1120-F U.S. Income Tax Return of a Foreign Corporation

9
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I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 1 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE, WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 279mm (11")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

1120-F

For calendar year 2007, or tax year beginning
©

Revised proofs
requested

OMB No. 1545-0126

, 2007, and ending

2007

, 20

See separate instructions.

Employer identification number

Name
Number, street, and room or suite no. (see instructions)

Check box(es) if:

City or town, state and ZIP code, or country (see instructions)

I

J

(3) If the corporation maintains an office or place of business in the
©
United States, check here

Did the corporation file a U.S. income tax return for
the preceding tax year?

(2) If “Yes,” is taxpayer’s trade or business within the
United States solely the result of a section 897
(FIRPTA) sale or disposition?

(1) Type of agent

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L At any time during the tax year, did the corporation
have a permanent establishment in the United States
for purposes of any applicable tax treaty between the
United States and a foreign country?

F See page 22 of the instructions and enter the corporation’s principal:

(3) Product or service

©

©

G Check method of accounting:
(3)
Other (specify) ©

(1)

No

K (1) At any time during the tax year, was the corporation
engaged in a trade or business in the United States?

E If the corporation had an agent in the United States at any time during
the tax year, enter:

©

Protective return

If “Yes,” attach an explanation.

(2) Principal location of worldwide business

(1) Business activity code number

Amended return

Schedule M-3 attached

Did the corporation’s method of determining income
change from the preceding tax year?

D (1) Location of corporation’s primary books and records (city, province
or state, and country)

(3) Address

Final return

First post-merger return

If “Yes,” attach an explanation.

C Date incorporated

(2) Name

Initial return

Name or address change

H Did the corporation’s method of accounting change Yes
from the preceding tax year?

A Country of incorporation
B Foreign country under whose laws the income reported on this return
is also subject to tax

(2) Business activity

Signature

O.K. to print

U.S. Income Tax Return of a Foreign Corporation

Department of the Treasury
(77)
Internal Revenue Service

Use
IRS
label.
Otherwise,
print or
type.

Date

Ref. checks = Rev. Rul. XX-XX

Changes & additions = yellow highlighting
Form

Action

If “Yes,” enter the name of the foreign country:

Cash

(2)

M Did the corporation have any transactions with
related parties?

Accrual

If “Yes,” Form 5472 may have to be filed (see instructions).

Enter number of Forms 5472 attached ©
Note: Additional information is required on page 2.

Computation of Tax Due or Overpayment

1

Tax from Section I, line 11, page 2

1

2

Tax from Section II, Schedule J, line 9, page 4

2

3
4

Tax from Section III (add lines 6 and 10 on page 5)
Total tax. Add lines 1 through 3
5a
2006 overpayment credited to 2007

3

5a

old line
5i
deleted

4

5b

b

2007 estimated tax payments

c

Less 2007 refund applied for on Form 4466

d

Combine lines 5a through 5c

e

Tax deposited with Form 7004

f

Credit for tax paid on undistributed capital gains (attach Form 2439)

g

Credit for federal tax on fuels (attach Form 4136). See instructions

5f
5g

h

U.S. income tax paid or withheld at source (add line 12, page 2, and
amounts from Forms 8288-A and 8805 (attach Forms 8288-A and 8805))

5h

i

Total payments. Add lines 5d through 5h

5c

(

)

5d
5e

5i
©

6

Estimated tax penalty (see instructions). Check if Form 2220 is attached

7
8
9

Amount owed. If line 5i is smaller than the total of lines 4 and 6, enter amount owed
Overpayment. If line 5i is larger than the total of lines 4 and 6, enter amount overpaid
Enter portion of line 8 you want Credited to 2008 estimated tax ©

Sign
Here

6
7
8

Refunded

©

9

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true,
correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.

Signature of officer

Paid
Preparer’s
Use Only

May the IRS discuss this return
with the preparer shown below
(see instructions)?
Yes
No

©

©
Preparer’s
signature

Date

Date

©

Firm’s name (or
yours if self-employed),
address, and ZIP code

Title

©

For Privacy Act and Paperwork Reduction Act Notice, see instructions.

Preparer’s SSN or PTIN

Check if
self-employed
EIN
Phone no.
Cat. No. 11470I

(

)
Form

1120-F

(2007)

9
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 2 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE, WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 279mm (11")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Former items T & V deleted. Item T is now Question 11 of Sect. III.
Form 1120-F (2007)

Page

Additional Information (continued from page 1)

U At the end of the tax year, did any individual, partnership, Yes
corporation, estate, or trust own, directly or indirectly,
50% or more of the corporation’s voting stock? (See
section 267(c) for rules of attribution.)

