Client has an ownership interest in five foreign corps. Four are CFCs. 5471s are filed annually.
All have E&P deficits except one, which is and has always been dormant. The four that are CFCs are classified as 'specified foreign corporations' under Sec 965(e), however none are classified as 'deferred foreign income corporations' under Sec 965(d).
There will be no inclusion under Sec 965(a), nor a corresponding deduction under Sec 965(c).
As there is no income under Sec 965, a transition statement isn't required to be attached:
https://www.irs.gov/pub/irs-news/Append ... llable.pdf
Do you agree? How is everyone else handling a situation like this? Statement disclosure that Sec 965 doesn't apply for reasons listed above or business as usual? Anything that I'm not considering for 2017?