Page 726 - Large Business IRS Training Guides

Aggregate Foreign Cash Position 2

the greater of:
The AFCP i s

a section 958(a) U.S. shareholder’s pro rata share
• the aggregate of
of
the cash position of each SFC determined on the SFC’s final cash
date, or
measurement

cash measurement date is the close of the last taxable
• An SFC’s final
year
of the SFC that begins before 1/1/18, and ends on or after 11/2/17, if

any.

• the average of
the aggregate of a section 958(a) U.S. shareholder’s
the cash position of each SFC determined as of
pro rata share of
first and second cash measurement dates.
each SFC’s

date of an SFC is the close of the last
• The second cash measurement
of the SFC that ends after 11/1/16, and before 11/2/17, if
taxable year
any.

• The first
cash measurement date of an SFC is the close of the last
taxable year
of the SFC that ends after 11/1/15, and before 11/2/16, if
any.

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