Guidance on Repatriation of Foreign Earnings Under the American Jobs Creation Act of 2004
This memorandum briefly summarizes the IRS Notice 2005-10, including the parameters for a domestic reinvestment plan, the permitted expenditures in the US for which repatriated funds may be used, the safe harbor mechanism for taxpayers to use in establishing that the domestic reinvestment plan requirement is satisfied, as well as information reporting requirements.