Section 15. Return of Partnership Income›3.11.15 Return of Partnership Income›Note:
Section 965 Returns
Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States
Section 965 (Repatriation Provision), Treatment of deferred foreign income upon transition to participation exemption systems of taxation for U.S. Shareholders of Specified Foreign Corporations per Tax Cuts & Jobs Act (Tax Reform), Public Law 115-97 (H.R. 1), Provision Section 14103, 131 STAT. 2195 (2017).
Identify a Section 965 return when any of the following are present and the partnerships Tax Period is 201712 through 202012:
"Section 965" or "965 Tax" (or similar language) notated on the return, attachments, or statements.
IRC 965 Transition Tax Statement (or similar 965 statement) is attached.
A significant entry is present on Line 11 or Line 13d of Schedule K, with the notation "Section 965" (or similar) statement.
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