965-A Instr

Instructions for Form 965-A

Department of the Treasury
Internal Revenue Service

(Rev. January 2021)

Individual Report of Net 965 Tax Liability
Section references are to the Internal Revenue Code unless
otherwise noted.

Future Developments

For the latest information about developments related to Form
965-A and its instructions, such as legislation enacted after they
were published, go to IRS.gov/Form965A.

What’s New

In Parts I, II, and III of the form, line 4 is now designated for use
for 2020 reporting.
Changes to the carryback of net operating losses. The
Coronavirus Aid, Relief, and Economic Security Act (CARES
Act) added section 172(b)(1)(D)(i), which provides for a
carryback of any net operating loss (NOL) arising in a taxable
year beginning after December 31, 2017, and before January 1,
2021, to each of the five taxable years preceding the taxable
year in which the loss arises, including those years in which a
taxpayer had a section 965(a) inclusion (section 965 years). A
taxpayer applying for a tentative refund resulting from the
carryback of an NOL to a section 965 year must include with the
Form 1045 an amended Form 965-A to record the amount of the
change in the section 965 net tax liability, if any, caused by the
NOL carryback, and a statement of explanation to explain the
change in the section 965 net tax liability. See Rev. Proc.
2020-24, 2020-18 I.R.B. 750, and Frequently asked questions
about carrybacks of NOLs for taxpayers who have had Section
965 inclusions for additional information regarding the
consequences of carrying back an NOL to a section 965 year,
including limitations on refunds for taxpayers that carry back
NOLs to section 965 years.

Reminders

The IRS has developed the following forms:
• Form 965-C, Transfer Agreement Under Section 965(h)(3).
• Form 965-D, Transfer Agreement Under Section 965(i)(2).
• Form 965-E, Consent Agreement Under Section 965(i)(4)(D).
The instructions for these forms contain information that may
be useful to filers of Form 965-A. As such, references to these
instructions have been added throughout the instructions for
Form 965-A.

Background

On December 22, 2017, section 965 of the Code was amended.
As a result of the amendment, certain taxpayers are required to
include in income an amount (a section 965(a) inclusion amount)
based on the accumulated post-1986 deferred foreign income of
certain foreign corporations (specified foreign corporations) that
are deferred foreign income corporations (DFICs) that they own
either directly or indirectly through other entities. Other taxpayers
may have inclusions in income under section 951(a) by reason
of section 965 due to ownership of DFICs through domestic
pass-through entities that are U.S. shareholders of the DFICs.
When referring to both amounts in the preceding two sentences,
these instructions use the term “section 965(a) inclusion.”
Section 965 also allows for a deduction (section 965(c)
deduction). Section 965(a) inclusions and corresponding section
965(c) deductions are taken into account based on the last tax
year of the DFIC that begins before January 1, 2018.

Dec 15, 2020

Certain taxpayers may make certain elections with respect to
section 965. Relevant to this form, these elections include: (i) an
election to pay a net 965 tax liability over 8 years, and (ii) an
election by S corporation shareholders to defer payment of a net
965 tax liability with respect to an S corporation until a triggering
event. In the case of the deferral election by S corporation
shareholders, the deferred amounts are subject to annual
reporting requirements, and when a triggering event occurs, the
S corporation shareholder may then (subject to certain
limitations) elect to pay the amount of the net 965 tax liability that
is no longer subject to deferral over 8 years.

General Instructions
Purpose of Form

This form should be used by individual taxpayers and entities
taxed like individuals (for example, certain trusts and estates).
This form is used to report a taxpayer’s net 965 tax liability for
each tax year in which a taxpayer must report or pay section 965
amounts. In addition, this form is used to report the
determination of a taxpayer’s net 965 tax liability, whether or not
to be paid in installments; the payments of a net 965 tax liability
to be paid in installments; adjustments of any net 965 tax
liabilities outstanding, including any net 965 tax liability of the
taxpayer that has been assumed by another taxpayer or any net
965 tax liability that the taxpayer has assumed; an S corporation
shareholder’s net 965 tax liability with respect to an S
corporation, whether or not to be deferred; and the beginning
balance of, adjustments to, and ending balance of any deferred
net 965 tax liabilities with respect to an S corporation. In
summary, this form is intended to be a cumulative report of a
taxpayer’s net 965 tax liabilities through payment in full. This
form must be completed by a taxpayer for every tax year for
which the taxpayer has any net 965 tax liability outstanding and
not fully paid at any point during the tax year, including deferred
net 965 tax liabilities with respect to an S corporation.