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N Is the corporation a controlled foreign corporation?
(See section 957(a) for definition.)

Yes

No

O Is the corporation a personal service corporation?
(See instructions for definition.)
P Enter tax-exempt interest received or accrued during
the tax year (see instructions) © $

If “Yes,” attach a schedule showing the name and
identifying number. (Do not include any information
already entered in item T.)

Q At the end of the tax year, did the corporation own,
directly or indirectly, 50% or more of the voting stock
of a U.S. corporation? (See section 267(c) for rules
of attribution.)

V Is the corporation taking a position on this return that a U.S.
tax treaty overrules or modifies an Internal Revenue law of
the United States, thereby causing a reduction of tax?

Enter percentage owned

Note: Failure to disclose a treaty-based return position
may result in a $10,000 penalty (see section 6712).

W During the tax year, did the corporation own any entity
that was disregarded as an entity separate from its owner
under Regulations sections 301.7701-2 and 301.7701-3?

R If the corporation has an NOL for the tax year
and is electing to forego the carryback period,
©
check here

If “Yes,” attach a statement listing the name, country under whose
laws the entity was organized, and EIN (if any) of each such entity.

X During the tax year, did the corporation own at least a 10%
interest, directly or indirectly, in any foreign partnership?

S Enter the available NOL carryover from prior tax
years. (Do not reduce it by any deduction on line 30a,
page 3.) © $

If “Yes,” see instructions for required attachment.

Y (1) Has the corporation made any allocation or reallocation
of income based on section 482 and its regulations?

T Is the corporation a subsidiary in a parent-subsidiary
controlled group?
If “Yes,” enter the parent corporation’s:
(1) EIN

©

If “Yes,” the corporation is generally required to complete
and attach Form 8833. See Form 8833 for exceptions.

If “Yes,” attach a schedule showing (1) name and
EIN of such U.S. corporation; (2) percentage owned;
and (3) taxable income or (loss) before net operating
loss (NOL) and special deductions of such U.S.
corporation for the tax year ending with or within your
tax year.

(2) Has the corporation recognized any interbranch
amounts? If “Yes,” attach statement (see instructions)

©

(2) Name

2

No

Z (1) Is the corporation a dealer under section 475?
©

(2) Did the corporation mark to market any securities or
commodities other than in a dealer capacity?

SECTION I— Income From U.S. Sources Not Effectively Connected With the Conduct of a Trade or Business
in the United States—Do not report items properly withheld and reported on Form 1042-S. See instructions.
Include below only income from U.S. sources that is not effectively connected with the conduct of a trade or business in the United States. Do
not report items properly withheld and reported on Form 1042-S. Report only items that (a) are not correctly withheld at source or (b) are not
correctly reported on Form 1042-S. The rate of tax on each item of gross income listed below is 30% (4% for the gross transportation tax) or such
lower rate specified by tax treaty. No deductions are allowed against these types of income. Enter treaty rates where applicable. If the corporation
is claiming a lower treaty rate, also complete Item V above. If multiple treaty rates apply to a type of income (e.g., subsidiary and portfolio
dividends or dividends received by disregarded entities), attach a schedule showing the amounts, tax rates, and withholding for each.

Name of treaty country, if any

©

(a)
Class of income (see instructions)

(b)
Gross amount

(c)
Rate of tax (%)

(d)
Amount of tax liability

(e)
Amount of U.S. income tax
paid or withheld at the source

1 Interest
2 Dividends
3 Rents
4 Royalties
5 Annuities
6 Gains from disposal of timber, coal, or
domestic iron ore with a retained economic
interest (attach supporting schedule)
7 Gains from sale or exchange of patents,
copyrights, etc.
8 Fiduciary distributions (attach supporting schedule)
9 Gross transportation income

4

10 Other fixed or determinable annual or
periodic gains, profits, and income

11 Total. Enter here and on line 1, page 1
12 Total. Enter here and include on line 5h, page 1

©
©

13 Is the corporation fiscally transparent under the laws of the foreign jurisdiction with respect to any item of income listed above?
If “Yes,” attach a schedule that provides the information requested above with respect to each such item of income.

Yes
Form

1120-F

No
(2007)

9
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 3 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE, WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 279mm (11")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Form 1120-F (2007)
Page 3
SECTION II—Income Effectively Connected With the Conduct of a Trade or Business in the United States
(see instructions)

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Important: Fill in all applicable lines and schedules. If you need more space, see Assembling the Return in the instructions.

Former
lines
21 and
22
deleted

Deductions (See instructions for limitations on deductions.)

