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                                                                                                     Department of the Treasury
                                                                                                     Internal Revenue Service
Instructions for Form 965-A

(Rev. January 2020)
Individual Report of Net 965 Tax Liability

Section references are to the Internal Revenue Code unless             determination of a taxpayer’s net 965 tax liability, whether or not 
otherwise noted.                                                       to be paid in installments; the payments of a net 965 tax liability 
                                                                       to be paid in installments; adjustments of any net 965 tax 
                                                                       liabilities outstanding, including any net 965 tax liability of the 
Future Developments                                                    taxpayer that has been assumed by another taxpayer or any net 
For the latest information about developments related to Form          965 tax liability that the taxpayer has assumed; an S corporation 
965-A and its instructions, such as legislation enacted after they     shareholder’s net 965 tax liability with respect to an S 
were published, go to IRS.gov/Form965A.                                corporation, whether or not to be deferred; and the beginning 
                                                                       balance of, adjustments to, and ending balance of any deferred 
                                                                       net 965 tax liabilities with respect to an S corporation. In 
What’s New                                                             summary, this form is intended to be a cumulative report of a 
In Parts I, II, and III of the form, line 3 is now designated for use  taxpayer’s net 965 tax liabilities through payment in full. This 
for 2019 reporting.                                                    form must be completed by a taxpayer for every tax year for 
  The IRS has developed the following new forms:                       which the taxpayer has any net 965 tax liability outstanding and 
Form 965-C, Transfer Agreement Under Section 965(h)(3).              not fully paid at any point during the tax year, including deferred 
Form 965-D, Transfer Agreement Under Section 965(i)(2).              net 965 tax liabilities with respect to an S corporation.
Form 965-E, Consent Agreement Under Section 965(i)(4)(D).
                                                                       Definitions
  Although these forms were not released in time for reporting 
for 2019 tax years, the instructions for these new forms contain       Deferred foreign income corporation (DFIC).  A DFIC is, with 
information that may be useful to filers of Form 965-A. As such,       respect to any U.S. shareholder, any specified foreign 
references to these new instructions have been added                   corporation (as defined under section 965(e)) of a U.S. 
throughout the instructions for Form 965-A.                            shareholder that has accumulated post-1986 deferred foreign 
                                                                       income (as defined under section 965(d)(2)) as of November 2, 
Background                                                             2017, or December 31, 2017, that is greater than zero.
On December 22, 2017, section 965 of the Code was amended.             U.S. shareholder.     For tax years of foreign corporations 
As a result of the amendment, certain taxpayers are required to        beginning before January 1, 2018, a U.S. shareholder is a U.S. 
include in income an amount (a section 965(a) inclusion amount)        person who owns (directly, indirectly, or constructively) 10% or 
based on the accumulated post-1986 deferred foreign income of          more of the total combined voting power of all classes of stock of 
certain foreign corporations (specified foreign corporations) that     a foreign corporation. A U.S. person for this purpose is defined 
are deferred foreign income corporations (DFICs) that they own         in section 957(c) of the Code.
either directly or indirectly through other entities. Other taxpayers 
may have inclusions in income under section 951(a) by reason           Net income tax liability.  The taxpayer’s regular income tax 
of section 965 due to ownership of DFICs through domestic              liability reduced by the credits allowed under subparts A, B, and 
pass-through entities that are U.S. shareholders of the DFICs.         D of part IV of subchapter A (generally non-refundable credits).
When referring to both amounts in the preceding two sentences,         Net 965 tax liability.  The excess of the taxpayer’s net income 
these instructions use the term “section 965(a) inclusion.”            tax liability computed with all section 965 amounts included 
Section 965 also allows for a deduction (section 965(c)                (“with calculation”) over the taxpayer’s net income tax liability 
deduction). Section 965(a) inclusions and corresponding section        without regard to section 965 (“without calculation”). See 
965(c) deductions are taken into account based on the last tax         Regulations section 1.965-7(g)(10) for rules for computing the 
year of the DFIC that begins before January 1, 2018.                   net 965 tax liability.