Definitions
Deferred foreign income corporation (DFIC). A DFIC is, with
respect to any U.S. shareholder, any specified foreign
corporation (as defined under section 965(e)) of a U.S.
shareholder that has accumulated post-1986 deferred foreign
income (as defined under section 965(d)(2)) as of November 2,
2017, or December 31, 2017, that is greater than zero.
U.S. shareholder. For tax years of foreign corporations
beginning before January 1, 2018, a U.S. shareholder is a U.S.
person who owns (directly, indirectly, or constructively) 10% or
more of the total combined voting power of all classes of stock of
a foreign corporation. A U.S. person for this purpose is defined
in section 957(c) of the Code.
Net income tax liability. The taxpayer’s regular income tax
liability reduced by the credits allowed under subparts A, B, and
D of part IV of subchapter A (generally non-refundable credits;
specifically, those credits allowed under sections 21 through
30D and sections 38 through 45T).
Net 965 tax liability. The excess of the taxpayer’s net income
tax liability computed with all section 965 amounts included
(“with calculation”) over the taxpayer’s net income tax liability
without regard to section 965 (“without calculation”). See

Cat. No. 71280E

for Form 965-C for more details.) If this occurs, the transferee
should complete one of lines 5 through 8 in Part I as follows:
• In column (a), enter the tax year of the net 965 tax liability for
which the installment payment liability is being assumed. For
example, if a net 965 tax liability incurred in tax year 2017 (with
respect to which an installment payment election was made)
was transferred to a transferee in 2022, in 2022 the taxpayer
(transferee) reports “2017” in column (a).
• Skip columns (b) through (i).
• In column (j), report, as a positive number, the remaining
installment payment liability (that is, original liability less
payments made by the transferor) assumed by the taxpayer as
transferee.
• In column (k), report the tax identification number of the
transferor.
• Payments of such liability would then be reported on the
corresponding line of Part II in the same manner as if the
taxpayer were the transferor.
For example, assume Transferor had an original net 965 tax
liability of $100 in year 1, when an installment payment election
was made. In years 1 through 5, Transferor reports payments of
five 8% installments. Then, in year 6, the liability to pay the
remaining installments (15%, 20%, and 25%) totaling $60 is
transferred to Taxpayer as transferee. Taxpayer would report on
a line in Part I the tax year of the net 965 tax liability for which the
installment payment liability is being assumed in column (a); the
$60 amount of the transfer as a positive number in column (j);
and the tax identification number of Transferor in column (k). In
addition, on the corresponding line in Part II, Taxpayer would
report the $15 installment payment made in column (g), Paid for
Year 6 (the installment year as if Taxpayer were paying as
Transferor). In the next reporting year, Taxpayer would report all
the same information in Part II, plus the payment of $20 (20% of
the original $100 liability) in column (h), Paid for Year 7. In the
following reporting year, Taxpayer would report all the same
information as in year 7, plus the final payment of $25 (25% of
the original $100 liability) in column (i), Paid for Year 8.
• Triggered deferred S corporation-related net 965 tax
liability. Deferred S corporation-related net 965 tax liabilities
become subject to payment when a triggering event occurs.
(See instructions for Part III and Part IV for information
concerning the computation, reporting, deferral election, and
triggering events for S corporation-related net 965 tax liabilities.)
When such a deferred liability is triggered, it must be transferred
from Part IV, where it is annually reported, to Part I, column (f).
Such a triggered S corporation-related net 965 tax liability is
generally eligible for an election to be paid in 8 installments
beginning in the year of the triggering event. In the case of a
triggering event with respect to a deferred S corporation-related
net 965 tax liability, complete one of lines 5 through 8 as follows:
In column (a), report the tax year in which the triggering event
occurred. Skip columns (b) through (e) and report the triggered
liability in column (f). Report in column (g) whether the taxpayer
elected to pay the triggered liability in 8 installments by entering
“Yes” or “No.”

