965 id application request 2026

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(1) In general For purposes of this section, the term specified foreign corporation means (A) any controlled foreign corporation, and (B) any foreign corporation with respect to which one or more domestic corporations is a United States shareholder.
Section 965 allows U.S. shareholders to reduce the amount of the income inclusion based on deficits in earnings and profits with respect to other specified foreign corporations. The effective tax rates applicable to income inclusions are adjusted by way of a participation deduction set out in section 965(c).
Section 965 requires United States shareholders (as defined under section 951(b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States.
Form 965, Inclusion of Deferred Foreign Income Upon Transition to Participation Exemption System, is used to report the following items: Section 965(a) inclusions from pass-through entities, the related foreign taxes deemed paid, and the related foreign taxes deemed paid but disallowed under section 965(g);
Form 965-C is used by an eligible section 965(h) transferor and transferee to enter into a transfer agreement so as not to trigger the acceleration of the deferred net 965(h) tax liability.

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For example, a taxpayer may have $400 of aggregate foreign cash position and takes into account a $300 section 965(a) inclusion amount on its 2017 tax return. The taxpayer will take into account $300 of aggregate foreign cash position on the 2017 tax return.

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