  Certain taxpayers may make certain elections with respect to         S corporation-related net 965 tax liability. With respect to an 
section 965. Relevant to this form, these elections include: (i) an    S corporation, the excess of the taxpayer’s net income tax 
election to pay a net 965 tax liability over 8 years, and (ii) an      liability computed with all section 965 amounts included (which, 
election by S corporation shareholders to defer payment of a net       in this case, includes only section 965 amounts allocated from 
965 tax liability with respect to an S corporation until a triggering  such S corporation with respect to DFICs of which such S 
event. In the case of the deferral election by S corporation           corporation is a U.S. shareholder) (“with calculation”) over the 
shareholders, the deferred amounts are subject to annual               taxpayer’s net income tax liability without regard to section 965 
reporting requirements, and when a triggering event occurs, the        (“without calculation”).
S corporation shareholder may then (subject to certain 
limitations) elect to pay the amount of the net 965 tax liability that Reporting year. The tax year of the return with which this form 
is no longer subject to deferral over 8 years.                         is being filed.

                                                                       Who Must File
General Instructions                                                   Any individual taxpayer (or taxpayer taxed like an individual) who 
                                                                       has a net 965 tax liability for any tax year or has any net 965 tax 
Purpose of Form                                                        liability remaining unpaid at any time during a tax year must file 
This form should be used by individual taxpayers and entities          this form.
taxed like individuals (for example, certain trusts and estates). 
This form is used to report a taxpayer’s net 965 tax liability for 
each tax year in which a taxpayer must report or pay section 965 
amounts. In addition, this form is used to report the 

Jan 25, 2020                                                 Cat. No. 71280E



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                                                                            a line in Part I the tax year of the net 965 tax liability for which the 
When and Where To File                                                      installment payment liability is being assumed in column (a); the 
File Form 965-A with the income tax return of the taxpayer for              $60 amount of the transfer as a positive number in column (j); 
the reporting year by the due date (taking into account                     and the tax identification number of Transferor in column (k). In 
extensions, if any) of the return.                                          addition, on the corresponding line in Part II, Taxpayer would 
                                                                            report the $15 installment payment made in column (g), Paid for 
Electronic Filing of Form 965-A                                             Year 6 (the installment year as if Taxpayer were paying as 
If you file your income tax return electronically, Form 965-A is            Transferor). In the next reporting year, Taxpayer would report all 
filed with the electronic income tax return. See the instructions           the same information in Part II, plus the payment of $20 (20% of 
for your income tax return for general information about                    the original $100 liability) in column (h), Paid for Year 7. In the 
electronic filing.                                                          following reporting year, Taxpayer would report all the same 
                                                                            information as in year 7, plus the final payment of $25 (25% of 
                                                                            the original $100 liability) in column (i), Paid for Year 8.
Specific Instructions                                                       Triggered deferred S corporation-related net 965 tax 
                                                                            liability. Deferred S corporation-related net 965 tax liabilities 
Amended Report                                                              become subject to payment when a triggering event occurs. 
Check the amended report box at the top of page 1 of the form if            (See instructions for Part III and Part IV for information 
Form 965-A is filed with an amended return that is filed to                 concerning the computation, reporting, deferral election, and 
change any reporting related to section 965, regardless of                  triggering events for S corporation-related net 965 tax liabilities.) 
whether a Form 965-A has previously been filed.                             When such a deferred liability is triggered, it must be transferred 
                                                                            from Part IV, where it is annually reported, to Part I, column (f). 
Part I – Report of Net 965 Tax Liability                                    Such a triggered S corporation-related net 965 tax liability is 
                                                                            generally eligible for an election to be paid in 8 installments 
and Election to Pay in Installments                                         beginning in the year of the triggering event. In the case of a 
Lines 1 through 8. Report in Part I net 965 tax liability amounts           triggering event with respect to a deferred S corporation-related 
as follows.                                                                 net 965 tax liability, complete one of lines 4 through 8 as follows: 
                                                                            In column (a), report the tax year in which the triggering event 
  On lines 1 and 2, you must continue to report 2017 and/or                 occurred. Skip columns (b) through (e) and report the triggered 
2018 amounts for all columns, including the original computation            liability in column (f). Report in column (g) whether the taxpayer 
of net 965 tax liability reported in columns (b) through (i) on a           elected to pay the triggered liability in 8 installments by entering 
prior-year Form 965-A. Report in column (j) any current-year net            “Yes” or “No.”
