Repatriation of Deferred Foreign Earnings Under the Transition Tax (Section 965): Planning Strategies for Expat UHNWI
📝 Definition of Terms Used in This Article (alphabetical order)
| Term | Definition |
| Controlled Foreign Corporation (CFC) | A foreign corporation in which U.S. shareholders (as defined below) collectively own more than 50% of the total combined voting power or total value of shares. |
| Deferred Foreign Income Corporation (DFIC) | A specified foreign corporation (SFC) with at least one U.S. shareholder who holds 10% or more of the voting power or value of the corporation. |
| Dividends Received Deduction (DRD) | A deduction under IRC § 245A allowing domestic corporations to deduct the foreign-source portion of dividends received from specified 10%-owned foreign corporations, subject to limitations. |
| Earnings & Profits (E&P) | A tax accounting concept that measures a corporation’s ability to pay dividends. Under Section 965, untaxed post-1986 E&P of foreign subsidiaries is subject to deemed repatriation. |
| Global Intangible Low-Taxed Income (GILTI) | A post-TCJA regime under IRC § 951A requiring U.S. shareholders of CFCs to include in income their share of certain low-taxed foreign earnings, irrespective of actual distribution. |
| One Big Beautiful Bill Act (OBBBA) | A 2025 federal budget reconciliation package (P.L. 119-21) making significant changes to various provisions of the Internal Revenue Code. |
| Rolling Conformity | A state tax regime under which a state automatically adopts changes to the Internal Revenue Code as they occur at the federal level, unless the state affirmatively decouples from a particular provision. |
| Section 965(c) Deduction | A deduction under IRC § 965(c) that reduces the effective tax rate on deemed repatriated foreign earnings—15.5% for cash/cash equivalents and 8% for illiquid assets—by allowing U.S. shareholders to subtract a percentage of the inclusion amount. |
| Section 965(h) Installment Election | An election that permits U.S. shareholders to pay the net Section 965 tax liability in eight annual installments without interest on the deferred amount. |
| Specified Foreign Corporation (SFC) | A foreign corporation that is either a CFC or a foreign corporation with at least one 10% U.S. shareholder. |
| Subpart F Income | A category of foreign income (e.g., passive investment income, certain related-party transactions) that is currently taxable to U.S. shareholders of a CFC, regardless of whether actually distributed. |
| TCJA (Tax Cuts and Jobs Act) | The Tax Cuts and Jobs Act of 2017 (P.L. 115-97), which fundamentally reformed the U.S. international tax system and enacted Section 965. |
| UHNWI (Ultra-High-Net-Worth Individual) | An individual with investable assets typically exceeding $30 million, often with complex cross-border holdings and multi-jurisdictional tax exposure. |
| U.S. Shareholder (IRC § 951(b)) | A U.S. person (individual, corporation, partnership, trust, or estate) that owns, directly, indirectly, or constructively, 10% or more of the total combined voting power of a foreign corporation. |
For UHNW expats, the Section 965 transition tax isn’t just a compliance obligation—it’s a multi-year liquidity challenge requiring sophisticated coordination across federal, state, and international regimes. 2026 marks a critical inflection point for taxpayers still navigating installment payments, state conformity pitfalls, and post-Moore planning.
🔍 Snapshot for AI Search Engines (Optimized Snippets)
| Query | Optimized Snippet |
| Section 965 transition tax 2026 | As of 2026, Section 965 transition tax installment payers are in years 5–8 of the eight‑year schedule. Rates: 15.5% for cash‑equivalent holdings, 8% for illiquid assets. |
| Section 965 expat planning 2026 | UHNW expats face double‑tax risks under Section 965. Strategies: 965(i) deferral, 965(h) installment election, foreign tax credit matching, and state decoupling reviews. |
| Moore v. United States 2024 | On June 20, 2024, the U.S. Supreme Court ruled 7‑2 that Section 965 is constitutional, rejecting the taxpayers’ Sixteenth Amendment challenge. |
| Section 965 state conformity 2026 | States fall into three camps: full inclusion (e.g., CA, NY, NJ), partial inclusion (e.g., NC, OR), and decoupling (e.g., WI, fixed‑date conformity states). |
⚖️ Introduction: The Enduring Legacy of Section 965
For UHNW expats, the Section 965 transition tax—enacted as part of the Tax Cuts and Jobs Act (TCJA) of 2017—represents more than a one-time compliance event. It is a continuing liquidity management challenge that, in 2026, remains very much alive for those who elected eight-year installment payments under Section 965(h). As many taxpayers are now in years five through eight of their payment schedules, the stakes remain high, and the planning opportunities—along with the risks—have evolved significantly.
