Page 814 - Large Business IRS Training Guides

Other
Noteworthy Rules & Guidance

Corporate
Individuals

are not
section 958(a) U.S.
• Foreign taxes in EPDFCs • Applies to individual
creditable. shareholders, even though they are
ineligible for participation exemption
• But foreign taxes associated with a system.

hovering deficit are available to the

extent of current E&P of SFC with the • Cannot claim deemed-paid FTCs under
hovering deficit. section 960 . . .

• Foreign taxes accruing between • Unless section 962 election is
11/2/17 and 12/31/17 are prorated to made.

determine post-1986 E&P as of
11/2/17. • Section 965(c) deduction is not treated
as an itemized deduction and thus is not
to 2% floor or the AMT.

• Specified E&P deficit is generally subject
first.
allocated to common stock • Election under Treas. Reg. §1.1411­

• There is a gain reduction rule for 10(g) may be made to include subpart F

distributions of section 965 PTEP inclusions, including section 965(a)

during inclusion year. inclusions, in income for NIIT purposes
at the same time the amounts are
included in income for regular tax 136
purposes.