Gross Income or (Loss) From Sources Outside the United States (INCLUDE Foreign Branch Gross Income here and on Schedule F)

Transcription

1 Form 1118 (Rev. ecember 2009) epartment of the Treasury Internal Revenue Service Name of corporation Foreign Tax redit s See separate instructions. ttach to the corporation's tax return. For calendar year 20, or other tax year beginning, 20, and ending, 20 OM No mployer identification number Use a separate Form 1118 for each applicable category of income listed below. See ategories of Income in the instructions. lso, see Specific Instructions. heck only one box on each form. Passive ategory Income General ategory Income Section 901(j) Income: Name of Sanctioned ountry Income Re-sourced by Treaty: Name of ountry Schedule Income or (Loss) efore djustments (Report all amounts in U.S. dollars. See Specific Instructions.) 1. Foreign ountry or U.S. Possession (nter two-letter code; see instructions. Use a separate line for each.) * Gross Income or (Loss) From Sources Outside the United States (INLU Foreign ranch Gross Income here and on Schedule F) 2. eemed ividends (a) xclude gross-up (b) Gross-up (sec. 78) 3. Other ividends (a) xclude gross-up (b) Gross-up (sec. 78) 4. Interest 5. Gross Rents, Royalties, and License Fees F Totals (add lines through F) * For section 863(b) income, NOLs, income from RIs, and high-taxed income, use a single line. eductions (INLU Foreign ranch eductions here and on Schedule F) F Totals 9. efinitely llocable eductions Rental, Royalty, and Licensing xpenses (c) xpenses (d) Other Related to Gross (a) epreciation, efinitely (b) Other Income From epletion, and llocable xpenses Performance of mortization eductions Services (e) Total efinitely llocable eductions (add columns 9(a) through 9(d)) 10. pportioned Share of eductions Not efinitely llocable (enter amount from applicable line of Schedule H, Part II, column (d)) 6. Gross Income From Performance of Services 11. Net Operating Loss eduction 7. Other (attach 12. Total eductions (add columns 9(e) through 11) 8. Total (add columns 2(a) through 7) 13. Total Income or (Loss) efore djustments (subtract column 12 from column 8) For Paperwork Reduction ct Notice, see separate instructions. at. No F

2 Page 2 Schedule Foreign Tax redit (Report all foreign tax amounts in U.S. dollars.) Part I Foreign Taxes Paid, ccrued, and eemed Paid F 1. redit is laimed for Taxes: Paid ate Paid ccrued ate ccrued 2. Foreign Taxes Paid or ccrued (attach schedule showing amounts in foreign currency and conversion rate(s) used) Tax Withheld at Source on: (a) ividends (b) Interest (c) Rents, Royalties, and License Fees Other Foreign Taxes Paid or ccrued on: (d) Section 863(b) Income (e) Foreign ranch Income (f) Services Income (g) Other 3. Tax eemed Paid (from Schedule (h) Total Foreign Taxes Part I, column 10, Paid or ccrued (add Part II, column 8(b), columns 2(a) through 2(g)) and Part III, column 8) Totals (add lines through F) Part II Separate Foreign Tax redit (omplete a separate Part II for each applicable category of income.) 1 Total foreign taxes paid or accrued (total from Part I, column 2(h)) Total taxes deemed paid (total from Part I, column 3) Reductions of taxes paid, accrued, or deemed paid (enter total from Schedule G) ( ) 4 Taxes reclassified under high-tax kickout nter the sum of any carryover of foreign taxes (from Schedule K, line 3, column (xiv)) plus any carrybacks to the current tax year.. 6 Total foreign taxes (combine lines 1 through 5) nter the amount from the applicable column of Schedule J, Part I, line 11. If Schedule J is not required to be completed, enter the result from the Totals line of column 13 of the applicable Schedule a Total taxable income from all sources (enter taxable income from the corporation s tax return) b djustments to line 8a c Subtract line 8b from line 8a ivide line 7 by line 8c. nter the resulting fraction as a decimal. If line 7 is greater than line 8c, enter Total U.S. income tax against which credit is allowed (regular tax liability section 26(b)) minus merican Samoa economic development credit).. 11 redit limitation (multiply line 9 by line 10) Separate foreign tax credit (enter the smaller of line 6 or line 11 here and on the appropriate line of Part III) Part III Summary of Separate redits (nter amounts from Part II, line 12 for each applicable category of income. o not include taxes paid to sanctioned countries.) 1 redit for taxes on passive category income redit for taxes on general category income redit for taxes on income re-sourced by treaty (combine all such credits on this line) Total (add lines 1 through 3) Reduction in credit for international boycott operations Total foreign tax credit (subtract line 5 from line 4). nter here and on the appropriate line of the corporation s tax return