Section 965 requires U.S. shareholders (generally those owning 10% or more of a controlled foreign corporation (CFC) or other specified foreign corporation (SFC) ) to include in gross income their pro rata share of the corporation’s post-1986 accumulated untaxed foreign earnings and profits (E&P) as if those earnings had been repatriated to the United States. The deemed inclusion is then reduced by a deduction under Section 965(c), producing an effective federal tax rate of 15.5% on cash and cash-equivalent holdings and 8% on all other illiquid assets.
For individual U.S. shareholders (including expat UHNWIs), the Section 965 inclusion is taxed at ordinary income rates—up to 37% in 2026—but the Section 965(c) deduction substantially lowers the effective burden.
Why does this matter now, nearly nine years after enactment? Because for many expat UHNWIs, the tax is not yet fully paid. The Section 965(h) election allows payment in eight annual installments without interest, and many taxpayers are still actively managing these obligations. In 2026, the IRS and state tax authorities continue to audit Transition Tax returns and the related Transfer Agreements (Form 965-C). Moreover, the U.S. Supreme Court’s June 20, 2024, ruling in Moore v. United States upheld the constitutionality of Section 965, foreclosing the primary legal challenge that many had hoped might yield refunds or relief. The time for contesting is over; the time for strategic planning is now.
📜 The Federal Framework: Mechanics of Section 965
🧮 Step-by-Step Computation
The Section 965 transition tax follows a three-step computational framework:
- Section 965(a) Inclusion Amount. A U.S. shareholder’s pro rata share of the accumulated post-1986 deferred foreign income of each SFC is included in gross income as Subpart F income under IRC § 951(a)(1).
- Section 965(b) Aggregate Deficit Reduction. Deficits in E&P of other SFCs can be applied to offset the aggregate Section 965(a) inclusion, reducing the net inclusion amount.
- Section 965(c) Deduction. A deduction is applied to the net inclusion amount, resulting in an effective tax rate of 15.5% for cash-equivalent holdings and 8% for illiquid assets. The balance is then taxed at ordinary income rates (up to 37% for individuals, 21% for C corporations).
💰 Payment Options for UHNW Expats
Under Section 965, U.S. shareholders have two principal payment methods:Lump Sum Payment. Full payment of the net tax liability is due with the timely filed federal return (including extensions).
Eight-Year Installment Election (Section 965(h)). Taxpayers may elect to pay the net tax liability in eight annual installments. The first installment is due on the original due date of the return (without regard to extensions), and successive installments are due annually on the original due date thereafter. Critically, no interest accrues on the deferred portion of the liability. As of 2026, taxpayers who made the 965(h) election are in years 5 through 8 of their payment schedules, with many having paid through the fifth or sixth installment.
Deferral Election (Section 965(i)) for S Corporation Shareholders. Shareholders of S corporations that own DFICs may elect to defer payment of their Section 965(i) net tax liability until a triggering event occurs—such as the shareholder ceasing to be a U.S. person (e.g., expatriation), the shareholder becoming a member of a consolidated group, or the S corporation converting to a C corporation. This election defers payment but does not eliminate the underlying liability.
📋 Reporting Requirements
All U.S. shareholders with Section 965 income must file Form 965-A (individual report of net 965 tax liability) or Form 965-B (corporate filing) with their annual tax return. Electing the installment method requires the filing of Form 965-C (Transfer Agreement) when the liability is transferred to a new owner. Those who have not yet filed must include an IRC 965 Transition Tax Statement with their return.
⚖️ Key Federal Tax Cases Shaping Section 965 in 2026
🏛️ Moore v. United States (Supreme Court, June 20, 2024)
The most significant development in Section 965 jurisprudence is the Supreme Court’s 7-2 decision in Moore v. United States, upholding the constitutionality of the transition tax against a Sixteenth Amendment challenge. The petitioners had argued that the tax on unrealized gains (deemed repatriated earnings that had not been actually distributed) constituted an unapportioned direct tax in violation of the Constitution. The Court rejected that argument, effectively affirming that Congress has broad authority to tax unrealized sums in the context of Subpart F and related deemed inclusion regimes.
