Page 766 - Large Business IRS Training Guides

Triggering Events (cont’d)

under section 965(i) may be possible
Continued deferral

if the triggering event is a covered triggering event, and a

agreement is properly entered into.
transfer
a covered triggering event if described in #4
• An event i s
and the transferee is an eligible section 965(i)
above,
transferee (a single U.S.
person that becomes a shareholder
of
the S corporation but not the domestic pass-through entity
itself).

a transfer that consists of multiple partial transfers,
• In case of
agreement may be entered into by the shareholder
a transfer
to which the triggering event occurs and an
with respect
eligible section 965(i)
transferee for each partial transfer.

• If a triggering event occurs and continued deferral under
not possible, the shareholder may elect to
section 965(i) is
section 965(i) net tax liability over 8 years.
pay its

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