IRC 965(h) Elections
Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States
An IRC 965(h) election is a deferral to pay the Section 965 transition tax in 8 annual installments.
IRC 965(h) elections are applicable to Forms: 1120 (MFT 02), 1120-C (MFT 02), 1120-L (MFT 02), 1120-PC (MFT 02), 1120-RIC (MFT 02), 1120-REIT (MFT 02), 990-T (MFT 34) & 1041 (MFT 05).
A 965(h) election could be made during the IRC 965 inclusion period (201712-201911), by including both the Section 965 income and Section 965 tax and deferring a portion of the Section 965 tax on the inclusion year return.
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