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Hướng dẫn Mẫu 965-A

Hướng dẫn cho Mẫu 965-A (Rev. Tháng 1 năm 2021)

Hướng dẫn về Mẫu 965-A, Báo cáo Cá nhân về Trách nhiệm Thuế 965

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Department of the Treasury  
Internal Revenue Service  
Instructions for Form 965-A  
Individual Report of Net 965 Tax Liability  
(Rev. January 2021)  
Section references are to the Internal Revenue Code unless  
otherwise noted.  
Certain taxpayers may make certain elections with respect to  
section 965. Relevant to this form, these elections include: (i) an  
election to pay a net 965 tax liability over 8 years, and (ii) an  
election by S corporation shareholders to defer payment of a net  
965 tax liability with respect to an S corporation until a triggering  
event. In the case of the deferral election by S corporation  
shareholders, the deferred amounts are subject to annual  
reporting requirements, and when a triggering event occurs, the  
S corporation shareholder may then (subject to certain  
limitations) elect to pay the amount of the net 965 tax liability that  
is no longer subject to deferral over 8 years.  
Future Developments  
For the latest information about developments related to Form  
965-A and its instructions, such as legislation enacted after they  
were published, go to IRS.gov/Form965A.  
What’s New  
In Parts I, II, and III of the form, line 4 is now designated for use  
for 2020 reporting.  
General Instructions  
Changes to the carryback of net operating losses. The  
Coronavirus Aid, Relief, and Economic Security Act (CARES  
Act) added section 172(b)(1)(D)(i), which provides for a  
carryback of any net operating loss (NOL) arising in a taxable  
year beginning after December 31, 2017, and before January 1,  
2021, to each of the five taxable years preceding the taxable  
year in which the loss arises, including those years in which a  
taxpayer had a section 965(a) inclusion (section 965 years). A  
taxpayer applying for a tentative refund resulting from the  
carryback of an NOL to a section 965 year must include with the  
Form 1045 an amended Form 965-A to record the amount of the  
change in the section 965 net tax liability, if any, caused by the  
NOL carryback, and a statement of explanation to explain the  
change in the section 965 net tax liability. See Rev. Proc.  
2020-24, 2020-18 I.R.B. 750, and Frequently asked questions  
965 inclusions for additional information regarding the  
consequences of carrying back an NOL to a section 965 year,  
including limitations on refunds for taxpayers that carry back  
NOLs to section 965 years.  
Purpose of Form  
This form should be used by individual taxpayers and entities  
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  
determination of a taxpayer’s net 965 tax liability, whether or not  
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  
taxpayer that has been assumed by another taxpayer or any net  
965 tax liability that the taxpayer has assumed; an S corporation  
shareholder’s net 965 tax liability with respect to an S  
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  
summary, this form is intended to be a cumulative report of a  
taxpayer’s net 965 tax liabilities through payment in full. This  
form must be completed by a taxpayer for every tax year for  
which the taxpayer has any net 965 tax liability outstanding and  
not fully paid at any point during the tax year, including deferred  
net 965 tax liabilities with respect to an S corporation.  
Reminders  
The IRS has developed the following forms:  
Form 965-C, Transfer Agreement Under Section 965(h)(3).  
Form 965-D, Transfer Agreement Under Section 965(i)(2).  
Form 965-E, Consent Agreement Under Section 965(i)(4)(D).  
Definitions  
Deferred foreign income corporation (DFIC). A DFIC is, with  
respect to any U.S. shareholder, any specified foreign  
corporation (as defined under section 965(e)) of a U.S.  
shareholder that has accumulated post-1986 deferred foreign  
income (as defined under section 965(d)(2)) as of November 2,  
2017, or December 31, 2017, that is greater than zero.  
The instructions for these forms contain information that may  
be useful to filers of Form 965-A. As such, references to these  
instructions have been added throughout the instructions for  
Form 965-A.  
Background  
U.S. shareholder. For tax years of foreign corporations  
beginning before January 1, 2018, a U.S. shareholder is a U.S.  
person who owns (directly, indirectly, or constructively) 10% or  
more of the total combined voting power of all classes of stock of  
a foreign corporation. A U.S. person for this purpose is defined  
in section 957(c) of the Code.  
On December 22, 2017, section 965 of the Code was amended.  
