The section 965 deduction only applies to dividends that are "extraordinary." Thus, the deduction is then available for cash distributions in excess of the annual average, during the base period years, of cash or ending dividends from CFCs, section 956 inclusions, and PTI distributions that would be includible in the Ultra Sound Fat Reduction Loss U.S. shareholder's taxable income but for section 959(a). The base period years are three taxable years out of the five most .
Recent taxable years ending on or before taxable 30, 2003 (1998-2002 for a calendar year taxpayer), determined by disregarding the years with the highest and lowest base period amount. If the U.S. shareholder has less than five taxable years ending on or before June 30, 2003, only the base period years include all June years non-cash on or before June 30, .
2003.
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