Oregon TCJA IRC § 965 Conformity And repatriation Tax Credit
As a result of the passage of the Tax Cuts and Jobs Act ("TCJA") enacted on December 22, 2017, treatment of deferred foreign income ("IRC §965"), was amended to require that taxpayers include the accumulated post-1986 deferred foreign corporation income in their federal taxable income for tax year 2017- a deemed repatriation.
Oregon now conforms, in part, to IRC §965 as amended under the TCJA. It should be noted, while the amendment requires the income to be added back, at the earliest, on the 2017 return, the IRS allows the tax on the repatriated income to be paid over eight years. However, Oregon does not have a comparable deferral provision. Accordingly, the Oregon tax on the repatriated income is due by the due date of the Oregon return, excluding extensions..