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Implementation of the Tax Cuts and Jobs Act Deemed Repatriation Tax Presented Significant Challenges

The Deputy Commissioner for Services and Enforcement should ensure that, if it is unable to refund excess payments to taxpayers because the entire income tax liability was not overpaid, the IRS takes steps to inform taxpayers that their excess payments will be applied to the deferred Section 965 portion of their income tax liability and inform them of the status of the liability, including when the next installment payment is due.