Note:

A United States shareholder is generally a United States person who owns 10 percent or more of the foreign corporation’s stock, applying the indirect stock ownership principles of section 958.

In general, foreign income held in the form of cash and cash equivalents is intended to be subject to an effective tax rate of 15.5 percent for calendar year domestic corporate taxpayers, and the remaining earnings are intended to be taxed at 8 percent.

The IRC 965 inclusion period was 201712 through 201911. After November 2019, no new IRC 965 inclusions are allowable.