What supporting documentation is required to be attached to a request for refund resulting from the carryback of NOLs to section 965 years

The supporting documentation required to be attached to a request for refund resulting from the carryback of NOLs to section 965 years includes:

1. All supporting documentation for the NOL carryback as described in the Form 1139 or Form 1045 instructions. This includes any forms, schedules, and statements that substantiate the NOL and its carryback.
2. An amended Form 965-A or Form 965-B (as applicable) to record the amount of the change in the section 965 net tax liability, if any, caused by the NOL carryback. This form is used to adjust the previously reported section 965 inclusion amounts and related tax liabilities.
3. A statement of explanation to explain the change in the section 965 net tax liability. This statement should detail how the NOL carryback affects the section 965 net tax liability, including any recalculations and adjustments made.

These documents ensure that the IRS has all necessary information to process the refund request accurately and to verify the impact of the NOL carryback on the section 965 year tax liability.

Sources:
Rev. Proc. 2020-24
Instructions for Form 1139 (11/2021)
Instructions for Form 1045 (2023)
§ 965. Treatment of deferred foreign income upon transition to participation exemption system of taxation