As a result of the amendment, certain taxpayers are required to  
include in income an amount (a section 965(a) inclusion amount)  
based on the accumulated post-1986 deferred foreign income of  
certain foreign corporations (specified foreign corporations) that  
are deferred foreign income corporations (DFICs) that they own  
either directly or indirectly through other entities. Other taxpayers  
may have inclusions in income under section 951(a) by reason  
of section 965 due to ownership of DFICs through domestic  
pass-through entities that are U.S. shareholders of the DFICs.  
When referring to both amounts in the preceding two sentences,  
these instructions use the term “section 965(a) inclusion.”  
Section 965 also allows for a deduction (section 965(c)  
Net income tax liability. The taxpayer’s regular income tax  
liability reduced by the credits allowed under subparts A, B, and  
D of part IV of subchapter A (generally non-refundable credits;  
specifically, those credits allowed under sections 21 through  
30D and sections 38 through 45T).  
Net 965 tax liability. The excess of the taxpayer’s net income  
tax liability computed with all section 965 amounts included  
(“with calculation”) over the taxpayer’s net income tax liability  
without regard to section 965 (“without calculation”). See  
deduction). Section 965(a) inclusions and corresponding section  
965(c) deductions are taken into account based on the last tax  
year of the DFIC that begins before January 1, 2018.  
Dec 15, 2020  
Cat. No. 71280E  
Regulations section 1.965-7(g)(10) for rules for computing the  
net 965 tax liability.  
for Form 965-C for more details.) If this occurs, the transferee  
should complete one of lines 5 through 8 in Part I as follows:  
In column (a), enter the tax year of the net 965 tax liability for  
S corporation-related net 965 tax liability. With respect to an  
S corporation, the excess of the taxpayer’s net income tax  
liability computed with all section 965 amounts included (which,  
in this case, includes only section 965 amounts allocated from  
such S corporation with respect to DFICs of which such S  
corporation is a U.S. shareholder) (“with calculation”) over the  
taxpayer’s net income tax liability without regard to section 965  
(“without calculation”).  
which the installment payment liability is being assumed. For  
example, if a net 965 tax liability incurred in tax year 2017 (with  
respect to which an installment payment election was made)  
was transferred to a transferee in 2022, in 2022 the taxpayer  
(transferee) reports “2017” in column (a).  
Skip columns (b) through (i).  
In column (j), report, as a positive number, the remaining  
installment payment liability (that is, original liability less  
payments made by the transferor) assumed by the taxpayer as  
transferee.  
Reporting year. The tax year of the return with which this form  
is being filed.  
In column (k), report the tax identification number of the  
Who Must File  
transferor.  
Payments of such liability would then be reported on the  
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  
liability remaining unpaid at any time during a tax year must file  
this form.  
corresponding line of Part II in the same manner as if the  
taxpayer were the transferor.  
For example, assume Transferor had an original net 965 tax  
liability of $100 in year 1, when an installment payment election  
was made. In years 1 through 5, Transferor reports payments of  
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  
a line in Part I the tax year of the net 965 tax liability for which the  
installment payment liability is being assumed in column (a); the  
$60 amount of the transfer as a positive number in column (j);  
and the tax identification number of Transferor in column (k). In  
addition, on the corresponding line in Part II, Taxpayer would  
report the $15 installment payment made in column (g), Paid for  
Year 6 (the installment year as if Taxpayer were paying as  
Transferor). In the next reporting year, Taxpayer would report all  
the same information in Part II, plus the payment of $20 (20% of  
the original $100 liability) in column (h), Paid for Year 7. In the  
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.  
When and Where To File  
File Form 965-A with the income tax return of the taxpayer for  
the reporting year by the due date (taking into account  
extensions, if any) of the return.  
Electronic Filing of Form 965-A  
If you file your income tax return electronically, Form 965-A is  
filed with the electronic income tax return. See the instructions  
for your income tax return for general information about  
electronic filing.  
Specific Instructions  
Amended Report  
Check the amended report box at the top of page 1 of the form if  
Form 965-A is filed with an amended return that is filed to  
change any reporting related to section 965, regardless of  
whether a Form 965-A has previously been filed. The amended  
return box must also be checked for any amended Form 965-A  
filed with a Form 1045 applying for a tentative refund resulting  
from the carryback of an NOL to a section 965 year pursuant to  
section 172(b)(1)(D)(i).  
