The Broad Implications of Section 965 Repatriation

Repatriation provisions under the American Jobs Creation Act of 2004

(section 965 of the Internal Revenue Code) offer an opportunity to bring profits earned overseas back to the United States with greatly reduced tax consequences. But section 965 is as much a forward-looking strategic matter as it is a tax matter.

Key findings

• Repatriating under section 965 is highly complex and poses risks to business operations, financial performance, and financial reporting, both now and in the future.
• Executing a successful repatriation under section 965 requires careful consideration of a company’s unique financial, operating, and strategic position.

Sponsored by Deloitte Tax LLP

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