Page 740 - Large Business IRS Training Guides

Basis Issue

• The section 965(b) PTEP (section 959(c)(2)) increase

accompanied by a basis increase in the DFIC
is not

(section 961)

• When the section 965(b) PTEP
is distributed it will
gain unless there is sufficient basis
trigger a capital

• To mitigate the DFIC’s
section 965(b) PTEP, the
section 965 provide an election to
regulations under

effectively
shift basis from EPDFC to DFIC

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