Triggered deferred S corporation-related net 965 tax  
liability. Deferred S corporation-related net 965 tax liabilities  
become subject to payment when a triggering event occurs.  
(See instructions for Part III and Part IV for information  
concerning the computation, reporting, deferral election, and  
triggering events for S corporation-related net 965 tax liabilities.)  
When such a deferred liability is triggered, it must be transferred  
from Part IV, where it is annually reported, to Part I, column (f).  
Such a triggered S corporation-related net 965 tax liability is  
generally eligible for an election to be paid in 8 installments  
beginning in the year of the triggering event. In the case of a  
triggering event with respect to a deferred S corporation-related  
net 965 tax liability, complete one of lines 5 through 8 as follows:  
In column (a), report the tax year in which the triggering event  
occurred. Skip columns (b) through (e) and report the triggered  
liability in column (f). Report in column (g) whether the taxpayer  
elected to pay the triggered liability in 8 installments by entering  
“Yes” or “No.”  
Part I – Report of Net 965 Tax Liability  
and Election to Pay in Installments  
Lines 1 through 8. Report in Part I net 965 tax liability amounts  
as follows.  
On lines 1, 2 and 3, you must continue to report 2017, 2018,  
and/or 2019 amounts for all columns, including the original  
computation of net 965 tax liability reported in columns (b)  
through (i) on a prior-year Form 965-A. Report in column (j) any  
current-year net 965 tax liability transferred out (that is, for which  
you filed a valid transfer agreement as the transferor) or any  
current tax year subsequent adjustments. Also, complete  
column (k), if applicable.  
For certain triggered net 965 tax liabilities, the taxpayer  
may elect to pay in installments only with consent of the  
!
CAUTION  
Secretary. (See instructions for Form 965-E for more  
For 2020 tax years, use line 4 to report section 965(a)  
inclusions derived solely through interests in pass-through  
entities that are U.S. shareholders of DFICs.  
details.) Without consent, the taxpayer must enter a checkmark  
in the “No” column of column (g) and enter the amount of the  
triggered liability in column (h).  
Use lines 5 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  
amount from column (f) in column (h). This should equal the  
payment reported in the corresponding line of Part II, column (b),  
Paid for Year 1.  
Installment liability transfers in. The taxpayer may, in  
certain circumstances, and by agreement with the Secretary,  
assume as transferee the installment payment liability for the  
transferor's remaining net 965 tax liability and pay it in the same  
manner as if the taxpayer were the transferor. (See instructions  
If the taxpayer elects to pay the triggered liability in  
installments, skip column (h) and report the amount from column  
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Instructions for Form 965-A (Rev. 01-2021)  
 
(f) in column (i). The corresponding line in Part II, column (b),  
Paid for Year 1, should report an 8% payment of the amount  
elected to be paid in installments. The remaining payments  
should generally be reported in subsequent reporting years  
according to the installment schedule. (See instructions for Part  
II, line 1, for the general installment schedule.)  
liability net of payments previously made, to a transferee in  
2022, the taxpayer (transferor) would report, on line 1, column  
(j), as a negative number, the amount of the net liability  
transferred out. The making and reporting of payments on such  
liability should generally cease (see instructions for Part II, later).  
Report any transfer in of a net 965 tax installment payment  
If lines 5 through 8 do not provide adequate lines to report all  
liability from a seller/transferor by a transferee (see the  
the taxpayer’s transactions described above, an additional Form  
965-A should be used.  
instructions for Lines 1 through 8, earlier).  
Report subsequent adjustments to the net 965 tax liability for  
the tax year reported in column (a) for which no amended return  
was required to be filed, such as an audit adjustment. A liability  
increase should be reported as a positive number and a  
decrease as a negative number.  
Note. Even if a net 965 tax liability was reported on a taxpayer’s  
income tax return and fully paid, because no elections were  
made, the taxpayer must complete the appropriate line in Part I  
and report the related payment on the corresponding line in Part  
II, column (b).  
Note. An adjustment of a net 965 tax liability elected to be paid  
in installments is generally prorated to all installments.  
