Page 782 - Large Business IRS Training Guides

Changes
in Method of Accounting &

Entity
Classification Elections

• Any change
in method of accounting made for a taxable year of an
that ends in 2017 or 2018 and filed on or after November 2,
SFC
2017, i s
disregarded for purposes of determining the amounts of the
with respect to a U.S. shareholder if the
section 965 elements
accounting would, without regard to the anti-
change in method of
abuse rule:

• Decrease a U.S.
shareholder’s section 965(a) inclusion amount,

shareholder’s aggregate foreign cash position,
• Decrease a U.S.

or

• Increase the deemed paid foreign taxes
that may be claimed with
respect
to a section 965(a) inclusion other than by reason of an
inclusion amount with respect to the
increase in a section 965(a)
SFC.

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