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Foreign entity returns

Investment in US Property and PFIC

The
Investment in U.S. Property and PFIC
 screen is used to enter investment in U.S. property amounts, any current year Section 960(c) Reduction of Deemed Paid Taxes (tax years 2011 and later), and any PFIC Inclusions. The investment in U.S. property for the year can be calculated by the system or entered as a net number if it has already been calculated for the year.
  1. On the TAS navigation tree, select the
    Foreign Entity
     folder.
  2. Select
    Investment in US Property and PFIC
    .
  3. If the Investment in U.S. Property amount has already been computed, select the
    Enter Sec 956 if already computed
     radio button and enter the current amount in the first field.
  4. Select the
    Enter aggregate of investment in U.S. Property
     option and let the system compute the investment in U.S. property to enter the quarterly aggregate investment amounts.
  5. Enter the
    Adjusted Basis
     for the assets for each quarter.
  6. Enter the
    Liabilities to which this property is subject
     for each quarter.
    The Quarterly Average of U.S. Investments field is automatically updated. The system compares this amount to the Section 959(c)(1)(A) earnings and profits to process a deemed paid dividend and deemed paid taxes based on available E&P.
  7. Enter a current year
    PFIC Inclusion
     amount if applicable.
  8. Select
    Save
    .

960(c) Reduction of Deemed Paid Taxes (Override)

A 960(c) Reduction of Deemed Paid Taxes (Override) tab is available in the Investment in U.S. Property and PFIC screen for tax years 2011 and later to record any decreases to the system calculated deemed paid credits on Section 956 (Investment in US Property) inclusions during Subpart F computes.
If you select the
Use Override Values
 box at the top of the
960(c) Reduction of Deemed Paid Taxes (Override)
tab, the system uses the amounts you enter in the
Amounts in U.S. Dollars
 column during Subpart F computes for that foreign entity. If you do not check the box, the system ignores any amounts entered in the 960(c) Overrides screen.
The Section 960(c) DPT Reduction transfers to the
Adjustments
tab in the FTC owner's
Foreign Income Tax
 screen during the International Transfer process of TAS Compute in the FTC Entity.

This article applies to:

  • Product: ONESOURCE Income Tax
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