Timing of Section 965(a) Inclusion: Ex. 3 Year End: USP 12/31 Year End: Year End: 11/30 FC1 FC2 12/31 DFI: 400 DFI: 100 FC1’s DFI of $400 in its income in 2018. 1. USP includes 2. USP includes FC2’s DFI of $100 in its income in 2017. 32