Page 785 - Large Business IRS Training Guides

Consolidated Groups
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in Treas. Reg. §1.965-8 and in other parts of the section 965 regulations
• The rules
members of a consolidated group that are section 958(a) U.S.
provide that
shareholders
are treated as a single shareholder for certain section 965 purposes.

• Single shareholder
treatment applies to the determination of the aggregate foreign
deficit under section 965(b), basis adjustment election, payment of the
E&P
in installments under section 965(h), extension of the SOL in
section 965 liability
section 965(k),
election to forgo use of NOLs in section 965(n), and calculation of
the section 965(c) deduction (but note special
rule for determination of the AFCP).

shareholder or single person treatment does not apply
• Single section 958(a) U.S.
of determining the amount of a section 958(a) U.S. shareholder’s
for purposes
deductions or E&P deficits), the foreign
inclusion (before accounting for any
to a section 965(a) inclusion, and for any
income taxes deemed paid with respect
purpose other
than those specifically enumerated in Treas. Reg. §1.965-8(e)(1) or
another provision of
the section 965 regulations.

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