Page 717 - Large Business IRS Training Guides

Section 965(b)
– Allocation of Deficits (cont’d)

• The aggregate foreign E&P deficit is allocated among the

shareholder’s DFICs in an amount that
section 958(a) U.S.
bears the same proportion to such aggregate as—

• Such U.S. shareholder’s
pro rata share of the section
965(a) earnings
amount of each such DFIC, bears to

pro rata share
• The aggregate of such U.S. shareholder’s
earnings amount of all DFICs of such
of the section 965(a)

U.S. shareholder.

• Section 965(a) earnings
amounts are translated (if

dollars using the spot rate on 12/31/17.
necessary) into U.S.

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