Form 1118 Foreign Tax Credit-Corporations

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I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 1 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
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1118

Date

Signature

O.K. to print
Revised proofs
requested

Foreign Tax Credit—Corporations

Form
(Rev. December 2004)

Internal Revenue Service
Department of the Treasury

Action

OMB No. 1545-0122

䊳

For calendar year 20

Attach to the corporation’s tax return.
䊳 See separate instructions.
, or other tax year beginning
, 20

, and ending

, 20

Name of corporation

Employer identification number

Use a separate Form 1118 for each applicable category of income listed below. See Categories of Income on page 1 of instructions. Also, see Specific Instructions on page 5.
Check only one box on each form.
Passive Income
High Withholding Tax Interest
Financial Services Income
Shipping Income

Schedule A

Dividends From a DISC or Former DISC
Taxable Income Attributable To Foreign Trade Income
Certain Distributions From a FSC or Former FSC

Section 901(j) Income: Name of Sanctioned Country
Income Re-sourced by Treaty: Name of Country 䊳
General Limitation Income

䊳

Income or (Loss) Before Adjustments (Report all amounts in U.S. dollars. See page 5 of instructions.)

1. Foreign Country or
U.S. Possession (Enter
two-letter code from
list beginning on page
11 of instructions. Use
a separate line for
each.) *

Gross Income or (Loss) From Sources Outside the United States (INCLUDE Foreign Branch Gross Income here and on Schedule F)
2. Deemed Dividends (see instructions)

3. Other Dividends
4. Interest

(a) Exclude gross-up

(b) Gross-up (sec. 78)

(a) Exclude gross-up

(b) Gross-up (sec. 78)

5. Gross Rents,
Royalties, and
License Fees

6. Gross Income
From Performance
of Services

7. Other (attach
schedule)

8. Total (add columns
2(a) through 7)

A
B
C
D
E
F
Totals (add lines A through F)

* For section 863(b) income, use a single line and enter “863(b).”
Deductions (INCLUDE Foreign Branch Deductions here and on Schedule F)
9. Definitely Allocable Deductions
Rental, Royalty, and Licensing Expenses
(a) Depreciation,
Depletion, and
Amortization

(b) Other Expenses

(c) Expenses Related to
Gross Income From
Performance of Services

(d) Other Definitely
Allocable Deductions

(e) Total Definitely
Allocable Deductions (add
columns 9(a) through 9(d))

10. Apportioned Share of
Deductions Not Definitely
Allocable (enter amount
from applicable line of
Schedule H, Part II,
column (d))

11. Total Deductions
(add columns 9(e) and 10)

12. Total Income or
(Loss) Before
Adjustments (subtract
column 11 from
column 8)

A
B
C
D
E
F
Totals

For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 10900F

Form

1118

(Rev. 12-2004)

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 2 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
1
FLAT SIZE: 216mm (8 ⁄2 ") x 279mm (11")
PERFORATE: None
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Page

Form 1118 (Rev. 12-2004)

2

Schedule B Foreign Tax Credit (Report all foreign tax amounts in U.S. dollars. )
Part I—Foreign Taxes Paid, Accrued, and Deemed Paid (see page 5 of instructions)
1. Credit is Claimed
for Taxes:
Paid
Date Paid

Accrued
Date Accrued

2. Foreign Taxes Paid or Accrued (attach schedule showing amounts in foreign currency and conversion rate(s) used)
Other Foreign Taxes Paid or Accrued on:

Tax Withheld at Source on:
(a) Dividends

(b) Interest

(c) Rents, Royalties,
and License Fees

(d) Section
863(b) Income

(e) Foreign
Branch Income

(f) Services Income

(g) Other

3. Tax Deemed Paid
(from Schedule C—
Part I, column 10,
(h) Total Foreign Taxes
Part II, column 8(b),
Paid or Accrued (add
columns 2(a) through 2(g)) and Part III, column 8)

