hjasin
Level 1
05-24-2022
04:45 PM
- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
Labels
jrodriguezcpa
Level 2
05-04-2023
03:53 PM
- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
In the table of contents go to "Other" then "Elections" then on top again to "Other" tab and then creat your own election at the "Other Election" fields.
jrodriguezcpa
Level 2
05-04-2023
04:38 PM
- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
Here is an example of the text of an election under section 954(b)(4):
"I, [Name], a U.S. shareholder of [CFC Name], hereby make an election under section 954(b)(4) of the Internal Revenue Code to exclude from Subpart F income for the taxable year ended [Date], my pro rata share of the accumulated earnings and profits of [CFC Name] attributable to income that was subject to income tax in [Foreign Country Name] at a rate equal to or greater than 90% of the maximum U.S. corporate income tax rate for the taxable year."