Page 695 - Large Business IRS Training Guides
P. 695
Why Section 965 Exists:
Pre-TCJA Law
• Foreign income earned by FC
generally is not
subject to U.S.
tax unless and until distributed
for subpart F and
• Exceptions
section 956 inclusions
• When FC
distributes its foreign
income to USP, the income is
generally subject to U.S.
tax
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