hjasin
		
		
		
		
		
		
		
		
	
			
		
		
			
					
		
	
	
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		05-24-2022
	
		
		04:45 PM
	
	
	
	
	
	
	
	
	
	
	
	
	
	
		
	
				
		
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			jrodriguezcpa
		
		
		
		
		
		
		
		
	
			
		
		
			
					
		
	
	
			Level 2
		
	
				
		
	
		
			
    
	
		
		
		05-04-2023
	
		
		03:53 PM
	
	
	
	
	
	
	
	
	
	
	
	
	
	
		
	
				
		
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In the table of contents go to "Other" then "Elections" then on top again to "Other" tab and then creat your own election at the "Other Election" fields.
			
		
			
	
	
			
				
		
		
			jrodriguezcpa
		
		
		
		
		
		
		
		
	
			
		
		
			
					
		
	
	
			Level 2
		
	
				
		
	
		
			
    
	
		
		
		05-04-2023
	
		
		04:38 PM
	
	
	
	
	
	
	
	
	
	
	
	
	
	
		
	
				
		
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Here is an example of the text of an election under section 954(b)(4):
"I, [Name], a U.S. shareholder of [CFC Name], hereby make an election under section 954(b)(4) of the Internal Revenue Code to exclude from Subpart F income for the taxable year ended [Date], my pro rata share of the accumulated earnings and profits of [CFC Name] attributable to income that was subject to income tax in [Foreign Country Name] at a rate equal to or greater than 90% of the maximum U.S. corporate income tax rate for the taxable year."