It is apparent that to the extent a CFC does not have Sec. 956 earnings, the main five columns connected with monitoring and reporting PTEP with the CFC on Schedules J and P are very likely not suitable. E&P amounts determined as inclusions to U.S. shareholders beneath Sec. 951A GILTI https://holdenfdyuo.webdesign96.com/36119400/the-fact-about-956-loan-that-no-one-is-suggesting