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 income, deductions, and tax liability to the relevant tax authority. These forms are an essential part of the tax filing process and are used to ensure individuals and businesses comply with tax laws and accurately calculate their tax obligations.

The specific tax forms required can vary depending on factors such as an individual's filing status, sources of income, and the country's tax laws. However, here are some common types of tax forms:

Individual Income Tax Forms: These forms, such as the 1040 series in the United States, are used by individuals to report their income, claim deductions and credits, and calculate their tax liability.

Business Tax Forms: Businesses, including sole proprietorships, partnerships, corporations, and self-employed individuals, may have to file various forms to report their income, expenses, and taxes owed. Examples include Schedule C (Profit or Loss from Business) and Form 1120 (U.S. Corporation Income Tax Return).

Employment Tax Forms: Employers are required to report employee wages and withhold and remit payroll taxes. Forms such as W-2 (Wage and Tax Statement) and 941 (Employer's Quarterly Federal Tax Return) are used for this purpose.

Investment and Retirement Account Forms: These forms are used to report investment income, capital gains, and losses, as well as contributions and distributions from retirement accounts. Examples include Form 1099-DIV (Dividends and Distributions) and Form 5498 (IRA Contribution Information).

Estate and Gift Tax Forms: When a person passes away or makes significant gifts, specific forms such as Form 706 (United States Estate (and Generation-Skipping Transfer) Tax Return) and Form 709 (United States Gift (and Generation-Skipping Transfer) Tax Return) are used to report and calculate any applicable estate or gift taxes.

It is important to note that tax laws and forms can change over time, so individuals and businesses should consult the relevant tax authority or seek professional tax advice to ensure compliance with the current requirements.

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