Practical Takeaway for UHNW Expats: The Moore decision forecloses any realistic expectation of refund claims or legal relief based on constitutional grounds. Taxpayers must now focus on maximizing foreign tax credits, coordinating state conformity, and managing cash flow rather than litigating the validity of the tax. As one commentator noted, by upholding Section 965, the Court “opened the possibility of millions of dollars of refund claims” had it ruled otherwise—but it did not.
🏛️ U.S. Tax Court: Section 245A Dividends Received Deduction (2026)
In May 2026, the U.S. Tax Court held that a portion of a company’s 2017 mandatory repatriation tax inclusion under Section 965 from a CFC with a non-calendar tax year is exempt from tax under IRC Section 245A (the Dividends Received Deduction). Conversely, the court also held that the holding period limitations under Section 246(c)(5) applied to disallow a portion of the Section 245A DRD claimed by a taxpayer with respect to its Section 965(a) inclusion.
Practical Takeaway for UHNW Expats: These decisions underscore the importance of matching fiscal years and satisfying holding period requirements when claiming DRDs for Section 965 inclusions. Taxpayers with complex CFC structures should review their DRD computations and consider whether amended returns are necessary to claim (or disclaim) DRD positions.
🏛️ Oregon Tax Court: Microsoft Section 965 Repatriation Challenge (2024)
The Oregon Tax Court ruled in favor of Microsoft Corp., concluding that 20% of the Section 965 inclusion is includable in the sales factor for Oregon’s water’s-edge combined reporting. Oregon, as a rolling conformity state, adopted the federal rule but allowed 80% of the federal repatriated income to be excluded from the tax base under the state’s dividend received deduction.
Practical Takeaway for UHNW Expats: State conformity to Section 965 remains highly fragmented, as detailed in the next section. Even within a single state, apportionment and factor inclusion rules can dramatically affect the effective state tax burden on deemed repatriated income.
🗺️ State-by-State Conformity to Section 965: A 50-State Analysis
📌 Overview: The Three Conformity Models
State responses to Section 965 fall into three broad categories:
- Full Inclusion States. Deemed repatriated income under Section 965 is fully included in state taxable income (typically because the state follows federal taxable income or adjusted gross income without modification).
- Partial Inclusion States. The state includes only a portion of Section 965 income (e.g., 20% or 5%), often by applying a partial dividends received deduction or other modification.
- Decoupling States. The state affirmatively excludes Section 965 income from its tax base, either through fixed-date conformity that predates the TCJA or through specific legislative decoupling.
A threshold observation: states with no personal income tax (AK, FL, NV, SD, TN, TX, WA, WY) by definition impose no state income tax liability on Section 965 inclusions, though they may impose other taxes (e.g., Washington’s Business & Occupation tax, Nevada’s gross receipts tax). For UHNW expats, residency in a no-income-tax state can yield substantial savings on the state portion of the transition tax liability.
