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The One and Only: The Transition Tax Under Section 965

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The One and Only: The Transition Tax Under Section 965
IRS Program #:
CTEC #: 6257-CE-0261
CE: 1 IRS & 1 CTEC credit
Speaker: Rita Ryan, J.D, LLM

Under the Tax Cuts and Jobs Act (TCJA), Congress enacted a one-time tax in section 965. This tax is the so-called “transition tax”. Under this tax, U.S. shareholders of certain foreign corporations are taxed on non-repatriated profits. Although this tax applied only once, the implications of such tax are still being felt. In some cases, the tax is still being paid, in others, taxpayers are not even aware of such tax, and may have to pay it even at this point in time. This session will discuss the ins and out of the transition tax, its rules, and most current guidance on section 965.

Learning Objectives:

  • Understand the rules and tax implications of the transition tax.
  • Determine reporting obligations under section 965.


  • Rita Ryan, J.D, LLM

    Rita leads Wolf’s International Tax Services Practice, where she focuses on tax planning and compliance for international holdings. Rita has extensive experience advising clients on the tax aspects of cross-border business activities, structuring international investments, and the United States compliance obligations relating to these activities and investments for both entities and individuals. Rita also works with other tax professionals as a trusted advisor to identify necessary reporting, advise on filings, or review work papers and prepared forms to ensure accuracy in this evolving international compliance landscape.

    Prior to joining Wolf, Rita was in private practice as an Associate Attorney at the law firm of Vacovec, Mayotte & Singer, LLP where she focused in the areas of international and domestic taxation, estate planning, and tax controversy.

    Rita is an Adjunct Professor at the Graduate Tax Program at Boston University School of Law where she co-founded and co-teaches “Foreign Information Reporting and Withholding.” She also teaches various other international tax topics for Strafford Publications, Tax Practice Pros, and Wolters Kluwer.


    • International Fiscal Association (IFA)
    • Women of IFA Network (WIN)
    • Massachusetts Bar Association
    • Allinial Global, Inc.

    • Bachelor of Arts in History from Marist College
    • Juris Doctor in Law from the Western New England University School of Law
    • Master of Laws in Taxation from the Boston University School of Law
    • Massachusetts Bar Association Leadership Academy Fellow

December 15, 2023
Fri 12:00 PM EST

Duration 1H 0M

This live web event has ended.