Page 770 - Large Business IRS Training Guides
P. 770
Section 965(n)
Election: Example (cont’d)
Carryover
NOL example: Taxpayer has carryover of $100
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)
Income 70
Net operating loss deduction (70)
Taxable income 0
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 60
Taxable income 130
Net operating loss carryovers
Carryover into 2017 $ 100
Current year 60
$ 160
92
