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Level 2
December 6, 2019
Solved

Section 965(a) amount

  • December 6, 2019
  • 1 reply
  • 16 views

section 965(a) amount is reported to taxpayer on k-1

the amount is quite small

From what I read, it sounds like there is a requirement to report income on the 1040 and a requirement to report and pay tax on some other form

Also I understand there is a disclosure statement that is required, and so far I have not seen any references to where that reporting is done

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Best answer by itonewbie

§965(a) income net of §965(c) deduction should be reported on Line 21 of F.1040 unless the taxpayer is eligible for §962 and elects to be taxed as a domestic C-corp for the purpose of Subpart F.  An IRC 965 Transition Tax Statement signed under the penalty of perjury must also be attached to the return.

You should also review whether the taxpayer is required to file F.5471 based on constructive ownership.

1 reply

itonewbie
itonewbieAnswer
Level 15
December 6, 2019

§965(a) income net of §965(c) deduction should be reported on Line 21 of F.1040 unless the taxpayer is eligible for §962 and elects to be taxed as a domestic C-corp for the purpose of Subpart F.  An IRC 965 Transition Tax Statement signed under the penalty of perjury must also be attached to the return.

You should also review whether the taxpayer is required to file F.5471 based on constructive ownership.

---------------------------------------------------------------------------------Still an AllStar
Level 2
December 6, 2019
Also, it appears that the 965 tax from Form 965-A should be put on Schedule 4 line 63.  However, if you do that, it appears that you are double taxing the 965 income since it is already on line 21.  Has anyone else experienced that?