Page 671 - Large Business IRS Training Guides
P. 671
Key
Takeaways
subpart F & other issues that
• Should we stop auditing
involve the E&P
of a CFC in open years prior to the new
effective date?
law’s
• No!
Why? To protect the government’s interest because
rates (pre-repatriation year tax rates
of the decline in tax
& to make sure that the beginning E&P for
are higher)
the repatriation
year is correct.
F income is picked up before the §965
• §951 subpart
repatriation
amount and taxed at a higher rate.
• Old law taxation of CFC income:
now or deferral
taxation of CFC income:
• New law now or never (if
domestic
corporate shareholder)
87
