US corporations that believe they have been taxed twice on repatriated foreign earnings can claim a refund in some circumstances, the US Internal Revenue Service (IRS) has announced. The IRS has said that the s.965 repatriation tax introduced by the Tax Cuts and Jobs Act 2017 may cause the same income to be taxed both as dividends and under s.965, where, for example, the foreign corporation has paid an unusual dividend for business reasons.