Regulations section 1.965-7(g)(10) for rules for computing the
net 965 tax liability.
S corporation-related net 965 tax liability. With respect to an
S corporation, the excess of the taxpayer’s net income tax
liability computed with all section 965 amounts included (which,
in this case, includes only section 965 amounts allocated from
such S corporation with respect to DFICs of which such S
corporation is a U.S. shareholder) (“with calculation”) over the
taxpayer’s net income tax liability without regard to section 965
(“without calculation”).
Reporting year. The tax year of the return with which this form
is being filed.

Who Must File

Any individual taxpayer (or taxpayer taxed like an individual) who
has a net 965 tax liability for any tax year or has any net 965 tax
liability remaining unpaid at any time during a tax year must file
this form.

When and Where To File

File Form 965-A with the income tax return of the taxpayer for
the reporting year by the due date (taking into account
extensions, if any) of the return.

Electronic Filing of Form 965-A

If you file your income tax return electronically, Form 965-A is
filed with the electronic income tax return. See the instructions
for your income tax return for general information about
electronic filing.

Specific Instructions
Amended Report

Check the amended report box at the top of page 1 of the form if
Form 965-A is filed with an amended return that is filed to
change any reporting related to section 965, regardless of
whether a Form 965-A has previously been filed. The amended
return box must also be checked for any amended Form 965-A
filed with a Form 1045 applying for a tentative refund resulting
from the carryback of an NOL to a section 965 year pursuant to
section 172(b)(1)(D)(i).

Part I – Report of Net 965 Tax Liability
and Election to Pay in Installments
Lines 1 through 8. Report in Part I net 965 tax liability amounts
as follows.
On lines 1, 2 and 3, you must continue to report 2017, 2018,
and/or 2019 amounts for all columns, including the original
computation of net 965 tax liability reported in columns (b)
through (i) on a prior-year Form 965-A. Report in column (j) any
current-year net 965 tax liability transferred out (that is, for which
you filed a valid transfer agreement as the transferor) or any
current tax year subsequent adjustments. Also, complete
column (k), if applicable.
For 2020 tax years, use line 4 to report section 965(a)
inclusions derived solely through interests in pass-through
entities that are U.S. shareholders of DFICs.
Use lines 5 through 8 to report other amounts of net 965 tax
liability of the taxpayer, such as:
• Installment liability transfers in. The taxpayer may, in
certain circumstances, and by agreement with the Secretary,
assume as transferee the installment payment liability for the
transferor's remaining net 965 tax liability and pay it in the same
manner as if the taxpayer were the transferor. (See instructions

For certain triggered net 965 tax liabilities, the taxpayer
may elect to pay in installments only with consent of the
CAUTION Secretary. (See instructions for Form 965-E for more
details.) Without consent, the taxpayer must enter a checkmark
in the “No” column of column (g) and enter the amount of the
triggered liability in column (h).

!

• If the taxpayer does not (or cannot) elect to pay the triggered
deferred net 965 tax liability in installments, then report the
amount from column (f) in column (h). This should equal the
payment reported in the corresponding line of Part II, column (b),
Paid for Year 1.
• If the taxpayer elects to pay the triggered liability in
installments, skip column (h) and report the amount from column
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Instructions for Form 965-A (Rev. 01-2021)

liability net of payments previously made, to a transferee in
2022, the taxpayer (transferor) would report, on line 1, column
(j), as a negative number, the amount of the net liability
transferred out. The making and reporting of payments on such
liability should generally cease (see instructions for Part II, later).
• Report any transfer in of a net 965 tax installment payment
liability from a seller/transferor by a transferee (see the
instructions for Lines 1 through 8, earlier).
• Report subsequent adjustments to the net 965 tax liability for
the tax year reported in column (a) for which no amended return
was required to be filed, such as an audit adjustment. A liability
increase should be reported as a positive number and a
decrease as a negative number.

(f) in column (i). The corresponding line in Part II, column (b),
Paid for Year 1, should report an 8% payment of the amount
elected to be paid in installments. The remaining payments
should generally be reported in subsequent reporting years
according to the installment schedule. (See instructions for Part
II, line 1, for the general installment schedule.)
• If lines 5 through 8 do not provide adequate lines to report all
the taxpayer’s transactions described above, an additional Form
965-A should be used.
Note. Even if a net 965 tax liability was reported on a taxpayer’s
income tax return and fully paid, because no elections were
made, the taxpayer must complete the appropriate line in Part I
and report the related payment on the corresponding line in Part
II, column (b).