965 tax liability transferred out (that is, for which you filed a valid 
transfer agreement as the transferor) or any current tax year                         For certain triggered net 965 tax liabilities, the taxpayer 
subsequent adjustments. Also complete column (k), if                          !       may elect to pay in installments only with consent of the 
applicable.                                                                 CAUTION   Secretary. (See instructions for Form 965-E for more 
  For 2019 tax years, use line 3 to report section 965(a)                   details.) Without consent, the taxpayer must enter a checkmark 
inclusions derived solely through interests in pass-through                 in the “No” column of column (g) and enter the amount of the 
entities that are U.S. shareholders of DFICs.                               triggered liability in column (h).
  Use lines 4 through 8 to report other amounts of net 965 tax              If the taxpayer does not (or cannot) elect to pay the triggered 
liability of the taxpayer, such as:                                         deferred net 965 tax liability in installments, then report the 
Installment liability transfers in. The taxpayer may, in                  amount from column (f) in column (h). This should equal the 
certain circumstances, and by agreement with the Secretary,                 payment reported in the corresponding line of Part II, column (b), 
assume as transferee the installment payment liability for the              Paid for Year 1.
transferor's remaining net 965 tax liability and pay it in the same         If the taxpayer elects to pay the triggered liability in 
manner as if the taxpayer were the transferor. (See instructions            installments, skip column (h) and report the amount from column 
for Form 965-C for more details.) If this occurs, the transferee            (f) in column (i). The corresponding line in Part II, column (b), 
should complete one of lines 4 through 8 in Part I as follows:              Paid for Year 1, should report an 8% payment of the amount 
In column (a), enter the tax year of the net 965 tax liability for        elected to be paid in installments. The remaining payments 
which the installment payment liability is being assumed. For               should generally be reported in subsequent reporting years 
example, if a net 965 tax liability incurred in tax year 2017 (with         according to the installment schedule. (See instructions for Part 
respect to which an installment payment election was made)                  II, line 1, for the general installment schedule.)
was transferred to a transferee in 2022, in 2022 the taxpayer               If lines 4 through 8 do not provide adequate lines to report all 
(transferee) reports “2017” in column (a).                                  the taxpayer’s transactions described above, an additional Form 
Skip columns (b) through (i).                                             965-A should be used.
In column (j), report, as a positive number, the remaining 
installment payment liability (that is, original liability less             Note. Even if a net 965 tax liability was reported on a taxpayer’s 
payments made by the transferor) assumed by the taxpayer as                 income tax return and fully paid, because no elections were 
transferee.                                                                 made, the taxpayer must complete the appropriate line in Part I 
In column (k), report the tax identification number of the                and report the related payment on the corresponding line in Part 
transferor.                                                                 II, column (b).
Payments of such liability would then be reported on the                  Note. If an installment election under section 965(h) or a 
corresponding line of Part II in the same manner as if the                  deferral election under section 965(i) was made, then the 
taxpayer were the transferor.                                               taxpayer must complete the appropriate line in Part I, as well as 
  For example, assume Transferor had an original net 965 tax                the corresponding line in Parts II through IV, as applicable, to 
liability of $100 in year 1, when an installment payment election           report the status of the net 965 tax liability and any related 
was made. In years 1 through 5, Transferor reports payments of              adjustments for the reporting year.
five 8% installments. Then, in year 6, the liability to pay the 
remaining installments (15%, 20%, and 25%) totaling $60 is 
transferred to Taxpayer as transferee. Taxpayer would report on 

                                                                        -2-                 Instructions for Form 965-A (Rev. 01-2020)



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Column (b). Report the taxpayer’s net income tax liability for             intentional disregard, or fraud on the part of TP. This adjustment 
the tax year reported in column (a), with all section 965 amounts          would be prorated to all the installments. TP would report the 
included (“with calculation”).                                             $50 adjustment in Part I, line 1, column (j), as a positive number, 
                                                                           so the reported adjusted liability would be $150. In addition, TP 
Column (c). Report the taxpayer’s net income tax liability for             would pay and report (in addition to the original $8 installment 
the tax year reported in column (a), without regard to section 965         reported for year 5) $20 on Part II, line 1, column (f), 
(“without calculation”).                                                   representing 8% of the adjustment prorated to each of years 1 
Column (d). Report the excess of the taxpayer’s “with                      through 5, for which the installment due date had already 
calculation” reported in column (b) over the “without calculation”         arrived. For year 6, TP would pay and report $22.50 (15% of the 
reported in column (c). This is the taxpayer’s net 965 tax liability       adjusted $150 liability); for year 7, $30 (20% of the adjusted 
for the tax year reported in column (a).                                   $150 liability); and for year 8, $37.50 (25% of the adjusted $150 
                                                                           liability).