3 Page 3 Schedule Tax eemed Paid by omestic Filing Return Use this schedule to figure the tax deemed paid by the corporation with respect to dividends from a first-tier foreign corporation under section 902(a), and deemed inclusions of earnings from a first- or lower-tier foreign corporation under section 960(a). Report all amounts in U.S. dollars unless otherwise specified. Part I ividends and eemed Inclusions From Post-1986 Undistributed arnings 1. Name of Foreign (identify ISs and former ISs) nd (Yr-Mo) Incorporation (enter country code from Undistributed arnings (in functional Post-1986 Taxes 6. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (b) Taxes eemed Paid (from Schedule, Part I see columns 5, 6(a), and 6(b)) (a) Functional urrency 8. ividends and eemed Inclusions 8(a) by 10. Tax eemed Paid (multiply column 7 by column 9) Total (dd amounts in column 10. nter the result here and include on Totals line of Schedule, Part I, column 3.) Part II ividends Paid Out of Pre-1987 ccumulated Profits 1. Name of Foreign (identify ISs and former ISs) nd (Yr-Mo) 4. ccumulated Profits for Tax Year Indicated currency computed under section 902) (attach 5. Foreign Taxes Paid and eemed Paid on arnings and Profits (&P) for Tax Year Indicated currency) (a) Functional urrency 6. ividends Paid 7. ivide 6(a) by 8. Tax eemed Paid (a) Functional urrency Total (dd amounts in column 8b. nter the result here and include on Totals line of Schedule, Part I, column 3.) Part III eemed Inclusions From Pre-1987 arnings and Profits 1. Name of Foreign (identify ISs and former ISs) nd (Yr-Mo) 4. &P for Tax Year Indicated currency translated from U.S. dollars, computed under section 964) (attach 5. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (a) Functional urrency 6. eemed Inclusions 7. ivide 6(a) by 8. Tax eemed Paid (multiply column 5 by column 7) Total (dd amounts in column 8. nter the result here and include on Totals line of Schedule, Part I, column 3.)

4 Page 4 Schedule Tax eemed Paid by First- and Second-Tier Foreign s under Section 902(b) Use Part I to compute the tax deemed paid by a first-tier foreign corporation with respect to dividends from a second-tier foreign corporation. Use Part II to compute the tax deemed paid by a second-tier foreign corporation with respect to dividends from a third-tier foreign corporation. Report all amounts in U.S. dollars unless otherwise specified. Part I Tax eemed Paid by First-Tier Foreign s Section ividends Paid Out of Post-1986 Undistributed arnings (Include the column 10 results in Schedule, Part I, column 6(b).) 1. Name of Second-Tier Foreign and Its Related First-Tier Foreign nd (Yr-Mo) Undistributed arnings Post-1986 Foreign Income Taxes 6. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (b) Taxes eemed Paid columns 5, 6(a), and 6(b)) 8. ividends Paid currency) (a) of Second-tier (b) of First-tier 10. Tax eemed column 7 by column 9) Section ividends Paid Out of Pre-1987 ccumulated Profits (Include the column 8(b) results in Schedule, Part I, column 6(b).) 1. Name of Second-Tier Foreign and Its Related First-Tier Foreign nd (Yr-Mo) 4. ccumulated Profits for Tax Year Indicated currency attach 5. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (in functional currency see 6. ividends Paid currency) (a) of Second-tier (b) of First-tier 7. ivide 6(a) by 8. Tax eemed Paid (a) Functional urrency of Second-tier Part II Tax eemed Paid by Second-Tier Foreign s Section ividends Paid Out of Post-1986 Undistributed arnings (Include the column 10 results in Section, column 6(b), of Part I above.) 1. Name of Third-Tier Foreign and Its Related Second-Tier Foreign nd (Yr-Mo) Undistributed arnings Post-1986 Foreign Income Taxes 6. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (b) Taxes eemed Paid (from Schedule, Part I, column 10) Foreign Income Taxes (add columns 5, 6(a), and 6(b)) 8. ividends Paid currency) (a) of Third-tier (b) of Second-tier 10. Tax eemed column 7 by column 9) Section ividends Paid Out of Pre-1987 ccumulated Profits (Include the column 8(b) results in Section, column 6(b), of Part I above.) 1. Name of Third-Tier Foreign and Its Related Second-Tier Foreign nd (Yr-Mo) 4. ccumulated Profits for Tax Year Indicated (in functional currency attach 5. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (in functional currency see 6. ividends Paid currency) (a) of Third-tier (b) of Second-tier 7. ivide 6(a) by 8. Tax eemed Paid (a) In Functional urrency of Third-tier

