Page 761 - Large Business IRS Training Guides
P. 761
Section 965 Elections
Six
elections are available to taxpayers with respect to section 965:
– Election to Pay Net Tax Liability Under Section 965 in
• Section 965(h)
Installments
– S Corporation Shareholder Election to Defer Payment
• Section 965(i)
Liability Under Section 965
of Net Tax
– Election for REITs to Defer Section 965 Inclusions
• Section 965(m)
– Election Not to Apply NOL Deduction
• Section 965(n)
• Election to Use Alternative Method to Compute Post-1986 E&P
• Election to Use Basis Adjustments Under Treas. Reg. §1.965-2(f)
83