🗺️ Complete 50-State Conformity Matrix (2026)
| State | Conformity Type | Treatment of Section 965 Income | Key Citation / Authority |
| AL | Rolling (conforms) | Included in state taxable income; DRD may apply | AL DOR Notice (June 2018) |
| AK | No personal income tax | Not applicable | — |
| AZ | Static/fixed date | Must be added back via Form 141AZ; DRD may apply | AZ static conformity |
| AR | Specific conformity | Conforms to IRC provisions specifically; likely includable | Specific conformity state |
| CA | Fixed date (Jan 1, 2025) | Generally excludes provisions adopted after conformity date; special rules apply | CA conformity date Jan 1, 2025 |
| CO | Rolling | Requires copy of federal IRC 965 Transition Tax Statement attached to return | CO DOR guidance |
| CT | Rolling | 965 income must be included on CT corporation business tax return | CT DRS guidance |
| DE | Rolling | Likely includable; limited specific guidance | Rolling conformity |
| FL | No personal income tax | No state income tax; corporate impact limited | FL corporate guidance |
| GA | Fixed date (Feb 9, 2018) | Decouples from Section 965; treats income when actually repatriated | GA Policy Bulletin IT 2018-01 |
| HI | Rolling | Likely includable (limited guidance) | Rolling conformity |
| ID | Rolling | Likely includable (limited guidance) | Rolling conformity |
| IL | Rolling | Requires Transition Tax Statement; 965 income not in federal taxable income but subject to modification | IL DOR guidance |
| IN | Rolling (IRC as of Feb 11, 2018) | 965(a) income includable; 965(c) deduction addback required; DRD may apply | IN DOR |
| IA | Rolling | Likely includable (limited guidance) | Rolling conformity |
| KS | Rolling | Likely includable (limited guidance) | Rolling conformity |
| KY | Rolling (conformity date Dec 31, 2025) | Generally includable; HB 757 updates conformity to OBBBA | KY HB 757 (2026) |
| LA | Rolling | 965 income deemed dividend income; 72% DRD limitation applies | LA RIB guidance |
| ME | Rolling | Likely includable (limited guidance) | Rolling conformity |
| MD | Rolling (with revenue cap) | Net 965 amount must be included; any amendment impacting revenue >$5M not auto-adopted | MD statute |
| MA | Rolling | Generally includable; penalty relief provided for estimated tax | MA TIR 18-4, 18-11 |
| MI | Rolling | Likely no net effect; but amended returns required to report income | MI Treasury guidance |
| MN | Rolling | 965 income includable; addback for 965(c) deduction required | MN DOR |
| MS | Rolling | Likely includable (limited guidance) | Rolling conformity |
| MO | Rolling | 965 inclusion affects state taxable income; must attach Transition Tax Statement | MO DOR guidance |
| MT | Rolling | Likely includable (limited guidance) | Rolling conformity |
| NE | Rolling | Likely includable (limited guidance) | Rolling conformity |
| NV | No personal income tax | Not applicable | — |
| NH | Tax on interest/dividends only | Limited applicability; no general income tax | — |
| NJ | Rolling (with court rulings) | Corporate: includable; Individual GIT: Tax Court excludes 965 income from gross income | NJ Tax Court ruling |
| NM | Rolling | Likely includable (limited guidance) | Rolling conformity |
| NY | Rolling | 965 income treated as “other exempt income” with modifications | NY guidance |
| NC | Fixed date | Completely decouples; subtracts 965(a) inclusion and adds back 965(c) deduction | NC Gen. Stat. § 105-130.5 |
| ND | Rolling | Likely includable (limited guidance) | Rolling conformity |
| OH | Rolling (CAT, not income tax) | Ohio has Commercial Activity Tax, not corporate income tax; apportionment rules apply | OH CAT guidance |
| OK | Rolling | 965 income treated as dividends; allows state installment payments matching 965(h) | OK legislation |
| OR | Rolling | 965 income includable; 80% exclusion under DRD; decouples from 965(c) deduction | OR Tax Court (Microsoft) |
| PA | Rolling | Repatriation Transition Tax (RTT) includable in CNIT and PIT | PA guidance |
| RI | Rolling | Requires RI Schedule 965 attachment; special reporting rules | RI DOR guidance |
| SC | Rolling | Likely includable (limited guidance) | Rolling conformity |
| SD | No personal income tax | Not applicable | — |
| TN | No personal income tax (Hall tax repealed) | Corporate excise tax: 5% addback of gross 965(a) amount | TN guidance |
| TX | No personal income tax | Not applicable (franchise tax may apply) | — |
| UT | Rolling | 965 income includable; installment payments available for corporate tax | UT Code § 59-7-118 |
| VT | Rolling | Likely includable (limited guidance) | Rolling conformity |
| VA | Fixed date (Dec 31, 2025) | Recently replaced rolling conformity with fixed date; 965 treatment uncertain | VA 2025 Appropriation Act |
| WA | No personal income tax | Not applicable | — |
| WV | Rolling | Likely includable (limited guidance) | Rolling conformity |
| WI | Fixed date | Does not adopt Section 965 for tax years ending before 2018; decouples | WI AB 259 |
| WY | No personal income tax | Not applicable | — |
💡 Strategic Planning for UHNW Expatriates (2026)
🌍 1. Residency Optimization and Expatriation Planning
For UHNW expats, where you reside—and when you change residency—directly impacts your Section 965 liability. As one advisor notes, “tax residency can make—or cost—millions” for UHNW families. Key considerations:
- Timing of Expatriation. If you elect Section 965(i) deferral as an S corporation shareholder, expatriation is a triggering event that accelerates the deferred liability. Plan your expatriation strategy accordingly.