Column (e). If the taxpayer is a shareholder in one or more S 
corporation(s) with section 965 amounts, report the total of                 In a case in which a net 965 tax liability for a tax year is both 
column (g) from Part III for the tax year reported in column (a).          adjusted and transferred, report the net adjustment/transfer 
This is the total S corporation-related net 965 tax liability the          number in column (j), a transferee tax identification number in 
taxpayer elected to defer. See detailed instructions for Part III          column (k), and provide a statement, attached to this form, which 
regarding the S corporation-by-S corporation calculations and              includes details of the amounts netted in column (j).
elections.
                                                                           Part II – Record of Amount of Net 965 
Column (f). Report the amount in column (d), less the amount 
in column (e), if any. This is the taxpayer’s net 965 tax liability        Tax Liability Paid by the Taxpayer
eligible for the installment payment election.                             Part II is intended to be a cumulative record of the actual 
                                                                           payments the taxpayer has made with respect to the net 965 tax 
Column (g). If the taxpayer made an election to pay a net 965              liabilities reported in Part I.
tax liability in installments over 8 years as provided for in section 
965(h) and in the manner described in Regulations section                  Line 1.    This line records the actual payments with respect to the 
1.965-7(b)(2), enter a check mark in the “Yes” column. If “Yes,”           net 965 tax liability reported on line 1 of Part I for the tax year 
skip column (h) and enter the amount from column (f) in column             2017.
(i). Otherwise, enter a check mark in the “No” column. If “No,”              The general installment payment schedule for a net 965 tax 
enter the amount from column (f) in column (h) and skip column             liability subject to an election to pay in installments is:
(i).                                                                         1. 8% of the net 965 tax liability payable in year 1 (the year 
        The actual payment of the first installment is due no later        of the section 965(a) inclusion or triggering event with respect to 
  !     than the due date of the return for the tax year without           a deferred S corporation-related net 965 tax liability),
CAUTION extension, even if the election is made on a return filed            2. 8% of the net 965 tax liability payable in year 2,
by the extended due date.
                                                                             3. 8% of the net 965 tax liability payable in year 3,
Column (j). Report the following in column (j):                              4. 8% of the net 965 tax liability payable in year 4,
Report, as a negative number, any net 965 tax liability for the            5. 8% of the net 965 tax liability payable in year 5,
year reported in column (a) that has been transferred out to a 
                                                                             6. 15% of the net 965 tax liability payable in year 6,
transferee, by agreement with the Secretary, under which the 
transferee becomes liable for the remaining installments due on              7. 20% of the net 965 tax liability payable in year 7, and
the liability in the same manner as if such transferee were the              8. 25% of the net 965 tax liability payable in year 8.
taxpayer. (See instructions for Form 965-C for more details.) In             If, for any reason, the actual payment differs from the 
addition, provide the tax identification number of the transferee          schedule, report the actual payment made.
in column (k). For example, if the taxpayer (transferor) incurred a 
net 965 tax liability in tax year 2017, for which an installment             Example.    If the reporting year is 2019 and the taxpayer is 
payment election was made, then properly transferred the                   reporting a 2017 net 965 tax liability for which an installment 
liability net of payments previously made, to a transferee in              payment election was made, because the 2019 reporting year is 
2022, the taxpayer (transferor) would report, on line 1, column            “Year 3” with respect to a 2017 net 965 tax liability being paid in 
(j), as a negative number, the amount of the net liability                 installments, installment payments reported in Part II on line 1, 
transferred out. The making and reporting of payments on such              the line for 2017, should generally be:
liability should generally cease (see instructions for Part II, later).    In column (b), Paid for Year 1, report 8% of the 2017 net 965 
Report any transfer in of a net 965 tax installment payment              tax liability;
liability from a seller/transferor by a transferee (see the                In column (c), Paid for Year 2, report 8% of the 2017 net 965 
instructions for lines 1 through 8, earlier).                              tax liability; and
Report subsequent adjustments to the net 965 tax liability for           In column (d), Paid for Year 3, report 8% of the 2017 net 965 
the tax year reported in column (a) for which no amended return            tax liability.
