The Broad Implications of Section 965 Repatriation

A report prepared in collaboration with Deloitte Tax LLP


In July 2005, a group of leading finance executives, tax practitioners, and editorial staff from CFO Research Services gathered in New York to discuss the repatriation provisions contained in the new section 965 of the Internal Revenue Code. The roundtable group?including senior finance executives from the manufacturing, pharmaceutical, durable goods, high tech, and telecommunications industries?discussed the ways section 965 has affected their businesses, both immediately and in the long term. The group addressed several important questions: Do companies see section 965 simply as a tactic for bringing home profits at low tax cost? Is section 965 an opportunity to recast a company?s footprint overseas? Has the opportunity presented by section 965 altered company strategies, or have companies used section 965 to advance current strategies?


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