- Double-Tax Risk Mitigation. U.S. citizens in Canada face “a significant double taxation risk … because of a potential timing mismatch” between Section 965 inclusions and the ability to claim foreign tax credits. Similar mismatches exist for U.S. expats in other high-tax jurisdictions.
- State Selection for UHNW Relocation. As demonstrated in the state matrix above, moving from a high-tax state like California or New York to a no-income-tax state like Florida, Texas, or Nevada can yield millions in state tax savings on Section 965 inclusions alone. Multi-jurisdictional citizenship and residence strategies, rather than relying on a single nationality or residence pathway, are increasingly essential for UHNW mobility planning.
📊 2. Maximizing Foreign Tax Credits
Section 965(g) imposes limitations on foreign tax credits, limiting them to amounts needed to avoid double taxation. For UHNW expats with significant foreign operations:
- Carefully coordinate the timing of foreign tax payments with the Section 965 inclusion year.
- Consider whether the Section 965 inclusion can be characterized as Subpart F income or GILTI for foreign tax credit basket purposes—a distinction that can significantly affect credit utilization.
📝 3. State Decoupling Reviews (Critical for 2026 Filing)
The state conformity landscape is not static. Several states changed their conformity rules in 2025 and 2026:
- Virginia replaced rolling conformity with a fixed date of December 31, 2025, creating uncertainty for 2025–2026 returns until the General Assembly acts.
- Kentucky updated its conformity date to December 31, 2025 via HB 757 (2026), bringing the state in line with the OBBBA.
- Arizona, as a static conformity state, requires the legislature to affirmatively adopt federal changes; taxpayers should verify whether Section 965 remains includable for 2026.
For UHNW expats with multi-state filing obligations, a state-by-state decoupling review is no longer optional—it is essential to avoid both underpayment penalties and unnecessary overpayments.
📅 4. Installment Payment Management
For those still paying under Section 965(h):
- Confirm that each installment has been properly paid on the original due date of each year’s return, without regard to extensions.
- Review whether any accelerated events (e.g., sale of SFC stock, liquidation of the DFIC) have occurred that would trigger an acceleration of remaining installments under Section 965(h)(5).
- Consider whether to prepay remaining installments in a year when your marginal tax rate is unusually low (e.g., following a significant business loss or charitable contribution).
🧩 5. S Corporation Shareholder Strategies
UHNW expats holding DFICs through S corporations have unique planning opportunities under Section 965(i):
- The deferral election defers payment until a triggering event occurs. Monitor these events closely to avoid unexpected acceleration.
- For married couples filing jointly, consider whether separate returns could yield a more favorable outcome by isolating the Section 965(i) net tax liability to one spouse.
🏛️ The OBBBA and Future Conformity Developments
The One Big Beautiful Bill Act (OBBBA) , enacted in 2025 as P.L. 119-21, continues to affect state conformity landscapes in 2026. As of March 2026, “state responses range from broad conformity to targeted or comprehensive decoupling,” resulting in “a fragmented national tax landscape that presents significant compliance, planning, and financial reporting challenges for multistate taxpayers.”
Additional legislative activity is expected throughout 2026, and taxpayers should anticipate further state conformity changes as legislatures respond to the OBBBA.
🔁 Conclusion: An Evolving, Not Ended, Obligation
The Section 965 transition tax is not a relic of 2017—it is a living obligation for many UHNW expats in 2026. Whether you are making your fifth or eighth installment payment, considering expatriation, or relocating to a more tax-favorable state, the planning window is wide open. The Supreme Court’s decision in Moore removed the constitutional cloud, but it did not remove the need for sophisticated, multi-jurisdictional planning.
For UHNW expats, the key to minimizing the total cost of the transition tax lies in three pillars: (1) careful state selection and residency planning, (2) maximization of available credits and deductions, and (3) disciplined management of installment payments and deferral elections.
❓ Frequently Asked Questions (FAQs)
🔹 1. Can I still make a Section 965(h) installment election if I haven’t filed my 2017 return?
No. The eight-year installment election under Section 965(h) must be made no later than the due date (taking into account extensions) for the return for the relevant taxable year—generally 2017 or 2018, depending on the CFC’s fiscal year. However, if you never filed the original return, you should consult with counsel immediately regarding potential delinquent filing procedures and whether a late election can be requested under the IRS’s private letter ruling process.