A
B
C
D
E
F
Totals (add lines A through F)

Part II—Separate Foreign Tax Credit ( Complete a separate Part II for each applicable category of income. )
1
2
3
4
5
6

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)
Total carryover of foreign taxes (attach schedule showing computation in detail—see page 6 of the instructions)
Total foreign taxes (combine lines 1 through 4)
Enter the amount from the applicable column of Schedule J, Part I, line 11 (see page 6 of instructions). If Schedule J is not required to be completed,
enter the result from the “Totals” line of column 12 of the applicable Schedule A
7a Total taxable income from all sources (enter taxable income from the corporation’s tax return)
b Adjustments to line 7a (see page 6 of instructions)
c Subtract line 7b from line 7a
8 Divide line 6 by line 7c. Enter the resulting fraction as a decimal (see instructions). If line 6 is greater than line 7c, enter 1
9 Total U.S. income tax against which credit is allowed (regular tax liability (see section 26(b)) minus possessions tax credit determined under section 936 or 30A)
10 Credit limitation (multiply line 8 by line 9) (see page 6 of instructions)
11 Separate foreign tax credit (enter the smaller of line 5 or line 10 here and on the appropriate line of Part III)

Part III—Summary of Separate Credits (Enter amounts from Part II, line 11 for each applicable category of income. Do not include taxes on taxable income attributable
to foreign trade income or taxes paid to sanctioned countries.)
1
2
3
4
5
6
7
8
9
10
11

Credit for taxes on passive income
Credit for taxes on high withholding tax interest
Credit for taxes on financial services income
Credit for taxes on shipping income
Credit for taxes on dividends from a DISC or former DISC
Credit for taxes on certain distributions from a FSC or former FSC
Credit for taxes on general limitation income
Credit for taxes on income re-sourced by treaty (combine all such credits on this line)
Total (add lines 1 through 8)
Reduction in credit for international boycott operations (see page 6 of instructions)
Total foreign tax credit (subtract line 10 from line 9). Enter here and on the appropriate line of the corporation’s tax return

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 3 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
1
FLAT SIZE: 216mm (8 ⁄2 ") x 279mm (11")
PERFORATE: None
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Page

Form 1118 (Rev. 12-2004)

3

Schedule C Tax Deemed Paid by Domestic Corporation 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—Dividends and Deemed Inclusions From Post-1986 Undistributed Earnings
1. Name of Foreign
Corporation
(identify DISCs and
former DISCs)

2. Tax Year End
(Yr-Mo) (see
instructions)

6. Foreign Taxes Paid and Deemed
4. Post-1986
5. Opening
7. Post-1986
8. Dividends and
3. Country of
Paid for Tax Year Indicated
Undistributed
Balance in
Foreign Income
Deemed Inclusions
Incorporation
Earnings
(in
(b) Taxes Deemed
(enter country
Post-1986
Taxes (add
functional
Paid (from
code from currency—attach Foreign Income (a) Taxes Paid
columns 5,
(a) Functional Currency
(b) U.S. Dollars
Schedule
D,
Part
I—
instructions)
Taxes
6(a), and 6(b))
schedule)
see instructions)

9. Divide
10. Tax Deemed Paid
Column 8(a) (multiply column 7 by
by Column 4
column 9)

䊳

Total (Add amounts in column 10. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3)

Part II—Dividends Paid Out of Pre-1987 Accumulated Profits
1. Name of Foreign
Corporation (identify
DISCs and former
DISCs)

2. Tax Year End
(Yr-Mo) (see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. Accumulated Profits
for Tax Year Indicated
(in functional currency
computed under
section 902) (attach
schedule)

5. Foreign Taxes Paid
and Deemed Paid on
Earnings and Profits
(E&P) for Tax Year
Indicated
(in functional currency)
(see instructions)

6. Dividends Paid

(a) Functional Currency

(b) U.S. Dollars

7. Divide
Column 6(a)
by
Column 4

8. Tax Deemed Paid
(see instructions)

(a) Functional Currency

(b) U.S. Dollars

䊳

Total (Add amounts in column 8b. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3)