Note. An adjustment of a net 965 tax liability elected to be paid
in installments is generally prorated to all installments.
For example, for tax year 2017, a taxpayer (TP) reported a
$100 net 965 tax liability for which an installment election was
made. For each of years 1 through 5, TP pays and reports an $8
installment. Also, in year 5, an audit adjustment increases the
2017 net 965 tax liability to $150, a $50 positive adjustment. No
amended return was required and there was no negligence,
intentional disregard, or fraud on the part of TP. This adjustment
would be prorated to all the installments. TP would report the
$50 adjustment in Part I, line 1, column (j), as a positive number,
so the reported adjusted liability would be $150. In addition, TP
would pay and report (in addition to the original $8 installment
reported for year 5) $20 on Part II, line 1, column (f),
representing 8% of the adjustment prorated to each of years 1
through 5, for which the installment due date had already
arrived. For year 6, TP would pay and report $22.50 (15% of the
adjusted $150 liability); for year 7, $30 (20% of the adjusted
$150 liability); and for year 8, $37.50 (25% of the adjusted $150
liability).
In a case in which a net 965 tax liability for a tax year is both
adjusted and transferred, report the net adjustment/transfer
number in column (j), a transferee tax identification number in
column (k), and provide a statement, attached to this form, which
includes details of the amounts netted in column (j).

Note. If an installment election under section 965(h) or a
deferral election under section 965(i) was made, then the
taxpayer must complete the appropriate line in Part I, as well as
the corresponding line in Parts II through IV, as applicable, to
report the status of the net 965 tax liability and any related
adjustments for the reporting year.
Column (b). Report the taxpayer’s net income tax liability for
the tax year reported in column (a), with all section 965 amounts
included (“with calculation”).
Column (c). Report the taxpayer’s net income tax liability for
the tax year reported in column (a), without regard to section 965
(“without calculation”).
Column (d). Report the excess of the taxpayer’s “with
calculation” reported in column (b) over the “without calculation”
reported in column (c). This is the taxpayer’s net 965 tax liability
for the tax year reported in column (a).
Column (e). If the taxpayer is a shareholder in one or more S
corporation(s) with section 965 amounts, report the total of
column (g) from Part III for the tax year reported in column (a).
This is the total S corporation-related net 965 tax liability the
taxpayer elected to defer. See detailed instructions for Part III
regarding the S corporation-by-S corporation calculations and
elections.

Part II – Record of Amount of Net 965
Tax Liability Paid by the Taxpayer

Column (f). Report the amount in column (d), less the amount
in column (e), if any. This is the taxpayer’s net 965 tax liability
eligible for the installment payment election.

Part II is intended to be a cumulative record of the actual
payments the taxpayer has made with respect to the net 965 tax
liabilities reported in Part I.

Column (g). If the taxpayer made an election to pay a net 965
tax liability in installments over 8 years as provided for in section
965(h) and in the manner described in Regulations section
1.965-7(b)(2), enter a check mark in the “Yes” column. If “Yes,”
skip column (h) and enter the amount from column (f) in column
(i). Otherwise, enter a check mark in the “No” column. If “No,”
enter the amount from column (f) in column (h) and skip column
(i).

Line 1. This line records the actual payments with respect to the
net 965 tax liability reported on line 1 of Part I for the tax year
2017.
The general installment payment schedule for a net 965 tax
liability subject to an election to pay in installments is:
1. 8% of the net 965 tax liability payable in year 1 (the year
of the section 965(a) inclusion or triggering event with respect to
a deferred S corporation-related net 965 tax liability),
2. 8% of the net 965 tax liability payable in year 2,
3. 8% of the net 965 tax liability payable in year 3,
4. 8% of the net 965 tax liability payable in year 4,
5. 8% of the net 965 tax liability payable in year 5,
6. 15% of the net 965 tax liability payable in year 6,
7. 20% of the net 965 tax liability payable in year 7, and
8. 25% of the net 965 tax liability payable in year 8.
If, for any reason, the actual payment differs from the
schedule, report the actual payment made.

The actual payment of the first installment is due no later
than the due date of the return for the tax year without
CAUTION extension, even if the election is made on a return filed
by the extended due date.

!

