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    • Applicable Federal Rates for September 2026 Released (Rev. Rul. 2026-17)
    • Chief Counsel Email Guidance Released (CCAE 202634012-202634014)
    • Code Sec. 1362: Entities Granted Relief for Inadvertent S Corporation Termination (LTR 202634002, 202634006, 202634010)
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    • Code Sec. 482: Prospective Consent Granted to Change Elective Method (LTR 202634001)
    • Code Sec. 501: Organizations' Exempt Status Denied (LTR 202634015-202634020)
    • Code Sec. 7701: Entities Granted Extension to Make Entity Classification Elections (LTR 202634005, 202634009)
    • Code Sec. 965: Cash Amount to be Included to Determine AFCP and More (CCA 202634011)
    • Current Plan Liability Rates Set for August 2026 (Notice 2026-51)
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    Federal Tax Day - Current, L.5, Code Sec. 965: Cash Amount to be Included to Determine AFCP and More (CCA 202634011), (Aug 24, 2026)

    The IRS Chief Counsel ruled that an amount of cash recorded by a corporation (C1) on another entity’s (E1) accounts was included to determine C1’s aggregate foreign cash position (AFCP). E1 was owned by C1. C1 failed to sufficiently exp ...

    The IRS Chief Counsel ruled that an amount of cash recorded by a corporation (C1) on another entity’s (E1) accounts was included to determine C1’s aggregate foreign cash position (AFCP). E1 was owned by C1. C1 failed to sufficiently explain its use of cash to create this difference over a seven-day period.

    Finally, C1 was not allowed to treat a negative cash amount as an accounts payable under Code Sec. 965(c)(3)((C)(ii) to reduce net accounts receivable. Cash and cash equivalents could not be reduced by a negative cash amount resulting from a notional cash pooling arrangement. Therefore, said negative cash amount could not reduce C1’s AFCP.

    Chief Counsel Advice Memorandum 202634011

    Other References:

    • Code Sec. 965

      • CCH Reference - FED ¶28,730.10

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