965 Inclusion of Deferred Foreign Income Upon Transition to

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Form

965

(January 2019)
Department of the Treasury
Internal Revenue Service

For calendar year 20

Inclusion of Deferred Foreign Income
Upon Transition to Participation Exemption System

OMB No. 1545-0123

Attach to tax return.
Go to www.irs.gov/Form965 for instructions and the latest information.
▶

▶

, or other tax year beginning

, 20

, and ending

, 20

, of the filer.

Identifying number

Name of person filing this return

DRAFT AS OF
September 24, 2018
DO NOT FILE
Note. Throughout this form, the term “2018 tax year” refers to 2018 calendar tax years and fiscal tax years of the person filing this
return that begin in 2018. The term “2017 tax year” refers to 2017 calendar tax years and fiscal tax years of the person filing this return
that begin in 2017.

Part I
1

2

3

4

5
6

Section 965(a) Inclusion

2018 tax year section 965(a) inclusion amounts from Schedule A.
Enter the sum of column (k) of Schedule A . . . . . . . . . . . . . .
2018 tax year section 965(a) inclusions from pass-throughs. Attach schedule .

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Total 2018 tax year section 965(a) inclusion. Add lines 1 and 2.
Enter the sum here and on your tax return as follows. Corporations: Enter the line 3 total on
Form 1120, Schedule C, line 15, column (a), or the corresponding line of other corporate tax
returns. All others: See instructions . . . . . . . . . . . . . . . . . . ▶
2017 tax year section 965(a) inclusion amounts from Schedule A.
Enter the sum of column (j) of Schedule A . . . . . . . . . . . . . . . . .
2017 tax year section 965(a) inclusions from pass-throughs. Attach schedule . . . .
Total 2017 tax year section 965(a) inclusion. Add lines 4 and 5 . . . . . . . . ▶

Part II

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6

Section 965(c) Deduction

SECTION 1—Section 965(c) Deduction by Tax Year
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15
16
17

2018 Tax Year
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8
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10

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11
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13

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14

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15

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16

Total 2018 tax year section 965(c) deduction. Add lines 15 and 16.
Enter the sum here and on your tax return as follows. Corporations: Enter the line 17 total on
Form 1120, Schedule C, line 15, column (c), or the corresponding line of other corporate tax
returns. All others: See instructions . . . . . . . . . . . . . . . . . . .

17

Enter the amount from Part I, line 1. If -0-, skip to line 16 . . . . . . .
Aggregate Foreign Cash Position.
Enter the sum from Schedule D, line 21 . . . . . . . . . . . . .
Enter the smaller of line 7 or 8 . . . . . . . . . . . . . . . .
Enter the 2018 15.5% Rate Equivalent Percentage from Part II, Section 2.
Enter amount from Section 2, line 1a . . . . . . . . . . . . . .
Section 965(c) Deduction Related to 15.5% Rate Equivalent Percentage.
Multiply line 9 by line 10 . . . . . . . . . . . . . . . . . .
Subtract line 9 from line 7 . . . . . . . . . . . . . . . . .
Enter the 2018 8% Rate Equivalent Percentage from Part II, Section 2.
Enter amount from Section 2, line 1b . . . . . . . . . . . . . .
Section 965(c) Deduction Related to 8% Rate Equivalent Percentage.
Multiply line 12 by line 13
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2018 tax year section 965(c) deduction not from pass-throughs.
Add lines 11 and 14 . . . . . . . . . . . . . . . . . . .
2018 tax year section 965(c) deduction from pass-throughs.
Attach schedule
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For Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.

Cat. No. 71279D

Form 965 (1-2019)

Page 2

Form 965 (1-2019)

SECTION 1—Section 965(c) Deduction by Tax Year (continued)
18
19

Enter the amount from Part I, line 4. If -0-, skip to line 27
Aggregate Foreign Cash Position.
Enter the sum from Schedule D, line 19 . . . . . .
Enter the smaller of line 18 or 19 . . . . . . . .

20

2017 Tax Year

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18

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19
20

DRAFT AS OF
September 24, 2018
DO NOT FILE
21

Enter the 2017 15.5% Rate Equivalent Percentage from Part II, Section 2.
For calendar year persons, enter amount from Section 2, line 1a. For fiscal year persons, enter
amount from Section 2, line 2c . . . . . . . . . . . . . . . . . . . . .
Section 965(c) Deduction Related to 15.5% Rate Equivalent Percentage.
Multiply line 20 by line 21
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Subtract line 20 from line 18
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22

23

24

Enter the 2017 8% Rate Equivalent Percentage from Part II, Section 2.
For calendar year persons, enter amount from Section 2, line 1b. For fiscal year persons, enter
amount from Section 2, line 2e . . . . . . . . . . . . . . . . . . . .
Section 965(c) Deduction Related to 8% Rate Equivalent Percentage.
Multiply line 23 by line 24
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2017 tax year section 965(c) deductions not from pass-throughs.
Add lines 22 and 25 . . . . . . . . . . . . . . . . . . . . . . .
2017 tax year section 965(c) deductions from pass-throughs.
Attach schedule
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Total 2017 tax year section 965(c) deductions.
Add lines 26 and 27 . . . . . . . . . . . . . . . . . . . . . . .

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SECTION 2—Rate Equivalent Percentages
2017
Calendar Year

2018
Tax Year

a 15.5 Percent Rate Equivalent Percentage

0.557142857

0.261904762

b 8 Percent Rate Equivalent Percentage

0.771428571

0.619047619

1

Calendar Year Persons

2

2017 Fiscal Year Persons
a

Enter the section 15 blended rate calculated in accordance with section 965(c)(2) (see instructions)
15.5 Percent Rate Equivalent Percentage
b Subtract 15.5% from line 2a
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c Divide line 2b by line 2a . . . . . . . . . . . . . . . . . . . . . . .
8 Percent Rate Equivalent Percentage
d Subtract 8% from line 2a . . . . . . . . . . . . . . . . . . . . . . .
e Divide line 2d by line 2a . . . . . . . . . . . . . . . . . . . . . . .

Part III
A
B
C
D
E

2a
2b
2c
2d
2e

Elections

Was an election made to pay the net tax liability over 8 years as provided for in section 965(h)?
Complete if a shareholder in an S corporation.
Was an election made to defer payment of net tax liability as provided for in section 965(i)? . .
Complete if a Real Estate Investment Trust.
Was an election made to include income over 8 years as provided for in section 965(m)? . .
Was an election made not to apply a net operating loss deduction as provided in section 965(n)?
Was the election provided for in Regulations section 1.965-2(f)(2) made? . . . . . . . .

Yes No
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Form 965 (1-2019)