Friday, August 24, 2018

Section 965 and combined reporting

If filing a combined return, and more than one entity in the combined group has deferred foreign income (“Section 965 income”) for Rhode Island tax purposes for the 2017 tax year, should a Rhode Island Schedule 965 (“965 Transition Tax Statement”) be included in the filing for each entity, or should the filing include a single Rhode Island Schedule 965 that includes the combined Section 965-related amounts for all the entities?

The answer is that the filing must include a single Rhode Island Schedule 965, showing the combined Section 965-related amounts for all the entities. Although the Rhode Island Schedule 965 will include only the combined amounts for all the entities, you must nevertheless create a spreadsheet or other such document listing the underlying detail for each of the entities. That spreadsheet or other such document must be kept on file and made readily available should the Division require the information at a later date.