Page 771 - Large Business IRS Training Guides

Alternative Method for Calculating Post-1986 E&P

a proration method cannot be used to determine post-1986
• Generally,
E&P
on an E&P measurement date.
• However,
an irrevocable elective alternate method available under Treas.
§1.965-7(f), allows an SFC to calculate its post-1986 E&P as of
Reg.
date in certain circumstances.
another

• An SFC
that does not have a 52-53-week taxable year may make the
purposes of determining its
election to use the alternative method for
on 11/2/17 but not on 12/31/17.
post-1986 E&P
• An SFC
that has a 52-53-week taxable year may make the election to use
of the post-1986 E&P
the alternative method to compute the amount
(including a deficit)
as of both E&P measurement dates.
• An SFC
that makes this election may compute the post-1986 E&P as the
the corporation’s post-1986 E&P (including a deficit) determined
sum of ( i )
of the notional measurement date, as if it were an E&P measurement
as
date,
and (ii) the corporation’s annualized E&P amounts with respect to
measurement date.
the notional

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