Income

1a Gross receipts or sales

b Less returns and allowances

c Bal

1c

©

2

2

Cost of goods sold (Schedule A, line 8)

3

Gross profit (subtract line 2 from line 1c)

3

4

Dividends (Schedule C, line 14)

4

5

Interest

6

Gross rents

7
8

Gross royalties
Capital gain net income (attach Schedule D (Form 1120))

7

9
10
11

Net gain or (loss) from Form 4797, Part II, line 17 (attach Form 4797)
Other income (see instructions—attach schedule)
Total income. Add lines 3 through 10

9
10

12

Compensation of officers (Schedule E, line 4)

12

13
14
15

Salaries and wages (less employment credits)
Repairs and maintenance
Bad debts (for bad debts over $500,000, attach a list of debtors and amounts)

13

16
17

Rents
Taxes and licenses

16

18

Interest expense from Schedule I, line 25

18

19
20

Charitable contributions
Depreciation from Form 4562 not claimed on Schedule A or elsewhere on return (attach Form 4562)

19

21
22

Depletion

21

Advertising

22

23

Pension, profit-sharing, etc., plans

23

24

Employee benefit programs

24

25

Domestic production activities deduction (attach Form 8903)

25

26

Deductions allocated and apportioned to ECI from Schedule H, line 21 (see instructions)

26

27
28

Other deductions (attach schedule)

29

Taxable income before NOL deduction and special deductions (subtract line 28 from line 11)
30a
Less: a Net operating loss deduction (see instructions)

30

5

8

©

14
15

20

©

27
28
29

30b

Taxable income or (loss). Subtract line 30c from line 29

Schedule A

11

17

Total deductions. Add lines 12 through 27

b Special deductions (Schedule C, line 15)
c Add lines 30a and 30b
31

6

30c
31

Cost of Goods Sold (see instructions)

1

Inventory at beginning of year

1

2
3

Purchases
Cost of labor

2

4

Additional section 263A costs (attach schedule)

4

5

Other costs (attach schedule)

5

6
7

Add lines 1 through 5

6

Inventory at end of year
Cost of goods sold. Subtract line 7 from line 6. Enter here and on Section II, line 2, above

7

8

3

8

9a Check all methods used for valuing closing inventory:
(1)
(2)
(3)

Cost as described in Regulations section 1.471-3
Lower of cost or market as described in Regulations section 1.471-4
Other (Specify method used and attach explanation.) ©

b Check if there was a writedown of subnormal goods as described in Regulations section 1.471-2(c)

©

c Check if the LIFO inventory method was adopted this tax year for any goods (if checked, attach Form 970)

©

d If the LIFO inventory method was used for this tax year, enter percentage (or amounts) of closing inventory
computed under LIFO
e If property is produced or acquired for resale, do the rules of section 263A apply to the corporation?

9d

f Was there any change in determining quantities, cost, or valuations between opening and closing inventory?
If “Yes,” attach explanation.
Form

Yes

No

Yes

No

1120-F

(2007)

9
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 4 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE, WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 279mm (11")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Page 4
SECTION II—Income Effectively Connected With the Conduct of a Trade or Business in the United States
(continued)
Schedule C Dividends and Special Deductions (see instructions)

Form 1120-F (2007)

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(a) Dividends
received

1 Dividends from less-than-20%-owned domestic corporations (other than
debt-financed stock)

(b) %

(c) Special deductions:
(a) 3 (b)

70

2 Dividends from 20%-or-more-owned domestic corporations (other than
debt-financed stock)

80

see
instructions

3 Dividends on debt-financed stock of domestic and foreign corporations (section 246A)
4 Dividends on certain preferred stock of less-than-20%-owned public utilities

42
48
70
80

5 Dividends on certain preferred stock of 20%-or-more-owned public utilities
6 Dividends from less-than-20%-owned foreign corporations
7 Dividends from 20%-or-more-owned foreign corporations

8 Total. Add lines 1 through 7. See instructions for limitation

9 Dividends from foreign corporations not included on lines 3, 6, or 7
10 Foreign dividend gross-up (section 78)

11 IC-DISC and former DISC dividends not included on lines 1, 2, or 3 (section 246(d))
12 Other dividends

13 Deduction for dividends paid on certain preferred stock of public utilities
14 Total dividends. Add lines 1 through 12. Enter here and on line 4, page 3
15 Total special deductions. Add lines 8 and 13. Enter here and on line 30b, page 3

Schedule E

(a) Name of officer

(b) Social security
number

(c) Percent of
time devoted
to business

Percent of corporation
stock owned
(d) Common
(e) Preferred

1a

%

%

%

b

%

%

%

c

%
%

%
%

%
%

%

%

%

d
e
2
3
4

(f) Amount of
compensation

Total compensation of officers
Compensation of officers claimed on Schedule A and elsewhere on this return
Subtract line 3 from line 2. Enter the result here and on line 12, page 3

Schedule J

Former
line 5b
deleted

©

Compensation of Officers (See instructions for Section II, line 12.)
Note: Complete Schedule E only if total receipts (line 1a plus lines 4 through 10 of Section II) are
$500,000 or more.

