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See what's trending for the November 15th deadline (Form 990) and resources for the upcoming tax season. View ProConnect Hot Topics.
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- Re: I have a client that we need to elect Sec 954(b)(4) " High-Tax exeption for CFC"I do not find such election in Proconnect...Help !! Thanks!
I have a client that we need to elect Sec 954(b)(4) " High-Tax exeption for CFC" I do not find such election in Proconnect... Help !! Thanks!
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hjasin
Level 1
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."