Note. If an installment election under section 965(h) or a  
deferral election under section 965(i) was made, then the  
taxpayer must complete the appropriate line in Part I, as well as  
the corresponding line in Parts II through IV, as applicable, to  
report the status of the net 965 tax liability and any related  
adjustments for the reporting year.  
For example, for tax year 2017, a taxpayer (TP) reported a  
$100 net 965 tax liability for which an installment election was  
made. For each of years 1 through 5, TP pays and reports an $8  
installment. Also, in year 5, an audit adjustment increases the  
2017 net 965 tax liability to $150, a $50 positive adjustment. No  
amended return was required and there was no negligence,  
intentional disregard, or fraud on the part of TP. This adjustment  
would be prorated to all the installments. TP would report the  
$50 adjustment in Part I, line 1, column (j), as a positive number,  
so the reported adjusted liability would be $150. In addition, TP  
would pay and report (in addition to the original $8 installment  
reported for year 5) $20 on Part II, line 1, column (f),  
Column (b). Report the taxpayer’s net income tax liability for  
the tax year reported in column (a), with all section 965 amounts  
included (“with calculation”).  
Column (c). Report the taxpayer’s net income tax liability for  
the tax year reported in column (a), without regard to section 965  
(“without calculation”).  
representing 8% of the adjustment prorated to each of years 1  
through 5, for which the installment due date had already  
arrived. For year 6, TP would pay and report $22.50 (15% of the  
adjusted $150 liability); for year 7, $30 (20% of the adjusted  
$150 liability); and for year 8, $37.50 (25% of the adjusted $150  
liability).  
In a case in which a net 965 tax liability for a tax year is both  
adjusted and transferred, report the net adjustment/transfer  
number in column (j), a transferee tax identification number in  
column (k), and provide a statement, attached to this form, which  
includes details of the amounts netted in column (j).  
Column (d). Report the excess of the taxpayer’s “with  
calculation” reported in column (b) over the “without calculation”  
reported in column (c). This is the taxpayer’s net 965 tax liability  
for the tax year reported in column (a).  
Column (e). If the taxpayer is a shareholder in one or more S  
corporation(s) with section 965 amounts, report the total of  
column (g) from Part III for the tax year reported in column (a).  
This is the total S corporation-related net 965 tax liability the  
taxpayer elected to defer. See detailed instructions for Part III  
regarding the S corporation-by-S corporation calculations and  
elections.  
Part II – Record of Amount of Net 965  
Tax Liability Paid by the Taxpayer  
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  
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  
liabilities reported in Part I.  
Column (g). If the taxpayer made an election to pay a net 965  
tax liability in installments over 8 years as provided for in section  
965(h) and in the manner described in Regulations section  
1.965-7(b)(2), enter a check mark in the “Yes” column. If “Yes,”  
skip column (h) and enter the amount from column (f) in column  
(i). Otherwise, enter a check mark in the “No” column. If “No,”  
enter the amount from column (f) in column (h) and skip column  
(i).  
Line 1. This line records the actual payments with respect to the  
net 965 tax liability reported on line 1 of Part I for the tax year  
2017.  
The general installment payment schedule for a net 965 tax  
liability subject to an election to pay in installments is:  
1. 8% of the net 965 tax liability payable in year 1 (the year  
of the section 965(a) inclusion or triggering event with respect to  
a deferred S corporation-related net 965 tax liability),  
The actual payment of the first installment is due no later  
than the due date of the return for the tax year without  
!
CAUTION  
extension, even if the election is made on a return filed  
2. 8% of the net 965 tax liability payable in year 2,  
3. 8% of the net 965 tax liability payable in year 3,  
4. 8% of the net 965 tax liability payable in year 4,  
5. 8% of the net 965 tax liability payable in year 5,  
6. 15% of the net 965 tax liability payable in year 6,  
7. 20% of the net 965 tax liability payable in year 7, and  
8. 25% of the net 965 tax liability payable in year 8.  
by the extended due date.  
Column (j). Report the following in column (j):  
Report, as a negative number, any net 965 tax liability for the  
year reported in column (a) that has been transferred out to a  
transferee, by agreement with the Secretary, under which the  
transferee becomes liable for the remaining installments due on  
the liability in the same manner as if such transferee were the  
taxpayer. (See instructions for Form 965-C for more details.) In  
addition, provide the tax identification number of the transferee  
in column (k). For example, if the taxpayer (transferor) incurred a  
net 965 tax liability in tax year 2017, for which an installment  
payment election was made, then properly transferred the  
If, for any reason, the actual payment differs from the  
schedule, report the actual payment made.  
