Page 706 - Large Business IRS Training Guides

Answers t
o DFIC & EPDFC Examples

• SFC1 is a DFIC because it
has positive accumulated
on one of the
post-1986 deferred foreign income (DFI)

11/2/17.
E&P measurement dates,

• SFC2 is a EFDFC
because it has a deficit in post-1986

E&P as of
11/2/17 and does not have positive DFI on
12/31/17.

a DFIC because it has DFI on one of the E&P
• SFC3 is

measurement
dates, 11/2/17. The priority rule
classifies
this entity as a DFIC even if it had otherwise

definition. In this example, the entity
met the EPDFC
does
not have a deficit on 11/2/17, so it would not

meet the definition of EPDFC.

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