Last week the IRS issued proposed regulations under the Section 965 Transition Tax. We have created charts of the 8 examples included in Prop. Treas. Reg. §1.965-1(g). The examples include:
Example 1: Special Non-Attribution Rule For P'ships in Defining Specified Foreign Corporations
Example 2: Attribution Rule For P'ships in Defining Specified Foreign Corporations
Example 3: Determination of Accumulated Post-1986 Deferred Foreign Income (All E&P was PTI & DFI was zero)
Example 4: Determination of Status as a DFIC or an E&P Deficit Foreign Corp (Solely a DFIC)
Example 5: Determination of Status as a DFIC or an E&P Deficit Foreign Corp (Neither a DFIC Nor a Def. Corp)
Example 6: Application of Currency Translation Rules
Example 7: Determination of Cash Measurement Dates and Pro Rata Shares of Cash Positions
Example 8: Determination of Section 958(a) U.S. Shareholder in case of a Controlled Domestic Partnership
Example 6 is helpful in that it shows how to allocate deficits when a U.S. shareholder has some CFCs with deficits and others with positive earnings.
All 1,000+ charts on andrewmitchel.com can be viewed in topical order here or alpha-numeric order here. In addition, a single PDF with all 1,138 charts in alpha-numeric order can be found here.
