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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Federal tax forms

Form 965-C is one of Federal tax forms that are documents used to report and file federal income taxes with the Internal Revenue Service (IRS) in the United States. These forms are used by individuals, businesses, and organizations to report their income, deductions, and other relevant information necessary for calculating their federal tax liability.

The most commonly used federal tax form is the Form 1040, which is used by individual taxpayers to report their personal income tax. Other commonly used forms include the Form 1065 for partnerships, Form 1120 for corporations, and Form 990 for tax-exempt organizations.

Federal tax forms typically require taxpayers to report various sources of income, such as wages, salaries, and tips, as well as income from investments, rental properties, and other sources. The forms also allow taxpayers to claim deductions and credits for various expenses, such as charitable contributions, mortgage interest, and healthcare expenses.

It is important to file federal tax forms accurately and on time, as failure to do so can result in penalties and interest charges from the IRS.

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