Page 768 - Large Business IRS Training Guides

Section 965(n)
Election: NOLs

• Under
section 965(n) and Treas. Reg. §1.965-7(e), a person may
take into account the “applicable amount”:
make an election to not

net operating loss (NOL) under section 172 for the
• In determining its

taxable year, or

that
• In determining the amount of taxable income for such taxable year
be reduced by NOL carryovers or carrybacks to such taxable year.
may

defined as the sum of:
• The “applicable amount” i s

• The person’s section 965(a) inclusions
reduced by the person’s section
965(c)
deductions for the taxable year and,

the taxes deemed paid under
• In the case of a domestic corporation,
that are
section 960(a)(1) associated with the section 965(a) inclusions
treated as dividends
under section 78.

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