Page 764 - Large Business IRS Training Guides

Section 965(i)
Election

of an S corporation that is a U.S. shareholder of a
• Each shareholder
DFIC
may elect to defer payment of its section 965(i) net tax liability with
to the S corporation indefinitely until a triggering event occurs.
respect

S corporation shareholders

Make section 965(i) election.

S corporation and electing

S Corp shareholders
remain jointly
liable for
and severally
deferred tax liability.

CFC DFIC has DFI.

shareholder of an S corporation makes a section 965(i) election, the S corporation
If any

is jointly and severally liable for the payment of the shareholder’s section 965(i) net tax

with respect to the S corporation, as well as any penalties, additions to tax, or
liability

other additional amounts attributable to such net tax liability.

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