Example. If the reporting year is 2020 and the taxpayer is  
reporting a 2017 net 965 tax liability for which an installment  
-3-  
Instructions for Form 965-A (Rev. 01-2021)  
   
payment election was made, because the 2020 reporting year is  
“Year 4” with respect to a 2017 net 965 tax liability being paid in  
installments, installment payments reported in Part II on line 1,  
the line for 2017, should generally be:  
amount reported on the corresponding line in Part I, column (j),  
less any payments reported in Part II, columns (b) through (i).  
Column (k). For each line, report only the payment made (if  
any) for the reporting year.  
In column (b), Paid for Year 1, report 8% of the 2017 net 965  
Current-year reporting of column (k) amounts:  
Individuals: For tax year 2020, enter the amount from Form  
965-A, Part II, column (k), line 4, on Schedule 2 (Form 1040),  
line 9.  
tax liability;  
In column (c), Paid for Year 2, report 8% of the 2017 net 965  
tax liability;  
In column (d), Paid for Year 3, report 8% of the 2017 net 965  
All others: For all other filers (that is, other taxpayers taxed like  
an individual), follow the form instructions for that other  
applicable return.  
tax liability; and  
In column (e), Paid for Year 4, report 8% of the 2017 net 965  
tax liability.  
Part III – S Corporation Shareholder:  
Report of Calculation of Net 965 Tax  
Liability Related to 965 Amounts  
Allocated from an S Corporation and  
Election To Defer Such Net 965 Tax  
Liability  
Column (a). Report the tax year of the section 965(a) inclusion,  
the net 965 tax liability for which an installment payment liability  
is being assumed, or triggering event with respect to a deferred  
S corporation-related net 965 tax liability, as reported on the  
corresponding line of Part I, column (a).  
Columns (b) through (i). These columns are used to record  
the taxpayer’s cumulative payments, made each reporting year,  
for the net 965 tax liability reported on the corresponding line in  
Part I.  
If no installment election is made, the net 965 tax liability  
reported in Part I, column (h), should be paid and reported on  
the corresponding line of Part II, column (b), Paid for Year 1, and  
the remaining payment columns (c) through (i) left blank.  
If an installment election is made, and no transfers,  
acceleration events, or adjustments occur during the 8-year  
installment period, then 8% of the net 965 tax liability should be  
paid and reported in column (b), Paid for Year 1 (the year of the  
installment payment election). In the next reporting year, the  
relevant information from the prior reporting year should be  
carried forward, plus 8% of the net 965 tax liability should be  
paid and reported in column (c), Paid for Year 2. In future  
reporting years, the payments and payment reporting should  
continue similarly in accordance with the general installment  
payment schedule described above.  
If the taxpayer transfers out a net 965 tax liability, then the  
making and reporting of installment payments should generally  
cease for the transferred net 965 tax liability in the year of  
transfer. However, reporting with respect to the net 965 tax  
liability is still required for the reporting year if any net 965 tax  
liability of the taxpayer remains unpaid at any time during the  
reporting year.  
If an acceleration event occurs, then the unpaid portion of all  
remaining installments is due on the date of the acceleration  
event and should be paid and reported in the column for the year  
in which the acceleration event occurs; however, reporting with  
respect to the net 965 tax liability is still required for the reporting  
year if any net 965 tax liability of the taxpayer remains unpaid at  
any time during the reporting year.  
If an adjustment occurs to a net 965 tax liability for which an  
installment election has been made, including on an amended  
return, the adjustment should generally be prorated over all the  
installment payments. For the part of the adjustment prorated to  
installments whose payment date has already arrived, adjust the  
payment for the reporting year in which the adjustment is made  
and report accordingly. For the part of the adjustment prorated to  
installments for which the payment date has not yet arrived, pay  
and report in accordance with the installment schedule.  
