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District Court Denver Probate Court County, Colorado Court Address: In the Matter of the Estate of: COURT USE ONLY Deceased Attorney or Party Without Attorney (Name and Address): Case Number: Phone.

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Categories 1a, 1c, 5a, and 5c to CFCs for purposes of Form 5471 classification. . Section 965 Specified Foreign Corporation (“SFC”)- An SFC is a foreign corporation that is either a CFC or has at least one U.S. shareholder that is a corporation.

Deferred Foreign Income: Defined in IRC 965(d)(2) and in general means the post-1986 earnings and profits except to the extent such earnings are attributable to income of the specified foreign corporation which is effectively connected with the conduct of a trade or business within the United States and subject to tax ...

Form 965-A is used by individual taxpayers and entities taxed like individuals to report a taxpayer's net 965 liability, for each tax year in which a taxpayer must account for section 965 amounts.

1 originally known as the “Tax Cuts and Jobs Act”, U.S. persons (citizens, resident aliens, and domestic corporations) with 10% or higher stock ownership in Specified Foreign Corporations (SFC) are subject to “deemed repatriation” tax.

What is section 965? Section 965 requires United States shareholders (as defined under section 951(b)) to pay a transition tax on the untaxed foreign earnings of certain specified foreign corporations as if those earnings had been repatriated to the United States.

A CFC is also, by definition, a SFC. Specified foreign corporation (SFC) - In addition to CFCs, an SFC is "any foreign corporation with respect to which one or more domestic corporations is a United States shareholder."

Very generally, a specified foreign corporation means either a controlled foreign corporation, as defined under section 957 (“CFC”), or a foreign corporation (other than a passive foreign investment company, as defined under section 1297, that is not also a CFC) that has a United States shareholder that is a domestic ...

An SFC is (i) any CFC and (ii) any foreign corporation with respect to which one or more domestic corporations is a U.S. shareholder. However, if a passive foreign investment company (as defined in section 1297) with respect to the shareholder is not a CFC, then such corporation is not an SFC.

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© Copyright 1997-2025
airSlate Legal Forms, Inc.
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Form Packages
Adoption
Bankruptcy
Contractors
Divorce
Home Sales
Employment
Identity Theft
Incorporation
Landlord Tenant
Living Trust
Name Change
Personal Planning
Small Business
Wills & Estates
Packages A-Z
Form Categories
Affidavits
Bankruptcy
Bill of Sale
Corporate - LLC
Divorce
Employment
Identity Theft
Internet Technology
Landlord Tenant
Living Wills
Name Change
Power of Attorney
Real Estate
Small Estates
Wills
All Forms
Forms A-Z
Form Library
Customer Service
Terms of Service
DMCA Policy
About Us
Blog
Affiliates
Contact Us
Privacy Notice
Delete My Account
Site Map
Industries
Forms in Spanish
Localized Forms
State-specific Forms
Forms Kit
Legal Guides
Real Estate Handbook
All Guides
Prepared for You
Notarize
Incorporation services
Our Customers
For Consumers
For Small Business
For Attorneys
Our Sites
US Legal Forms
USLegal
FormsPass
pdfFiller
signNow
airSlate workflows
DocHub
Instapage
Social Media
Call us now toll free:
1-877-389-0141
As seen in:
  • USA Today logo picture
  • CBC News logo picture
  • LA Times logo picture
  • The Washington Post logo picture
  • AP logo picture
  • Forbes logo picture
© Copyright 1997-2025
airSlate Legal Forms, Inc.
3720 Flowood Dr, Flowood, Mississippi 39232