Exception:
Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States
REQ77 and credit transfer actions should be taken without HQ approval. The above only applies to REQ54/ADJ54 adjustments.
The TC 971 AC 114 amount represents the total IRC Section 965 tax minus any amount deferred under 965(i). For TY 2017, the TC 971 AC 115 represented the IRC 965(h) deferred tax amount as reported by the taxpayer and was used to generate the TC 766 CRN 263 faux credit.
For TY 2018 and TY 2019, BMF programming systemically posted a TC 766 CRN 263 from amounts reported on applicable BMF returns, see the tables located in IRM 3.14.2.6.5, IRC 965 Transition Tax Overview, for additional information on how the TC 766 CRN 263 was systemically posted on TY 2018 and TY 2019 modules.
IRC 965 designated payments are identified with a Designated Payment Code (DPC) of 64. They should post to the inclusion year module as a TC 670 DPC 64. Once posted, BMF programming systemically generate a TC 767 CRN 263 in the amount of the payment.
If, when reviewing an inclusion year module or triggering event year module where a Section 965(h) election was made to pay the triggered liability in installments, it appears that the taxpayer failed to pay an installment that was due, research the inclusion year/triggering event year module and each subsequent year module to see if the installment payment was misapplied and/or mis-coded and therefore not applied to the deferral. Refer to the table below when researching and transferring IRC 965 designated payments and/or applying payment to the Section 965 deferral:
If
And
Then
The IRC 965 designated payment (TC 670 DPC 64) posted to a non-inclusion year module or non-triggering event year module
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