Page 769 - Large Business IRS Training Guides
P. 769
Section 965(n)
Election: Example
NOL example
Current year
Without section 965(n) Election
Section 965(a) inclusion less section 965(c) deduction $100
Section 78 gross-up with respect to section 965(a) inclusion 30
Taxable loss from operations (60)
Taxable income 70
With section 965(n) Election
Section 965(a) inclusion less section 965(c) deduction $100
Section 78 gross-up with respect to section 965(a) inclusion 30
Taxable loss from operations (60)
Reduction for applicable amount (130)
Net operating loss to be carried back or forward (60)
Section 965(a) inclusion less section 965(c) deduction $100
Section 78 gross-up with respect to section 965(a) inclusion 30
Taxable income $130
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