was required to be filed, such as an audit adjustment. A liability 
increase should be reported as a positive number and a                     Column (a).   Report the tax year of the section 965(a) inclusion, 
decrease as a negative number.                                             the net 965 tax liability for which an installment payment liability 
                                                                           is being assumed, or triggering event with respect to a deferred 
Note. An adjustment of a net 965 tax liability elected to be paid          S corporation-related net 965 tax liability, as reported on the 
in installments is generally prorated to all installments.                 corresponding line of Part I, column (a).
  For example, for tax year 2017, a taxpayer (TP) reported a               Columns (b) through (i).       These columns are used to record 
$100 net 965 tax liability for which an installment election was           the taxpayer’s cumulative payments, made each reporting year, 
made. For each of years 1 through 5, TP pays and reports an $8             for the net 965 tax liability reported on the corresponding line in 
installment. Also, in year 5, an audit adjustment increases the            Part I.
2017 net 965 tax liability to $150, a $50 positive adjustment. No            If no installment election is made, the net 965 tax liability 
amended return was required and there was no negligence,                   reported in Part I, column (h), should be paid and reported on 

Instructions for Form 965-A (Rev. 01-2020)                              -3-



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the corresponding line of Part II, column (b), Paid for Year 1, and          with respect to S corporations. For each S corporation-related 
the remaining payment columns (c) through (i) left blank.                    net 965 tax liability, the taxpayer may elect to defer payment of 
If an installment election is made, and no transfers,                        such liability until a triggering event occurs. (See instructions for 
acceleration events, or adjustments occur during the 8-year                  Part IV for more information on triggering events.) Each S 
installment period, then 8% of the net 965 tax liability should be           corporation-related net 965 tax liability is calculated on an 
paid and reported in column (b), Paid for Year 1 (the year of the            individual S corporation basis, and an election to defer such 
installment payment election). In the next reporting year, the               liability is also made on an individual S corporation basis. Such 
relevant information from the prior reporting year should be                 liabilities deferred, if any, must be totaled by tax year, and the 
carried forward, plus 8% of the net 965 tax liability should be              total carried to Part I, column (e), of the respective tax year line.
paid and reported in column (c), Paid for Year 2. In future                  Lines 1 through 3. Report S corporation-related net 965 tax 
reporting years, the payments and payment reporting should                   liabilities for the tax year indicated. On lines 1 and 2, you must 
continue similarly in accordance with the general installment                continue to report 2017 and/or 2018 amounts for all columns, 
payment schedule described above.                                            even though they were reported on a prior-year Form 965-A. 
If the taxpayer transfers out a net 965 tax liability, then the              Space is provided for reporting net 965 tax liabilities related to 
making and reporting of installment payments should generally                up to five S corporations. If additional lines are needed for the 
cease for the transferred net 965 tax liability in the year of               tax year, use additional Forms 965-A.
transfer; however, reporting with respect to the net 965 tax                 Column (a). Report the name of the S corporation from which 
liability is still required for the reporting year if any net 965 tax        the taxpayer is allocated section 965 amounts. Abbreviate as 
liability of the taxpayer remains unpaid at any time during the              needed.
reporting year.
If an acceleration event occurs, then the unpaid portion of all              Column (b). Report the tax identification number of the S 
remaining installments is due on the date of the acceleration                corporation reported in column (a). The tax identification number 
event and should be paid and reported in the column for the year             of an S corporation is its employer identification number (EIN).
in which the acceleration event occurs; however, reporting with              Column (c). Report the taxpayer’s net income tax for the tax 
respect to the net 965 tax liability is still required for the reporting     year calculated only with section 965 amounts allocated from 
year if any net 965 tax liability of the taxpayer remains unpaid at          this S corporation with respect to DFICs of which the S 
any time during the reporting year.                                          corporation is a U.S. shareholder. This is the S 
If an adjustment occurs to a net 965 tax liability for which an              corporation-related “with calculation.”
