The U.S. IRS has published a draft form and schedules for the Section 965 Transition Tax. The tax is part of a transition to a participation exemption introduced by the Tax Cuts and Jobs Act (TCJA) and provides for the inclusion of the pro-rata share of the post-1986 deferred foreign earnings taxed at a rate of 15.5% on foreign earnings held in the form of cash and cash equivalents and at a rat…