Page 649 - Large Business IRS Training Guides
P. 649
Anti-Abuse Rules
4
Sec. 965 Asset sale
meas. date
1/1/18 11/30/18 12/31/18 11/30/19 12/31/19
USP
CFC1 DISQUALIFIED PERIOD CFC1’s first inclusion year
CFC2 CFC2’s first inclusion year
245A
DRD
• Not subject to transition tax under §965: Gain realized by CFC1 is
excluded from earnings subject to §965 transition tax because gain
arises after the §965 E&P measurement dates (November 2 nd and
December 31 , as applicable).
st
65
