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Subpart F

Binder Properties - foreign entity international

If you have a Foreign Entity binder, the International Binder Properties has a
Section 965
 account types to allow FTC entities to capture inclusions, dividend received deductions (DRDs) and Section 78 gross-ups at a cash/noncash level for Section 965 calculations for the determination of deferred foreign income and related amounts.
The cash, translation rate and deferred earnings information reported in the Repatriation of Deferred Foreign Income workpaper of each controlled foreign corporation and non-controlled 10/50 company is considered during Subpart F calculations to determine the Section 965 cash position, earnings and any deficit allocation regardless of the foreign entity’s repatriation checkbox status.
The default state of the repatriation box is unchecked.
  • Check the repatriation box in a tax year 2017 binder to indicate that the Section 965 inclusion for the foreign entity should be reported in the U.S. filer’s 2017 taxable income.
  • Do not check if the Section 965 inclusion (and related amounts) should be included in the U.S. filer’s 2018 return.

This article applies to:

  • PRODUCT: ONESOURCE Income Tax
  • Return type: international
  • Subject: Setup

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