What information is required in Part IV of Form 965-C?

Part IV of Form 965-C requires the entry of the transferor's section 965(h) net tax liability remaining unpaid and the date of the next installment payment due by the transferee.

What is Form 965-C used for?

Form 965-C is a document used by eligible taxpayers to enter into a transfer agreement under IRC Section 965(h) for the assumption of a portion of another taxpayer's section 965(h) net tax liability arising from the transition tax under IRC Section 965.

What information is required in Part II of Form 965-C?

Part II of Form 965-C requires the name, address, and identification number of the eligible section 965(h) transferee, as well as a description of the covered acceleration event.

What information is required in Part I of Form 965-C?

Part I of Form 965-C requires the name, address, and identification number of both the eligible section 965(h) transferor and the eligible section 965(h) transferee.

What is required in Part V of Form 965-C?

Part V of Form 965-C requires the eligible section 965(h) transferee to confirm their ability to pay the remaining payments required under IRC Section 965(h) with respect to the section 965(h) net tax liability being assumed.

What is required in Part VI of Form 965-C?

Part VI of Form 965-C requires both the eligible section 965(h) transferor and the eligible section 965(h) transferee to sign the transfer agreement, certifying that they have examined the form and that it is true, correct, and complete.

What is the purpose of the leverage ratio requirement in Part V of Form 965-C?

The leverage ratio requirement in Part V of Form 965-C is used by the Commissioner to determine whether the eligible section 965(h) transferee has the ability to pay the outstanding section 965(h) net tax liability. A leverage ratio in excess of three to one does not necessarily mean that a transfer agreement is invalid.

What is a covered acceleration event?

A covered acceleration event is an event that triggers the inclusion in income under IRC Section 965 of previously untaxed foreign earnings and profits or previously taxed foreign earnings and profits that have been reclassified as subpart F income or global intangible low-taxed income.

Who are the parties involved in a Form 965-C agreement?

The parties involved in a Form 965-C agreement are the eligible section 965(h) transferor and the eligible section 965(h) transferee.

What information is required in Part III of Form 965-C?

Part III of Form 965-C requires a detailed description of the covered acceleration event, including the date it occurred and the amount of foreign base company sales or services income and global intangible income included in income under IRC Section 965.

Form 965-C

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Transfer Agreement Under Section 965(h)(3)

Rev. December 2019

These instructions explain how to complete Part VI of Form 965-C, which pertains to the terms of agreement for transferring section 965(h) net tax liability. The transferee must agree to assume the liability and comply with all applicable requirements under section 965(h) and Regulations thereunder.

Instructions

Form 965-C Instructions - Instructions for Form 965-C, Transfer Agreement Under Section 965(h)(3)

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Form 965-C

FAQ

What information is required in Part IV of Form 965-C?
Part IV of Form 965-C requires the entry of the transferor's section 965(h) net tax liability remaining unpaid and the date of the next installment payment due by the transferee.
What is Form 965-C used for?
Form 965-C is a document used by eligible taxpayers to enter into a transfer agreement under IRC Section 965(h) for the assumption of a portion of another taxpayer's section 965(h) net tax liability arising from the transition tax under IRC Section 965.
What information is required in Part II of Form 965-C?
Part II of Form 965-C requires the name, address, and identification number of the eligible section 965(h) transferee, as well as a description of the covered acceleration event.
What information is required in Part I of Form 965-C?
Part I of Form 965-C requires the name, address, and identification number of both the eligible section 965(h) transferor and the eligible section 965(h) transferee.
What is required in Part V of Form 965-C?
Part V of Form 965-C requires the eligible section 965(h) transferee to confirm their ability to pay the remaining payments required under IRC Section 965(h) with respect to the section 965(h) net tax liability being assumed.
What is required in Part VI of Form 965-C?
Part VI of Form 965-C requires both the eligible section 965(h) transferor and the eligible section 965(h) transferee to sign the transfer agreement, certifying that they have examined the form and that it is true, correct, and complete.
What is the purpose of the leverage ratio requirement in Part V of Form 965-C?
The leverage ratio requirement in Part V of Form 965-C is used by the Commissioner to determine whether the eligible section 965(h) transferee has the ability to pay the outstanding section 965(h) net tax liability. A leverage ratio in excess of three to one does not necessarily mean that a transfer agreement is invalid.
What is a covered acceleration event?
A covered acceleration event is an event that triggers the inclusion in income under IRC Section 965 of previously untaxed foreign earnings and profits or previously taxed foreign earnings and profits that have been reclassified as subpart F income or global intangible low-taxed income.
Who are the parties involved in a Form 965-C agreement?
The parties involved in a Form 965-C agreement are the eligible section 965(h) transferor and the eligible section 965(h) transferee.
What information is required in Part III of Form 965-C?
Part III of Form 965-C requires a detailed description of the covered acceleration event, including the date it occurred and the amount of foreign base company sales or services income and global intangible income included in income under IRC Section 965.

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Tax forms

Form 965-C is one of Tax forms that are documents used to report information about an individual's or business's income, deductions, and tax liability to the relevant tax authority. These forms are necessary to comply with tax laws and fulfill tax obligations. Tax forms vary depending on the country and the specific tax requirements in place. Here are some common types of tax forms:

Individual Tax Forms: These forms are used by individual taxpayers to report their personal income and claim deductions, credits, and exemptions. Examples include the 1040 form in the United States or the Self-Assessment Tax Return form in the United Kingdom.

Business Tax Forms: Business tax forms are used by companies, partnerships, or self-employed individuals to report their business income, expenses, and other tax-related information. Examples include the Schedule C form (Profit or Loss from Business) in the United States or the CT600 form (Company Tax Return) in the United Kingdom.

Payroll Tax Forms: These forms are used by employers to report the wages, salaries, and taxes withheld from their employees' paychecks. Examples include the W-2 form in the United States or the P60 form in the United Kingdom.

Sales Tax Forms: Sales tax forms are used by businesses to report and remit sales tax collected on taxable goods or services. The specific sales tax forms vary by jurisdiction.

Value Added Tax (VAT) Forms: VAT forms are used in countries that impose a value-added tax to report and remit VAT collected on sales and claim VAT credits for purchases. Examples include the VAT return forms used in many countries.

Estimated Tax Forms: Estimated tax forms are used to report and pay estimated taxes on income that is not subject to withholding, such as self-employment income or investment income.

These are just a few examples of the numerous tax forms that may exist. The specific forms required depend on the tax laws and regulations in your country or jurisdiction. It is important to consult the tax authority's guidelines or seek professional advice to determine which forms are applicable to your situation.

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