installment election has been made, including on an amended                  Column (d). Report the taxpayer’s net income tax for the tax 
return, the adjustment should generally be prorated over all the             year calculated without regard to section 965, that is, the 
installment payments. For the part of the adjustment prorated to             “without calculation.” This should equal the taxpayer’s net tax 
installments whose payment date has already arrived, adjust the              liability without section 965 amounts for the corresponding tax 
payment for the reporting year in which the adjustment is made               year reported in Part I, column (c).
and report accordingly. For the part of the adjustment prorated to 
installments for which the payment date has not yet arrived, pay             Column (e). Report the excess of the taxpayer’s S 
and report in accordance with the installment schedule.                      corporation-related “with calculation” reported in column (c) over 
                                                                             the “without calculation” reported in column (d). This is the 
Payments should include both actual installment payments                     taxpayer’s S corporation-related net 965 tax liability with respect 
made and excess payments of other income tax liabilities                     to this S corporation for the tax year.
applied to the taxpayer’s net 965 tax liability.
                                                                             Column (f). If the taxpayer made an election to defer payment 
Column (j). Report the net 965 tax liability remaining unpaid                of this S corporation-related net 965 tax liability as provided for in 
after the payment for the reporting year. This amount should                 section 965(i) and in the manner described in Regulations 
equal the amount reported on the corresponding line in Part I,               section 1.965-7(c)(2), enter a check mark in the “Yes” column. 
column (f), or column (i), as applicable, plus or minus any                  Otherwise, enter a check mark in the "No" column.
amount reported on the corresponding line in Part I, column (j), 
less any payments reported in Part II, columns (b) through (i).              Column (g). If the taxpayer elected to defer an S 
                                                                             corporation-related net 965 tax liability, enter the amount from 
Column (k). For each line, report only the payment made (if                  column (e). (If the election was not made, then the liability 
any) for the reporting year.                                                 remains a part of the taxpayer’s total net 965 tax liability subject 
Current-year reporting of column (k) amounts:                                to an installment payment election.) The total of column (g) for a 
Individuals: For tax year 2019, enter the amount from Form                   tax year represents the taxpayer’s total deferred S 
965-A, Part II, column (k), line 3, on Schedule 2 (Form 1040 or              corporation-related net 965 tax liability for the tax year and 
1040-SR), line 9.                                                            should be entered on the corresponding tax year line in Part I, 
All others: For all other filers (that is, other taxpayers taxed like        column (e).
an individual), follow the form instructions for that other 
applicable return.                                                           Part IV – Annual Report of Deferred 
Part III – S Corporation Shareholder:                                        Net 965 Tax Liability Related to 965 
Report of Calculation of Net 965 Tax                                         Amounts Allocated from S 
Liability Related to 965 Amounts                                             Corporations
                                                                             Any shareholder of an S corporation that makes an election to 
Allocated from an S Corporation and                                          defer payment of an S corporation-related net 965 tax liability 
Election To Defer Such Net 965 Tax                                           must report such liability with their income tax return for the year 
                                                                             of election and every year thereafter through the year in which 
Liability                                                                    such amount is fully paid. Part IV provides for the required 
This Part allows a taxpayer that is an S corporation shareholder             annual reporting of deferred S corporation-related net 965 tax 
to report net 965 tax liabilities related to section 965 amounts             liabilities and any adjustments related to such deferred liabilities 
                                                                             during the reporting year.

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        If the taxpayer fails to report for any year information          liability, the transfer is not treated as a triggering event if the 
  !     required to be reported under section 965(i)(7) by the            transferee, by agreement with the Secretary, becomes liable for 
CAUTION due date of the return for such year, 5% of the deferred          the deferred S corporation-related net 965 tax liability in the 
net 965 tax liability shall be assessed as an addition to tax for         same manner as the transferor. (See instructions for Form 965-D 
such reporting year.                                                      for more details.)
