Page 763 - Large Business IRS Training Guides

Acceleration Events

• Any of the following constitutes an acceleration event:
1) Failure to timely pay an installment;

2) Liquidation, sale, exchange, or other disposition of substantially all of the assets of

the person making the installment election (including bankruptcy or death);
3) Cessation of business by
the person;

4) Any event that results in the person no longer being a U.S. person (e.g.,
expatriation);
5) The person becoming a member of a consolidated group;

6) The cessation of the existence of a consolidated group;

7) A determination by the IRS that there was a material misstatement or omission in a

transfer agreement.
be possible if the acceleration
• Continued deferral under section 965(h) may
event is a covered
acceleration event, and a transfer agreement is properly
entered into.

• An acceleration event is a covered acceleration event if it is described in #2, #5, or
#6 above, and the transferee is an eligible section 965(h) transferee (a single U.S.

person that is not a domestic pass-through entity).

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