Page 756 - Large Business IRS Training Guides

Example 6 (cont’d)
3

Foreign Taxes Deemed Paid by Domestic Corporation

(a) (b) (c) (d) (e)
Post-1986
Section 965(a) Undistributed Post-1986
Inclusion in Earnings in Divide Column Foreign Income Taxes Deemed
Functional Functional (a) by Column (b) Taxes Paid

Currency
Currency
DFIC1 92 100 92.0% 30 27.60

DFIC2 917 1,000 91.7% 400 366.80
DFIC3 92 100 92.0% - -
1,100 1,200 394.40

• Deemed paid tax calculated for each DFIC

• USSH
must own 10% or more of the voting

stock of DFIC

78