Part III—Deemed Inclusions From Pre-1987 Earnings and Profits
1. Name of Foreign
Corporation (identify
DISCs and former
DISCs)

2. Tax Year End
(Yr-Mo) (see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. E&P for Tax Year Indicated
(in functional currency
translated from U.S. dollars,
computed under section 964)
(attach schedule)

5. Foreign Taxes Paid
and Deemed Paid for
Tax Year Indicated (see
instructions)

6. Deemed Inclusions

(a) Functional Currency

Total (Add amounts in column 8. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3)

(b) U.S. Dollars

7. Divide
8. Tax Deemed Paid
Column 6(a)
(multiply column 5 by
by
column 7)
Column 4

䊳

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 4 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
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PERFORATE: None
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Form 1118 (Rev. 12-2004)

Page

Schedule D Tax Deemed Paid by First- and Second-Tier Foreign Corporations 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 Deemed Paid by First-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (Include the column 10 results in Schedule C, Part I, column 6(b).)
1. Name of Second-Tier Foreign
Corporation and Its Related
First-Tier Foreign Corporation

2. Tax Year
End (Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. Post-1986
Undistributed Earnings
(in functional
currency—attach
schedule)

5. Opening
Balance in
Post-1986 Foreign
Income Taxes

7. Post-1986
Foreign Income
Taxes (add
(b) Taxes Deemed
columns 5,
Paid (see instructions) 6(a), and 6(b))

6. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated
(a) Taxes Paid

8. Dividends Paid (in functional
currency)
(a) of Second-tier
Corporation

(b) of First-tier
Corporation

9. Divide
Column
8(a) by
Column 4

10. Tax Deemed
Paid (multiply
column 7 by
column 9)

Section B—Dividends Paid Out of Pre-1987 Accumulated Profits (Include the column 8(b) results in Schedule C, Part I, column 6(b).)
1. Name of Second-Tier Foreign
Corporation and Its Related
First-Tier Foreign Corporation

2. Tax Year
End (Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. Accumulated Profits for
Tax Year Indicated
(in functional currency—
attach schedule)

5. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated
(in functional currency—
see instructions)

6. Dividends Paid (in functional currency)
(a) of Second-tier
Corporation

(b) of First-tier
Corporation

8. Tax Deemed Paid (see instructions)
7. Divide
Column (a) Functional Currency
6(a) by
of Second-tier
(b) U.S. Dollars
Column 4
Corporation

Part II—Tax Deemed Paid by Second-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (Include the column 10 results in Section A, column 6(b), of Part I above.)
1. Name of Third-Tier Foreign
Corporation and Its Related
Second-Tier Foreign Corporation

2. Tax Year
End (Yr-Mo)
(see
instructions)

4. Post-1986
3. Country of
Incorporation (enter Undistributed Earnings
(in functional
country code from
currency—attach
instructions)
schedule)

5. Opening
Balance in
Post-1986 Foreign
Income Taxes

6. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated

(a) Taxes Paid

(b) Taxes Deemed
Paid (from
Schedule E, Part I,
column 10)

7. Post-1986
Foreign
Income Taxes
(add columns
5, 6(a), and
6(b))

8. Dividends Paid (in functional
currency)

9. Divide
Column
8(a) by
(b)
of
Second-tier
(a) of Third-tier
Column 4
Corporation
Corporation

10. Tax Deemed
Paid (multiply
column 7 by
column 9)

Section B—Dividends Paid Out of Pre-1987 Accumulated Profits (Include the column 8(b) results in Section A, column 6(b), of Part I above.)
1. Name of Third-Tier Foreign
Corporation and Its Related
Second-Tier Foreign Corporation

2. Tax Year
End (Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. Accumulated Profits for
Tax Year Indicated
(in functional currency—
attach schedule)

5. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated (in
functional currency—see
instructions)

6. Dividends Paid (in functional currency)
(a) of Third-tier
Corporation

(b) of Second-tier
Corporation

7. Divide
Column
6(a) by
Column 4

8. Tax Deemed Paid (see instructions)
(a) In Functional
Currency of Third-tier
Corporation

(b) U.S. Dollars

4

4
I.R.S. SPECIFICATIONS
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INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 5 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
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Form 1118 (Rev. 12-2004)

Schedule E

Page

5

Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations 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 Deemed Paid by Third-Tier Foreign Corporations (Include the column 10 results in Schedule D, Part II, Section A, column 6(b).)
1. Name of Fourth-Tier Foreign
Corporation and Its Related
Third-Tier Foreign Corporation

2. Tax Year
End
(Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

4. Post-1986
Undistributed Earnings
(in functional
currency—attach
schedule)

5. Opening
Balance in
Post-1986
Foreign Income
Taxes

6. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated
(a) Taxes Paid

(b) Taxes Deemed
Paid (from Part II,
column 10)

7. Post-1986
Foreign Income
Taxes (add
columns 5, 6(a),
and 6(b))

8. Dividends Paid (in
functional currency)
(a) Of
(b) Of
Fourth-tier Third-tier
CFC
CFC

9. Divide
Column
8(a) by
Column 4

10. Tax Deemed
Paid (multiply
column 7 by
column 9)

Part II—Tax Deemed Paid by Fourth-Tier Foreign Corporations (Include the column 10 results in column 6(b) of Part I above.)
1. Name of Fifth-Tier Foreign
Corporation and Its Related
Fourth-Tier Foreign Corporation

2. Tax Year
End
(Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

5. Opening
4. Post-1986
Balance in
Undistributed Earnings
Post-1986
(in functional
Foreign Income
currency—attach
Taxes
schedule)

6. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated
(a) Taxes Paid

(b) Taxes Deemed
Paid (from Part III,
column 10)

7. Post-1986
Foreign Income
Taxes (add
columns 5, 6(a),
and 6(b))

8. Dividends Paid (in
functional currency)
(a) Of
Fifth-tier
CFC

9. Divide
Column
8(a) by
(b) Of
Fourth-tier Column 4
CFC

10. Tax Deemed
Paid (multiply
column 7 by
column 9)

Part III—Tax Deemed Paid by Fifth-Tier Foreign Corporations (Include the column 10 results in column 6(b) of Part II above.)
1. Name of Sixth-Tier Foreign
Corporation and Its Related
Fifth-Tier Foreign Corporation

2. Tax Year
End
(Yr-Mo)
(see
instructions)

3. Country of
Incorporation (enter
country code from
instructions)

5. Opening
4. Post-1986
Balance in
Undistributed Earnings
Post-1986
(in functional
Foreign Income
currency—attach
Taxes
schedule)

6. Foreign Taxes
Paid For Tax Year
Indicated

7. Post-1986
Foreign Income
Taxes (add
columns 5 and 6)

8. Dividends Paid (in
functional currency)
(a) Of
Sixth-tier
CFC

(b) Of
Fifth-tier
CFC

9. Divide
Column
8(a) by
Column 4

10. Tax Deemed
Paid (multiply
column 7 by
column 9)

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 6 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
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FLAT SIZE: 216mm (8 ⁄2 ") x 279mm (11")
PERFORATE: None
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Form 1118 (Rev. 12-2004)

Schedule F

Page

Gross Income and Definitely Allocable Deductions for Foreign
Branches

1. Name of Foreign Country or U.S.
Possession (Use a separate line for each.)

2. Gross Income

3. Definitely Allocable
Deductions

A

Schedule G
A
B

B

Reductions of Taxes Paid, Accrued, or Deemed Paid

Reduction of Taxes Under Section 901(e)—Attach
separate schedule
Reduction of Oil and Gas Extraction Taxes—Enter
amount from Schedule I, Part II, line 6

C

Reduction of Taxes Due to International Boycott Provisions—
Enter appropriate portion of Schedule C (Form 5713), line 2b.
Important: Enter only “specifically attributable taxes” here.

