Page 727 - Large Business IRS Training Guides

Aggregate Foreign Cash Position:
Example

Cash Position

USP Measurement Dates First Second Final
12/31/2015 12/31/2016 12/31/2017
CFC1 200 100 ­
100% 100% CFC2 - 50 300
200 (3) 150 (2) 300 (1)

CFC1 CFC2 AFCP 12/31/2017 (1) 300

Average ((2)+(3))/2 175
AFCP 300
AFCP - 2017 300
12/31/15: $200 12/31/15: $0
12/31/16: $100 12/31/16: $50
12/31/17: $0 12/31/17: $300

aggregate of the pro rata share of CFC1’s and CFC2’s cash positions on the final
• USP’s
cash measurement date (12/31/17) is $300.

average of the aggregate of the pro rata share of CFC1’s and CFC2’s cash
• USP’s
on the first and second cash measurement dates (12/31/15 & 12/31/16) is
positions
$175.

• Thus, USP’s aggregate foreign cash position (the greater of the two amounts) is $300.

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