Ugovor o prijenosu prema odjeljku 965 (i) (2)
Form 965-D (12-2019) is a transfer agreement under Section 965(i)(2) of the Internal Revenue Service's Department of the Treasury. The form is used for reporting the transfer of stock from one party to another and the assumption of section 965(i) net tax liability by the transferee. Parties involved are required to provide identifying information including names, taxpayer identification numbers, addresses, and cities or towns. Sections in the document include Transferor Information, Transferee Information, Identifying Information of the S Corporation, Triggering Event Leading to Transfer Agreement, Report of Unpaid Section 965(i) Net Tax Liability or Portion Thereof Attributable to Transferred Stock, Terms of Agreement, and Instructions. The document outlines conditions for eligibility, procedures for reporting, and the parties' obligations and liabilities.
Yes, failure to file a complete Form 965-D on time may result in penalties, including late payment penalties and possible accuracy-related penalties. It is important to consult with tax advisors for specific guidance.
Form 965-D, Transfer Agreement for Section 965(i) Liability, is used by eligible taxpayers to transfer their section 965(i) net tax liability to a related party in connection with certain transfers of stock of controlled foreign corporations (CFCs). The form is required to be filed with the IRS and provides details about the covered triggering event, the transferred stock, the parties involved, and the terms of the agreement.
Form 965-D must be filed electronically through the IRS FIRE system. A paper copy of the form and all supporting documentation should be kept for records.
The parties must file a valid and complete Form 965-D, which includes detailed information about the covered triggering event, the transferred stock, and the terms of the agreement. Additionally, the eligible section 965(i) transferee must have the ability to pay the outstanding net tax liability.
Eligible parties include an eligible section 965(i) transferor (the taxpayer transferring the stock and net tax liability) and an eligible section 965(i) transferee (the taxpayer assuming the net tax liability). Both parties must be related entities under common control.
A covered triggering event includes the sale, exchange, or other disposition of all or part of the stock in a CFC. It can also include the death of an eligible section 965(i) transferor.
Obrazac 965-D je jedan od Poreznih obrazaca koji su dokumenti koji se koriste za prijavu informacija povezanih s porezima relevantnom poreznom tijelu. Postoje različite vrste poreznih obrazaca, uključujući savezne, državne i lokalne porezne obrasce, koji se mogu razlikovati ovisno o okolnostima i lokaciji poreznog obveznika.
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