Page 758 - Large Business IRS Training Guides
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Example 6 (cont’d)
5
Deemed paid taxes $394.40 (reported on F1118 Sch B)
Section 965(g) disallowed taxes $219.68 (reported on F1118 Sch G)
Total foreign taxes $174.72
Section 78 gross-up $174.61
( section 965(a) inclusion - section 965(c) deduction)
Deemed paid taxes x
section 965(a) inclusion
Section 78 gross up
Deemed paid taxes x (section 965(a) inclusion - section 965(c) deduction)
section 965(a) inclusion
394.40 x ((1,100-613)/1,100) = 174.61
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