This Part allows a taxpayer that is an S corporation shareholder  
to report net 965 tax liabilities related to section 965 amounts  
with respect to S corporations. For each S corporation-related  
net 965 tax liability, the taxpayer may elect to defer payment of  
such liability until a triggering event occurs. (See instructions for  
Part IV for more information on triggering events.) Each S  
corporation-related net 965 tax liability is calculated on an  
individual S corporation basis, and an election to defer such  
liability is also made on an individual S corporation basis. Such  
liabilities deferred, if any, must be totaled by tax year, and the  
total carried to Part I, column (e), of the respective tax year line.  
Lines 1 through 4. Report S corporation-related net 965 tax  
liabilities for the tax year indicated. On lines 1, 2 and 3, you must  
continue to report 2017, 2018, and/or 2019 amounts for all  
columns, even though they were reported on a prior-year Form  
965-A. Space is provided for reporting net 965 tax liabilities  
related to up to four S corporations. If additional lines are needed  
for the tax year, use additional Forms 965-A.  
Column (a). Report the name of the S corporation from which  
the taxpayer is allocated section 965 amounts. Abbreviate as  
needed.  
Column (b). Report the tax identification number of the S  
corporation reported in column (a). The tax identification number  
of an S corporation is its employer identification number (EIN).  
Column (c). Report the taxpayer’s net income tax for the tax  
year calculated only with section 965 amounts allocated from  
this S corporation with respect to DFICs of which the S  
corporation is a U.S. shareholder. This is the S  
corporation-related “with calculation.”  
Column (d). Report the taxpayer’s net income tax for the tax  
year calculated without regard to section 965, that is, the  
“without calculation.” This should equal the taxpayer’s net tax  
liability without section 965 amounts for the corresponding tax  
year reported in Part I, column (c).  
Column (e). Report the excess of the taxpayer’s S  
corporation-related “with calculation” reported in column (c) over  
the “without calculation” reported in column (d). This is the  
taxpayer’s S corporation-related net 965 tax liability with respect  
to this S corporation for the tax year.  
Payments should include both actual installment payments  
made and excess payments of other income tax liabilities  
applied to the taxpayer’s net 965 tax liability.  
Column (f). If the taxpayer made an election to defer payment  
of this S corporation-related net 965 tax liability as provided for in  
section 965(i) and in the manner described in Regulations  
section 1.965-7(c)(2), enter a check mark in the “Yes” column.  
Otherwise, enter a check mark in the "No" column.  
Column (j). Report the net 965 tax liability remaining unpaid  
after the payment for the reporting year. This amount should  
equal the amount reported on the corresponding line in Part I,  
column (f), or column (i), as applicable, plus or minus any  
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Instructions for Form 965-A (Rev. 01-2021)  
 
Column (g). If the taxpayer elected to defer an S  
corporation-related net 965 tax liability, enter the amount from  
column (e). (If the election was not made, then the liability  
remains a part of the taxpayer’s total net 965 tax liability subject  
to an installment payment election.) The total of column (g) for a  
tax year represents the taxpayer’s total deferred S  
corporation-related net 965 tax liability for the tax year and  
should be entered on the corresponding tax year line in Part I,  
column (e).  
Column (f). Report the amount of each deferred S  
corporation-related net 965 tax liability, payment of which  
ceases to be deferred as a result of a triggering event during the  
reporting year (“triggered S corporation-related net 965 tax  
liability”). The triggered S corporation-related net 965 tax liability  
amount should be reported in column (f) as a negative number  
and transferred to column (f) on one of lines 5 through 8 in Part I  
as a positive number. See Triggered deferred S  
corporation-related net 965 tax liability, in the instructions for  
Part IV – Annual Report of Deferred  
Net 965 Tax Liability Related to 965  
Amounts Allocated from S  
Corporations  
Column (g). Report the amount of deferred S  
corporation-related net 965 tax liability transferred out or in.  
Transfers (out). When a taxpayer transfers stock of an S  
corporation with respect to which the taxpayer has made an  
election to defer payment of its S corporation-related net 965 tax  
liability, the transfer is not treated as a triggering event if the  
transferee, by agreement with the Secretary, becomes liable for  
the deferred S corporation-related net 965 tax liability in the  
same manner as the transferor. (See instructions for Form 965-D  
for more details.)  
Report the amount of the transfer out as a negative number in  
column (g) of the same line as the taxpayer reported the  
deferred S corporation-related net 965 tax liability at the  
beginning of the reporting year.  
