Caution:

If the taxpayer is a shareholder in more than one S corporation with section 965 amounts, the taxpayer could have elected to defer more than one S corporation-related net 965 tax liability until a triggering even occurs. There can be instances where an S-Corp(s) (whose related net 965 liability was deferred) experience a triggering event while others do not, meaning the triggered liability becomes due while the non-triggered liabilities remain deferred. So, the amount of 965(i) deferred tax that was reported in the inclusion year is subject to change as the deferred liabilities are triggered. The sum of Form 965-A, Individual Report of Net 965 Tax Liability, Part IV, Column (i) should reflect the remaining deferred IRC 965(i) net tax liability at the end of the reporting year. This total is the amount that is input into the TC 971 AC 165 Misc Field each year a 965(i) election remains intact.

If a taxpayer fails to report an intact 965(i) liability annually by not attaching a complete Form 965-A ,Individual Report of Net 965 Tax Liability, to their income tax return reflecting the amount of the 965(i) deferred liability for the reporting year

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