Column (j). Report the following in column (j):
• Report, as a negative number, any net 965 tax liability for the
year reported in column (a) that has been transferred out to a
transferee, by agreement with the Secretary, under which the
transferee becomes liable for the remaining installments due on
the liability in the same manner as if such transferee were the
taxpayer. (See instructions for Form 965-C for more details.) In
addition, provide the tax identification number of the transferee
in column (k). For example, if the taxpayer (transferor) incurred a
net 965 tax liability in tax year 2017, for which an installment
payment election was made, then properly transferred the
Instructions for Form 965-A (Rev. 01-2021)

Example. If the reporting year is 2020 and the taxpayer is
reporting a 2017 net 965 tax liability for which an installment
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amount reported on the corresponding line in Part I, column (j),
less any payments reported in Part II, columns (b) through (i).

payment election was made, because the 2020 reporting year is
“Year 4” with respect to a 2017 net 965 tax liability being paid in
installments, installment payments reported in Part II on line 1,
the line for 2017, should generally be:
• In column (b), Paid for Year 1, report 8% of the 2017 net 965
tax liability;
• In column (c), Paid for Year 2, report 8% of the 2017 net 965
tax liability;
• In column (d), Paid for Year 3, report 8% of the 2017 net 965
tax liability; and
• In column (e), Paid for Year 4, report 8% of the 2017 net 965
tax liability.

Column (k). For each line, report only the payment made (if
any) for the reporting year.
Current-year reporting of column (k) amounts:
Individuals: For tax year 2020, enter the amount from Form
965-A, Part II, column (k), line 4, on Schedule 2 (Form 1040),
line 9.
All others: For all other filers (that is, other taxpayers taxed like
an individual), follow the form instructions for that other
applicable return.

Part III – S Corporation Shareholder:
Report of Calculation of Net 965 Tax
Liability Related to 965 Amounts
Allocated from an S Corporation and
Election To Defer Such Net 965 Tax
Liability

Column (a). Report the tax year of the section 965(a) inclusion,
the net 965 tax liability for which an installment payment liability
is being assumed, or triggering event with respect to a deferred
S corporation-related net 965 tax liability, as reported on the
corresponding line of Part I, column (a).
Columns (b) through (i). These columns are used to record
the taxpayer’s cumulative payments, made each reporting year,
for the net 965 tax liability reported on the corresponding line in
Part I.
If no installment election is made, the net 965 tax liability
reported in Part I, column (h), should be paid and reported on
the corresponding line of Part II, column (b), Paid for Year 1, and
the remaining payment columns (c) through (i) left blank.
If an installment election is made, and no transfers,
acceleration events, or adjustments occur during the 8-year
installment period, then 8% of the net 965 tax liability should be
paid and reported in column (b), Paid for Year 1 (the year of the
installment payment election). In the next reporting year, the
relevant information from the prior reporting year should be
carried forward, plus 8% of the net 965 tax liability should be
paid and reported in column (c), Paid for Year 2. In future
reporting years, the payments and payment reporting should
continue similarly in accordance with the general installment
payment schedule described above.
If the taxpayer transfers out a net 965 tax liability, then the
making and reporting of installment payments should generally
cease for the transferred net 965 tax liability in the year of
transfer. However, reporting with respect to the net 965 tax
liability is still required for the reporting year if any net 965 tax
liability of the taxpayer remains unpaid at any time during the
reporting year.
If an acceleration event occurs, then the unpaid portion of all
remaining installments is due on the date of the acceleration
event and should be paid and reported in the column for the year
in which the acceleration event occurs; however, reporting with
respect to the net 965 tax liability is still required for the reporting
year if any net 965 tax liability of the taxpayer remains unpaid at
any time during the reporting year.
If an adjustment occurs to a net 965 tax liability for which an
installment election has been made, including on an amended
return, the adjustment should generally be prorated over all the
installment payments. For the part of the adjustment prorated to
installments whose payment date has already arrived, adjust the
payment for the reporting year in which the adjustment is made
and report accordingly. For the part of the adjustment prorated to
installments for which the payment date has not yet arrived, pay
and report in accordance with the installment schedule.
Payments should include both actual installment payments
made and excess payments of other income tax liabilities
applied to the taxpayer’s net 965 tax liability.