                                                                          Report the amount of the transfer out as a negative number in 
Column (a). Report the year of:                                           column (g) of the same line as the taxpayer reported the 
Deferral election. In a year for which an election is made to           deferred S corporation-related net 965 tax liability at the 
defer an S corporation-related net 965 tax liability, any amounts         beginning of the reporting year.
elected to be deferred must be transferred from Part III, column 
(g), to the corresponding line in Part IV, column (d). Enter the          In a case of multiple transferees, report the total deferred S 
year for which the election is made in column (a) of the                  corporation-related net 965 tax liability transferred as a negative 
corresponding line.                                                       number in column (g) and in column (h) report the tax 
Transfer in. In certain circumstances, by agreement with the            identification number of a transferee and attach a schedule to 
Secretary, a taxpayer may assume a deferred S                             Form 965-A providing a breakdown of the total deferred S 
corporation-related net 965 tax liability from another taxpayer           corporation-related net 965 tax liability transferred and the 
who had elected to defer such amount. The transferee is liable            associated tax identification numbers of each transferee.
for the deferred S corporation-related net 965 tax liability in the       Transfers in. A taxpayer may assume, by agreement with the 
same manner as the transferor, including being subject to                 Secretary, a deferred 965 net tax liability as a buyer/transferee of 
annual reporting requirements. (See instructions for Form 965-D           S corporation stock with respect to which the transferor has a 
for more details.) Enter the tax year of transfer in column (a). See      deferred S corporation-related net 965 tax liability. The taxpayer 
the instructions for Part IV, column (g), later, for reporting the        will then be liable for the deferred S corporation-related net 965 
amount of the transfer in.                                                tax liability in the same manner as the transferee, including being 
Column (b). Report the name of the S corporation to which the             subject to annual reporting requirements, beginning for the tax 
deferred net 965 tax liability relates. Abbreviate as needed.             year of transfer. (See instructions for Form 965-D for more 
                                                                          details.) For the year of transfer, a new line in Part IV must be 
Column (c). Report the tax identification number of the S                 completed, skipping columns (d), (e), and (f), and entering in 
corporation reported in column (b). The tax identification number         both columns (g) and (i) the deferred S corporation-related net 
of an S corporation is its employer identification number (EIN).          965 tax liability transferred in as a positive number.
Column (d). Report the beginning deferred S                               For reporting years following the year of transfer, report the 
corporation-related net 965 tax liability.                                transferred deferred S corporation-related net 965 tax liability in 
For the year of the deferral election, this amount will be the S        the same fashion as all other deferred S corporation-related net 
corporation-related net 965 tax liability for which the taxpayer          965 tax liabilities.
elects to defer payment and should be transferred from the                Column (h). Provide the tax identification number of the 
corresponding line for such S corporation in Part III, column (g).        transferee or transferor.
For subsequent reporting years, the amount reported should 
equal the amount on the corresponding line in column (i) from             Column (i). For each line, combine the amounts reported in 
Part IV of Form 965-A for the prior reporting year.                       columns (d) through (g).
For assumptions of deferred S corporation-related net 965 tax 
liabilities, by agreement with the Secretary, the amount reported 
should equal the amount of S corporation-related net 965 tax              Paperwork Reduction Act Notice
liability assumed by the taxpayer.                                        We ask for the information on this form to carry out the Internal 
                                                                          Revenue laws of the United States. You are required to give us 
Column (e). Reserved for future use.                                      the information. We need it to ensure that you are complying 
Column (f). Report the amount of each deferred S                          with these laws and to allow us to figure and collect the right 
corporation-related net 965 tax liability, payment of which               amount of tax.
ceases to be deferred as a result of a triggering event during the 
reporting year (“triggered S corporation-related net 965 tax              You are not required to provide the information requested on 
liability”). The triggered S corporation-related net 965 tax liability    a form that is subject to the Paperwork Reduction Act unless the 
amount should be reported in column (f) as a negative number              form displays a valid OMB control number. Books or records 
and transferred to column (f) on one of lines 4 through 8 in Part I       relating to a form or its instructions must be retained as long as 
as a positive number. See Triggered deferred S                            their contents may become material in the administration of any 
corporation-related net 965 tax liability, in the instructions for        Internal Revenue law. Generally, tax returns and return 
Part I, lines 1 through 8, earlier.                                       information are confidential, as required by section 6103.
Column (g). Report the amount of deferred S                               The time needed to complete and file this form will vary 
corporation-related net 965 tax liability transferred out or in.          depending on individual circumstances. The estimated burden 
Transfers (out). When a taxpayer transfers stock of an S                  for individual taxpayers filing this form is approved under OMB 
corporation with respect to which the taxpayer has made an                control number 1545-0074 and is included in the estimates 
election to defer payment of its S corporation-related net 965 tax        shown in the instructions for their individual income tax return.

Instructions for Form 965-A (Rev. 01-2020)                             -5-






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