Page 736 - Large Business IRS Training Guides
P. 736
Overview of
Sections 959 and 961
Pre-TCJA
• CFC
E&P subject to tax under an anti-deferral
subpart F) could be also subject to
regime (e.g.,
such E&P if not for
tax on the distribution of
section 959
and
• Section 959 (addressing adjustments to E&P)
its corollary, section 961 (addressing adjustments
prevent this type of double taxation
to basis)
Post
-TCJA
• Section 965(a)
inclusion also creates PTI
• Rules to address new PTEP under
development
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