Page 783 - Large Business IRS Training Guides

Changes
in Method of Accounting &

Entity Classification
Elections (cont’d)

• Except as provided with respect to certain

an election to change the
incorporation transactions,
an entity that is filed on or after
classification of
11/2/17 is disregarded for
purposes of determining

the amounts of
all section 965 elements of a U.S.
f the election would, without regard to
shareholder i
change the amount of any
the anti-abuse rule,
section 965 element of
the U.S. shareholder.

• The anti-abuse rules described above apply

whether the change in method of
regardless of
accounting or
the election to change the
classification of
an entity is made with a principal
purpose of
changing the section 965 element.

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