D

Reduction of Taxes for Section 6038(c) Penalty—
Attach separate schedule

E

Other Reductions of Taxes—Attach schedule(s)

C
D
E
F

Totals (add lines A through F)*

䊳

* Note: The Schedule F totals are not carried over to any other Form 1118 Schedule. (These totals were already included in
Schedule A.) However, the IRS requires the corporation to complete Schedule F under the authority of section 905(b).

Total (add lines A through E). Enter here and on Schedule
䊳
B, Part II, line 3

6

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 7 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
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PERFORATE: None
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Page

Form 1118 (Rev. 12-2004)

Schedule H

Apportionment of Deductions Not Definitely Allocable (complete only once)

Part I—Research and Development Deductions
(b) Gross Income Method—Check method used:

(a) Sales Method
Product line #1 (SIC Code:
(i) Gross Sales

1

Totals (see pages 8 and 9 of
instructions)

2

Total to be apportioned

3

Apportionment among statutory
groupings:

(ii) R&D Deductions

a General limitation income
b Passive income
c High withholding tax interest
d Financial services income
e Shipping income
f Taxable income attributable to
foreign trade income
g Section 901(j) income*
h Income re-sourced by treaty*
4

)*

Total foreign (add lines 3a through 3h)

*Important: See Computer-Generated Schedule H in instructions.

Product line #2 (SIC Code:
(iii) Gross Sales

(iv) R&D
Deductions

)*

(v) Total R&D
Deductions Under
Sales Method (add
columns (ii) and (iv))

(See page 9 of

Option 1

Option 2 instructions.)
(vii) Total R&D
(vi) Gross Income
Deductions Under
Gross Income Method

(c) Total R&D
Deductions Not
Definitely Allocable
(enter all amounts
from column (a)(v)
or all amounts from
column (b)(vii))

7

4
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1118, PAGE 8 OF 8
MARGINS; TOP 13mm (1⁄2 "), CENTER SIDES.
PRINTS: HEAD TO HEAD
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INK: BLACK
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FLAT SIZE: 216mm (8 ⁄2 ") x 279mm (11")
PERFORATE: None
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Form 1118 (Rev. 12-2004)

Schedule H

Page

Apportionment of Deductions Not Definitely Allocable (continued)

Part II—Interest Deductions, All Other Deductions, and Total Deductions
(a) Average Value of Assets—Check method used:
Fair market value

Tax book value

(b) Interest Deductions

Alternative tax book value
(i) Nonfinancial
Corporations

(ii) Financial Corporations

1a Totals (see pages 9 and 10 of instructions)
b Amounts specifically allocable under Temp. Regs.
1.861-10T(e)
c Other specific allocations under Temp. Regs. 1.861-10T
d Assets excluded from apportionment formula
2

Total to be apportioned (subtract the sum of lines 1b, 1c,
and 1d from line 1a)

3

Apportionment among statutory groupings:
a General limitation income

b Passive income
c High withholding tax interest
d Financial services income
e Shipping income
f Taxable income attributable to foreign trade income
g Certain distributions from a FSC or former FSC
h Dividends from a DISC or former DISC
i Section 901(j) income*
j Income re-sourced by treaty*
4

Total foreign (add lines 3a through 3j)

* Important: See Computer-Generated Schedule H in instructions.
Printed on recycled paper

(iii) Nonfinancial
Corporations

(iv) Financial
Corporations

(c) All Other
Deductions Not
Definitely Allocable

(d) Totals (add the
corresponding
amounts from
column (c), Part I;
columns (b)(iii) and
(b)(iv), Part II; and
column (c), Part II).
Enter each amount
from lines 3a
through 3j below in
column 10 of the
corresponding
Schedule A.

8