§965(a) income net of §965(c) deduction should be reported on Line 21 of F.1040 unless the taxpayer is eligible for §962 and elects to be taxed as a domestic C-corp for the purpose of Subpart F.  An IRC 965 Transition Tax Statement signed under the penalty of perjury must also be attached to the return.

You should also review whether the taxpayer is required to file F.5471 based on constructive ownership.