This Part allows a taxpayer that is an S corporation shareholder
to report net 965 tax liabilities related to section 965 amounts
with respect to S corporations. For each S corporation-related
net 965 tax liability, the taxpayer may elect to defer payment of
such liability until a triggering event occurs. (See instructions for
Part IV for more information on triggering events.) Each S
corporation-related net 965 tax liability is calculated on an
individual S corporation basis, and an election to defer such
liability is also made on an individual S corporation basis. Such
liabilities deferred, if any, must be totaled by tax year, and the
total carried to Part I, column (e), of the respective tax year line.

Lines 1 through 4. Report S corporation-related net 965 tax
liabilities for the tax year indicated. On lines 1, 2 and 3, you must
continue to report 2017, 2018, and/or 2019 amounts for all
columns, even though they were reported on a prior-year Form
965-A. Space is provided for reporting net 965 tax liabilities
related to up to four S corporations. If additional lines are needed
for the tax year, use additional Forms 965-A.
Column (a). Report the name of the S corporation from which
the taxpayer is allocated section 965 amounts. Abbreviate as
needed.
Column (b). Report the tax identification number of the S
corporation reported in column (a). The tax identification number
of an S corporation is its employer identification number (EIN).
Column (c). Report the taxpayer’s net income tax for the tax
year calculated only with section 965 amounts allocated from
this S corporation with respect to DFICs of which the S
corporation is a U.S. shareholder. This is the S
corporation-related “with calculation.”
Column (d). Report the taxpayer’s net income tax for the tax
year calculated without regard to section 965, that is, the
“without calculation.” This should equal the taxpayer’s net tax
liability without section 965 amounts for the corresponding tax
year reported in Part I, column (c).
Column (e). Report the excess of the taxpayer’s S
corporation-related “with calculation” reported in column (c) over
the “without calculation” reported in column (d). This is the
taxpayer’s S corporation-related net 965 tax liability with respect
to this S corporation for the tax year.
Column (f). If the taxpayer made an election to defer payment
of this S corporation-related net 965 tax liability as provided for in
section 965(i) and in the manner described in Regulations
section 1.965-7(c)(2), enter a check mark in the “Yes” column.
Otherwise, enter a check mark in the "No" column.

Column (j). Report the net 965 tax liability remaining unpaid
after the payment for the reporting year. This amount should
equal the amount reported on the corresponding line in Part I,
column (f), or column (i), as applicable, plus or minus any
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Instructions for Form 965-A (Rev. 01-2021)

Column (f). Report the amount of each deferred S
corporation-related net 965 tax liability, payment of which
ceases to be deferred as a result of a triggering event during the
reporting year (“triggered S corporation-related net 965 tax
liability”). The triggered S corporation-related net 965 tax liability
amount should be reported in column (f) as a negative number
and transferred to column (f) on one of lines 5 through 8 in Part I
as a positive number. See Triggered deferred S
corporation-related net 965 tax liability, in the instructions for
Part I, lines 1 through 8, earlier.

Column (g). If the taxpayer elected to defer an S
corporation-related net 965 tax liability, enter the amount from
column (e). (If the election was not made, then the liability
remains a part of the taxpayer’s total net 965 tax liability subject
to an installment payment election.) The total of column (g) for a
tax year represents the taxpayer’s total deferred S
corporation-related net 965 tax liability for the tax year and
should be entered on the corresponding tax year line in Part I,
column (e).

Part IV – Annual Report of Deferred
Net 965 Tax Liability Related to 965
Amounts Allocated from S
Corporations

Column (g). Report the amount of deferred S
corporation-related net 965 tax liability transferred out or in.
Transfers (out). When a taxpayer transfers stock of an S
corporation with respect to which the taxpayer has made an
election to defer payment of its S corporation-related net 965 tax
liability, the transfer is not treated as a triggering event if the
transferee, by agreement with the Secretary, becomes liable for
the deferred S corporation-related net 965 tax liability in the
same manner as the transferor. (See instructions for Form 965-D
for more details.)
Report the amount of the transfer out as a negative number in
column (g) of the same line as the taxpayer reported the
deferred S corporation-related net 965 tax liability at the
beginning of the reporting year.
In a case of multiple transferees, report the total deferred S
corporation-related net 965 tax liability transferred as a negative
number in column (g) and in column (h) report the tax
identification number of a transferee and attach a schedule to
Form 965-A providing a breakdown of the total deferred S
corporation-related net 965 tax liability transferred and the
associated tax identification numbers of each transferee.

