help with 965(a) computation (Guya?) anyone??

Technical topics regarding tax preparation.
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Joanmcq  
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My client owns 2 CFCs, one (corp A) with a calendar year end and another (corp B) with a fiscal year end of Sept. 30. I'm working through the Pub 5292 calculation of the Sec. 965 inclusion, but don't have any data for the year ending Sept. 30, 2018 which is the 'Close of the last tax year beginning before Jan. 1, 2018' which is used to determine the aggregate cash position for 2017. I've read that in cases where a fiscal year ends after a shareholder's return is due, then the cash position for 2017 with respect to that corp will be zero. However, Corp B's year ends before Oct. 15, but the financial statements usually aren't completed until July of the next year. I'm hoping to get at least some figures soon, but my client's son is having surgery today, so I don't know. Originally when I read the regs and analysis I thought the fiscal year end inclusion would be figured out separately and reported on the shareholder's 2018 return and the calendar year corp would be reported on the 2017 return. But after working through the Pub, it doesn't seem to be the case.

Also, I saw one analysis define 'net accounts receivable' as A/R-A/P, but not less than zero. I can't find where the net A/R figure has to be positive in the law or regs and my client normally has much higher A/P than A/R and a correspondingly high amount of cash with which to pay it. Can anyone point me to a definitive answer? If the one analysis is true, the 'net A/R' will always be zero for my client, and he'll be screwed by the cash on hand to pay the A/P.

Lastly, I'm under the impression that any dividends paid during the year of inclusion aren't deducted from E&P. However, most of what I'm reading has to do with dividends paid to another SFC, not a shareholder. I'm currently including them in the E&P, but not reporting on the individual return since that would result in double taxation. Am I correct in this?
 

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