To read the related article on Financial Times, see www.ft.com/content/d428d4a2-6852-11e8-8cf3-0c230fa67aec


Webinar: To learn more about the relief, the election, how the $1,000,000 is calculated, and the June 15, 2018 deadline, click here to join a webinar:


Topic: The Treasury fix and considerations before June 15. Time: Thursday June 7. 10 am London Time, 11 am Germany/France, 12 pm Israel, 5 pm Beijing, 6 pm Seoul/Tokya


To register: whathttps://zoom.us/webinar/register/WN_isH3dLT5SqipHZZMDqwk4A


Treasury fix

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