Any shareholder of an S corporation that makes an election to
defer payment of an S corporation-related net 965 tax liability
must report such liability with their income tax return for the year
of election and every year thereafter through the year in which
such amount is fully paid. Part IV provides for the required
annual reporting of deferred S corporation-related net 965 tax
liabilities and any adjustments related to such deferred liabilities
during the reporting year.
If the taxpayer fails to report for any year information
required to be reported under section 965(i)(7) by the
CAUTION due date of the return for such year, 5% of the deferred
net 965 tax liability shall be assessed as an addition to tax for
such reporting year.

!

Column (a). Report the year of:
• Deferral election. In a year for which an election is made to
defer an S corporation-related net 965 tax liability, any amounts
elected to be deferred must be transferred from Part III, column
(g), to the corresponding line in Part IV, column (d). Enter the
year for which the election is made in column (a) of the
corresponding line.
• Transfer in. In certain circumstances, by agreement with the
Secretary, a taxpayer may assume a deferred S
corporation-related net 965 tax liability from another taxpayer
who had elected to defer such amount. The transferee is liable
for the deferred S corporation-related net 965 tax liability in the
same manner as the transferor, including being subject to
annual reporting requirements. (See instructions for Form 965-D
for more details.) Enter the tax year of transfer in column (a). See
the instructions for Part IV, column (g), later, for reporting the
amount of the transfer in.

Transfers in. A taxpayer may assume, by agreement with the
Secretary, a deferred 965 net tax liability as a buyer/transferee of
S corporation stock with respect to which the transferor has a
deferred S corporation-related net 965 tax liability. The taxpayer
will then be liable for the deferred S corporation-related net 965
tax liability in the same manner as the transferee, including being
subject to annual reporting requirements, beginning for the tax
year of transfer. (See instructions for Form 965-D for more
details.) For the year of transfer, a new line in Part IV must be
completed, skipping columns (d), (e), and (f), and entering in
both columns (g) and (i) the deferred S corporation-related net
965 tax liability transferred in as a positive number.
For reporting years following the year of transfer, report the
transferred deferred S corporation-related net 965 tax liability in
the same fashion as all other deferred S corporation-related net
965 tax liabilities.

Column (b). Report the name of the S corporation to which the
deferred net 965 tax liability relates. Abbreviate as needed.

Column (h). Provide the tax identification number of the
transferee or transferor.

Column (c). Report the tax identification number of the S
corporation reported in column (b). The tax identification number
of an S corporation is its employer identification number (EIN).

Column (i). For each line, combine the amounts reported in
columns (d) through (g).

Column (d). Report the beginning deferred S
corporation-related net 965 tax liability.
• For the year of the deferral election, this amount will be the S
corporation-related net 965 tax liability for which the taxpayer
elects to defer payment and should be transferred from the
corresponding line for such S corporation in Part III, column (g).
• For subsequent reporting years, the amount reported should
equal the amount on the corresponding line in column (i) from
Part IV of Form 965-A for the prior reporting year.
• For assumptions of deferred S corporation-related net 965 tax
liabilities, by agreement with the Secretary, the amount reported
should equal the amount of S corporation-related net 965 tax
liability assumed by the taxpayer.

Paperwork Reduction Act Notice

We ask for the information on this form to carry out the Internal
Revenue laws of the United States. You are required to give us
the information. We need it to ensure that you are complying
with these laws and to allow us to figure and collect the right
amount of tax.
You are not required to provide the information requested on
a form that is subject to the Paperwork Reduction Act unless the
form displays a valid OMB control number. Books or records
relating to a form or its instructions must be retained as long as
their contents may become material in the administration of any
Internal Revenue law. Generally, tax returns and return
information are confidential, as required by section 6103.

Column (e). Reserved for future use.
Instructions for Form 965-A (Rev. 01-2021)

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The time needed to complete and file this form will vary
depending on individual circumstances. The estimated burden
for individual taxpayers filing this form is approved under OMB

control number 1545-0074 and is included in the estimates
shown in the instructions for their individual income tax return.

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Instructions for Form 965-A (Rev. 01-2021)