Any shareholder of an S corporation that makes an election to  
defer payment of an S corporation-related net 965 tax liability  
must report such liability with their income tax return for the year  
of election and every year thereafter through the year in which  
such amount is fully paid. Part IV provides for the required  
annual reporting of deferred S corporation-related net 965 tax  
liabilities and any adjustments related to such deferred liabilities  
during the reporting year.  
If the taxpayer fails to report for any year information  
In a case of multiple transferees, report the total deferred S  
corporation-related net 965 tax liability transferred as a negative  
number in column (g) and in column (h) report the tax  
required to be reported under section 965(i)(7) by the  
!
CAUTION  
due date of the return for such year, 5% of the deferred  
net 965 tax liability shall be assessed as an addition to tax for  
such reporting year.  
identification number of a transferee and attach a schedule to  
Form 965-A providing a breakdown of the total deferred S  
corporation-related net 965 tax liability transferred and the  
associated tax identification numbers of each transferee.  
Column (a). Report the year of:  
Deferral election. In a year for which an election is made to  
defer an S corporation-related net 965 tax liability, any amounts  
elected to be deferred must be transferred from Part III, column  
(g), to the corresponding line in Part IV, column (d). Enter the  
year for which the election is made in column (a) of the  
corresponding line.  
Transfers in. A taxpayer may assume, by agreement with the  
Secretary, a deferred 965 net tax liability as a buyer/transferee of  
S corporation stock with respect to which the transferor has a  
deferred S corporation-related net 965 tax liability. The taxpayer  
will then be liable for the deferred S corporation-related net 965  
tax liability in the same manner as the transferee, including being  
subject to annual reporting requirements, beginning for the tax  
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  
completed, skipping columns (d), (e), and (f), and entering in  
both columns (g) and (i) the deferred S corporation-related net  
965 tax liability transferred in as a positive number.  
Transfer in. In certain circumstances, by agreement with the  
Secretary, a taxpayer may assume a deferred S  
corporation-related net 965 tax liability from another taxpayer  
who had elected to defer such amount. The transferee is liable  
for the deferred S corporation-related net 965 tax liability in the  
same manner as the transferor, including being subject to  
annual reporting requirements. (See instructions for Form 965-D  
for more details.) Enter the tax year of transfer in column (a). See  
the instructions for Part IV, column (g), later, for reporting the  
amount of the transfer in.  
For reporting years following the year of transfer, report the  
transferred deferred S corporation-related net 965 tax liability in  
the same fashion as all other deferred S corporation-related net  
965 tax liabilities.  
Column (b). Report the name of the S corporation to which the  
deferred net 965 tax liability relates. Abbreviate as needed.  
Column (h). Provide the tax identification number of the  
Column (c). Report the tax identification number of the S  
corporation reported in column (b). The tax identification number  
of an S corporation is its employer identification number (EIN).  
transferee or transferor.  
Column (i). For each line, combine the amounts reported in  
columns (d) through (g).  
Column (d). Report the beginning deferred S  
corporation-related net 965 tax liability.  
Paperwork Reduction Act Notice  
For the year of the deferral election, this amount will be the S  
corporation-related net 965 tax liability for which the taxpayer  
elects to defer payment and should be transferred from the  
corresponding line for such S corporation in Part III, column (g).  
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  
the information. We need it to ensure that you are complying  
with these laws and to allow us to figure and collect the right  
amount of tax.  
For subsequent reporting years, the amount reported should  
equal the amount on the corresponding line in column (i) from  
Part IV of Form 965-A for the prior reporting year.  
You are not required to provide the information requested on  
a form that is subject to the Paperwork Reduction Act unless the  
form displays a valid OMB control number. Books or records  
relating to a form or its instructions must be retained as long as  
their contents may become material in the administration of any  
Internal Revenue law. Generally, tax returns and return  
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  
liability assumed by the taxpayer.  
Column (e). Reserved for future use.  
information are confidential, as required by section 6103.  
-5-  
Instructions for Form 965-A (Rev. 01-2021)  
   
The time needed to complete and file this form will vary  
depending on individual circumstances. The estimated burden  
for individual taxpayers filing this form is approved under OMB  
control number 1545-0074 and is included in the estimates  
shown in the instructions for their individual income tax return.  
-6-  
Instructions for Form 965-A (Rev. 01-2021)