This document provides guidance under
new section 965 enacted by the American Jobs Creation Act of 2004
(P.L. 108-357). In general and subject to limitation and
conditions, section 965(a) provides that a corporation that is a
U.S. shareholder of a controlled foreign corporation (CFC) may
elect, for one taxable year, an 85 percent dividends received
deduction (DRD) with respect to certain cash dividends it received
from its CFCs. Section 956(f) provides that taxpayers may elect the
application of section 965 for either the taxpayer's last taxable
year which begins before October 22, 2004, or the taxpayer's first
taxable year which
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.