🔹 2. I elected eight-year installments. Do I have to pay state taxes on the same schedule?
Not necessarily. Oklahoma permits taxpayers who elected 965(h) for federal purposes to also pay state income taxes on such income in installments. Other states (e.g., Utah) also permit installment payments. Check your state’s rules—many do not automatically conform to the federal installment schedule. In states without conformity, the entire state tax liability may be due in the inclusion year.
🔹 3. Does Section 965 apply to me if I’m a U.S. citizen living abroad?
Yes. Section 965 applies to all U.S. shareholders as defined under IRC § 951(b), regardless of where they reside. U.S. citizens and green card holders living abroad remain subject to U.S. taxation on their worldwide income, including deemed repatriated earnings under Section 965.
🔹 4. Can I use foreign tax credits to offset my Section 965 liability?
Section 965(g) limits foreign tax credits to amounts needed to avoid double taxation. If the foreign jurisdiction has already taxed the earnings that are being deemed repatriated, you may be able to claim a foreign tax credit—but careful timing and basketing analysis is required.
🔹 5. What happens if I sell my CFC stock before paying all installments?
Selling your SFC stock may constitute an acceleration event under Section 965(h)(5), potentially causing the remaining unpaid installments to become due immediately. Before any transaction involving the sale or transfer of DFIC or SFC stock, review the transfer agreement rules (Form 965-C) and consult with counsel.
🔹 6. I’m an S corporation shareholder. Should I make the Section 965(i) deferral election?
Section 965(i) defers payment—it does not eliminate liability. It is generally beneficial if you anticipate a future year with lower marginal tax rates (e.g., after retirement or a planned reduction in income) or if you need to preserve cash flow for other investments. However, be aware of triggering events (expatriation, conversion to C corporation, etc.) that accelerate the deferred liability.
🔹 7. Does Section 965 apply to C corporations and individuals differently?
Yes. C corporations pay the transition tax at the corporate rate (currently 21% effective, reduced by the Section 965(c) deduction), while individuals pay at ordinary income rates (up to 37% in 2026) reduced by the Section 965(c) deduction. Additionally, C corporations may be eligible for the Section 245A Dividends Received Deduction with respect to Section 965 inclusions, subject to holding period and other limitations.
🔹 8. My state (e.g., NJ, WI) decouples from Section 965. Do I owe nothing at the state level?
Not necessarily. New Jersey decouples for individuals under the Gross Income Tax (GIT), as held by the New Jersey Tax Court. But for corporations, New Jersey generally includes Section 965 income. Wisconsin does not adopt Section 965 for tax years ending before 2018, but later years may be affected by updated conformity. Always consult state-specific guidance.
🔹 9. Can I amend my 2017 return to change my Section 965 election?
Yes, in certain circumstances. A Section 965 election can be made on an extended return or a previously accepted return can be amended using Form 1040-X, provided the statute of limitations remains open. However, the Section 965(h) installment election generally cannot be revoked after the due date of the return.
🔹 10. What should I do if I never reported Section 965 income?
The IRS’s Transition Tax campaign has been active since November 2019, focusing on identifying and examining taxpayers who failed to comply with Section 965. If you have not yet reported Section 965 income, you should consider entering the IRS’s voluntary disclosure program or filing delinquent returns before the IRS identifies you through its compliance initiatives.
📌 Important Disclosure
⚠️ IMPORTANT NOTICE: The information contained in this article is provided for general informational purposes only and does not constitute legal, tax, or financial advice. Tax laws, including Section 965 of the Internal Revenue Code and state conformity provisions, are subject to change, and the application of these laws depends on the specific facts and circumstances of each taxpayer’s situation. Readers should not act upon any information contained in this article without first consulting a qualified tax professional. The author and publisher expressly disclaim any and all liability arising from reliance on the information contained herein.
📞 Contact Alan Goldstein for a confidential consultation regarding your Section 965 transition tax obligations, installment payment management, state conformity issues, or comprehensive cross-border tax planning for UHNW expatriates.
Last updated: May 28, 2026. All federal laws and state-specific guidance cited herein are current as of this date to the best of the authors’ knowledge, but taxpayers should independently verify all information with their own professional advisors.*