Page 703 - Large Business IRS Training Guides

DFIC & EPDFC

• Deferred foreign income corporation (“DFIC”)

an SFC that has accumulated post-1986 deferred
• A DFIC i s

foreign income greater
than zero as of either 11/2/17 or
12/31/17 (each, an “E&P measurement date”).

• If an SFC
meets the definition of a DFIC, it is classified solely
and not also as an EPDFC even if it otherwise
as a DFIC
the definition of an EPDFC (“priority rule”).
meets

• E&P
deficit foreign corporation (“EPDFC”)

is, with respect to a section 958(a) U.S.
• An EPDFC
if, as of 11/2/17, the SFC had a deficit in
shareholder, an SFC
post-1986 earnings and profits, the corporation was an SFC,

of the corporation.
and the shareholder was a U.S. shareholder

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