Thỏa thuận chuyển nhượng theo Mục 965 (h) (3)
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.
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.
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.
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.
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.
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.
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.
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.
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.
The parties involved in a Form 965-C agreement are the eligible section 965(h) transferor and the eligible section 965(h) transferee.
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.
Mẫu 965-C là một trong những Biểu mẫu khai thuế là văn bản dùng để khai báo các thông tin liên quan đến thuế với cơ quan thuế liên quan. Có nhiều loại biểu mẫu thuế khác nhau, bao gồm biểu mẫu thuế liên bang, tiểu bang và địa phương, có thể khác nhau tùy thuộc vào hoàn cảnh và địa điểm của người nộp thuế.
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