5 Page 5 Schedule Tax eemed Paid by ertain Third-, Fourth-, and Fifth-Tier Foreign s Under Section 902(b) Use this schedule to report taxes deemed paid with respect to dividends from eligible post-1986 undistributed earnings of fourth-, fifth- and sixth-tier controlled foreign corporations. Report all amounts in U.S. dollars unless otherwise specified. Part I Tax eemed Paid by Third-Tier Foreign s (Include the column 10 results in Schedule, Part II, Section, column 6(b).) 1. Name of Fourth-Tier Foreign and Its Related Third-Tier Foreign nd (Yr-Mo) Undistributed arnings Post-1986 Taxes 6. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (b) Taxes eemed Paid (from Part II, column 10) columns 5, 6(a), and 6(b)) 8. ividends Paid (in functional currency) (a) Of Fourth-tier (b) Of Third-tier 10. Tax eemed column 7 by column 9) Part II Tax eemed Paid by Fourth-Tier Foreign s (Include the column 10 results in column 6(b) of Part I above.) 1. Name of Fifth-Tier Foreign and Its Related Fourth-Tier Foreign nd (Yr-Mo) Undistributed arnings Post-1986 Taxes 6. Foreign Taxes Paid and eemed Paid for Tax Year Indicated (b) Taxes eemed Paid (from Part III, column 10) columns 5, 6(a), and 6(b)) 8. ividends Paid (in functional currency) (a) Of Fifth-tier (b) Of Fourth-tier 10. Tax eemed column 7 by column 9) Part III Tax eemed Paid by Fifth-Tier Foreign s (Include the column 10 results in column 6(b) of Part II above.) 1. Name of Sixth-Tier Foreign and Its Related Fifth-Tier Foreign nd (Yr-Mo) Undistributed arnings Post-1986 Taxes 6. Foreign Taxes Paid For Tax Year Indicated columns 5 and 6) 8. ividends Paid (in functional currency) (a) Of Sixth-tier (b) Of Fifth-tier 10. Tax eemed column 7 by column 9)

6 Page 6 Schedule F Gross Income and efinitely llocable eductions for Foreign ranches Schedule G Reductions of Taxes Paid, ccrued, or eemed Paid 1. Foreign ountry or U.S. Possession (nter two-letter code from Schedule, column 1. Use a separate line for each.) 2. Gross Income 3. efinitely llocable eductions Reduction of Taxes Under Section 901(e) ttach separate schedule Reduction of Foreign Oil and Gas Taxes nter amount from Schedule I, Part II, line 6 Reduction of Taxes ue to International oycott Provisions nter appropriate portion of Schedule (Form 5713), line 2b. Important: nter only specifically attributable taxes here. Reduction of Taxes for Section 6038(c) Penalty ttach separate schedule Other Reductions of Taxes ttach schedule(s) F Totals (add lines through F)* * Note: The Schedule F totals are not carried over to any other Form 1118 Schedule. (These totals were already included in Schedule.) However, the IRS requires the corporation to complete Schedule F under the authority of section 905(b). Total (add lines through ). nter here and on Schedule, Part II, line

7 Page 7 Schedule H pportionment of eductions Not efinitely llocable (complete only once) Part I Research and evelopment eductions 1 Totals (a) Sales Method Product line #1 (SI ode: ) * Product line #2 (SI ode: ) * (i) Gross Sales (ii) R& eductions (iii) Gross Sales (iv) R& eductions (v) Total R& eductions Under Sales Method (add columns (ii) and (iv)) (b) Gross Income Method heck method used: (See Option 1 Option 2 instructions.) (vii) Total R& (vi) Gross Income eductions Under Gross Income Method (c) Total R& eductions Not efinitely llocable (enter all amounts from column (a)(v) or all amounts from column (b)(vii)) 2 Total to be apportioned 3 pportionment among statutory groupings: a b c d General category income Passive category income Section 901(j) income* Income re-sourced by treaty* 4 Total foreign (add lines 3a through 3d) * Important: See omputer-generated Schedule H in instructions.

8 Page 8 Schedule H pportionment of eductions Not efinitely llocable (continued) Part II Interest eductions, ll Other eductions, and Total eductions (a) verage Value of ssets heck method used: 1a b c Totals mounts specifically allocable under Temp. Regs T(e) Other specific allocations under Temp. Regs T d ssets excluded from apportionment formula 2 Total to be apportioned (subtract the sum of lines 1b, 1c, and 1d from line 1a) 3 pportionment among statutory groupings: Fair market value lternative tax book value (i) Nonfinancial s Tax book value (ii) Financial s (iii) Nonfinancial s (b) Interest eductions (iv) Financial s (c) ll Other eductions Not efinitely llocable (d) Totals (add the corresponding amounts from column (c), Part I; columns (b)(iii) and (b)(iv), Part II; and column (c), Part II). nter each amount from lines 3a through 3d below in column 10 of the corresponding Schedule. a b c d General category income Passive category income Section 901(j) income* Income re-sourced by treaty* 4 Total foreign (add lines 3a through 3d) * Important: See omputer-generated Schedule H in instructions.