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.- On the TAS navigation tree, select theForeign Entityfolder.
- SelectInvestment in US Property and PFIC.
- If the Investment in U.S. Property amount has already been computed, select theEnter Sec 956 if already computedradio button and enter the current amount in the first field.
- Select theEnter aggregate of investment in U.S. Propertyoption and let the system compute the investment in U.S. property to enter the quarterly aggregate investment amounts.
- Enter theAdjusted Basisfor the assets for each quarter.
- Enter theLiabilities to which this property is subjectfor 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.
- Enter a current yearPFIC Inclusionamount if applicable.
- SelectSave.
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.