Page 709 - Large Business IRS Training Guides
P. 709
Timing of
Section 965(a) Inclusion: Ex. 1 & 2
Example 1:
• DFIC
has a taxable year ending 11/30, and its section 958(a)
U.S. shareholder is
a calendar year taxpayer.
• The DFIC’s
inclusion year is its taxable year ending 11/30/18,
U.S. shareholder inclusion year is the
and the section 958(a)
12/31/18.
taxable year ending
Example 2:
has a taxable year ending 12/31, and its section 958(a)
• DFIC
U.S.
shareholder has a taxable year ending 11/30.
• The DFIC’s
inclusion year is its taxable year ending 12/31/17,
U.S. shareholder inclusion year is the
and the section 958(a)
taxable year ending
11/30/18.
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