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Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States

In extremely rare cases, due to pass-through partnership claims, an IRC 965 inclusion could be made in 2020.

For returns with an IRC 965(h) election made in the inclusion year and/or in the year of the triggering event for an IRC 965(i) election moving to an IRC 965(h) election, a TC 766 with Credit Reference Number (CRN) 263 should be posted to the module indicating the remaining unpaid IRC 965 liability amount (deferred amount) to be paid in installments.

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