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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ABOUT

Internal Revenue Service (IRS) Forms

Form 965-C is one of the official tax forms used in the United States to report income, claim deductions and credits, calculate tax liability, and fulfill other tax-related obligations. The IRS is the federal agency responsible for administering and enforcing the internal revenue laws in the United States.

Here are some examples of Internal Revenue Service forms:

Form 1040: This is the primary individual income tax return form used by most taxpayers. It is used to report various types of income, claim deductions and credits, calculate tax liability, and determine whether a taxpayer owes additional tax or is entitled to a refund.

Form 1099: There are different variations of Form 1099, such as 1099-MISC, 1099-INT, 1099-DIV, etc. These forms are used to report income received by individuals or businesses from various sources other than employment, such as self-employment income, interest income, dividend income, and rental income.

Form W-2: This form is used by employers to report wages paid to employees and the taxes withheld from their pay. Employees use the information on Form W-2 to complete their individual tax returns.

Form 941: Employers use this form to report employment taxes, including federal income tax withheld, Social Security tax, and Medicare tax, for their employees.

Form 1065: This form is used by partnerships to report their income, deductions, and tax liability. Partnerships themselves do not pay income tax; instead, the partners report their share of partnership income on their individual tax returns.

Form 1120: This is the corporate income tax return form used by C corporations to report their income, deductions, and tax liability.

Form 990: This form is used by tax-exempt organizations, such as nonprofits and charities, to report their financial information, activities, and compliance with tax laws.

Form 8862: This form is used by taxpayers who previously claimed the Earned Income Tax Credit (EITC) but had it disallowed, and now want to claim it again.

These are just a few examples of the numerous IRS forms that exist to fulfill various tax-related obligations. The specific forms required for an individual or business depend on their unique circumstances, income sources, and deductions. It's advisable to consult the official website of the Internal Revenue Service (www.irs.gov) or seek professional tax advice to obtain accurate and up-to-date information regarding the specific IRS forms relevant to your tax situation.

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