Tax Computation (see instructions)

1

Check if the corporation is a member of a controlled group (attach Schedule O (Form 1120))

©

2
3

Income tax. Check if a qualified personal service corporation (see instructions)

©

Alternative minimum tax (attach Form 4626)

4

Add lines 2 and 3

5a Foreign tax credit (attach Form 1118)
b General business credit. Check applicable box(es):
Form (specify):
Form 3800
c Credit for prior year minimum tax (attach Form 8827)
Form 8860
Form 8912
d Bond credits from:

2
3
4

5a
5b
5c
5d

6

Total credits. Add lines 5a through 5d

6

7

Subtract line 6 from line 4

7

8

Other taxes. Check if from:

9

Form 4255
Form 8611
Form 8866
Form 8902
Total tax. Add lines 7 and 8. Enter here and on line 2, page 1

Form 8697
Other (attach schedule)

8
9
Form

Check boxes for Forms 8835, 6478, and
8844 deleted.

1120-F

(2007)

9
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 5 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE,WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 276mm (107⁄ 8 ")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Form 1120-F (2007)

Page

5

SECTION III—Branch Profits Tax and Tax on Excess Interest
Part I—Branch Profits Tax (see instructions)
1

1

Enter the amount from Section II, line 29

2

Enter total adjustments to line 1 to get effectively connected earnings and profits. (Attach required schedule
showing the nature and amount of adjustments.) (See instructions.)

3

Effectively connected earnings and profits. Combine line 1 and line 2

4a Enter U.S. net equity at the end of the current tax year. (Attach required schedule.)
b Enter U.S. net equity at the end of the prior tax year. (Attach required schedule.)

5
6

2
3
4a
4b

c Increase in U.S. net equity. If line 4a is greater than or equal to line 4b, subtract line 4b from line 4a. Enter
the result here and skip to line 4e

4c

d Decrease in U.S. net equity. If line 4b is greater than line 4a, subtract line 4a from line 4b

4d

e Non-previously taxed accumulated effectively connected earnings and profits. Enter excess, if any, of
effectively connected earnings and profits for preceding tax years beginning after 1986 over any dividend
equivalent amounts for those tax years

4e

Dividend equivalent amount. Subtract line 4c from line 3. If zero or less, enter -0-. If no amount is entered
on line 4c, add the lesser of line 4d or line 4e to line 3 and enter the total here

5

Branch profits tax. Multiply line 5 by 30% (or lower treaty rate if the corporation is a qualified resident or
otherwise qualifies for treaty benefits). Enter here and include on line 3, page 1. (See instructions.) Also
complete item V on page 2

6

Part II—Tax on Excess Interest (see instructions for this Part and for Schedule I)
7a

7a Enter the interest from Section II, line 18

8

b Enter the inverse of the total amount deferred, capitalized, and disallowed from Schedule I, line 24d
(i.e, if line 24d is negative, enter as a positive number; if line 24d is positive, enter as a negative number).

7b

c Combine lines 7a and 7b (amount must equal Schedule I, line 23).

7c

Branch Interest (see instructions for definition): Enter the sum of Schedule I, line 9, column (c), and Schedule I, line
22. If the interest paid by the foreign corporation’s U.S. trade or business was increased because 80% or more of
©
the foreign corporation’s assets are U.S. assets, check this box

9a Excess interest. Subtract line 8 from line 7c. If zero or less, enter -0-

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b If the foreign corporation is a bank, enter the excess interest treated as interest on deposits. Otherwise, enter
-0-. (See instructions.)
c Subtract line 9b from line 9a
10

Tax on excess interest. Multiply line 9c by 30% or lower treaty rate (if the corporation is a qualified resident
or otherwise qualifies for treaty benefits). (See instructions.) Enter here and include on line 3, page 1. Also
complete item V on page 2

Part III—Additional Information
11

8
9a
9b
9c

10

Yes

No

Is the corporation claiming a reduction in, or exemption from, the branch profits tax due to:
a A complete termination of all U.S. trades or businesses?

b The tax-free liquidation or reorganization of a foreign corporation?
c The tax-free incorporation of a U.S. trade or business?

If 11a or 11b applies and the transferee is a domestic corporation, attach Form 8848. If 11c applies, attach the statement required
by Temporary Regulations section 1.884-2T(d)(5).
Form

1120-F

(2007)

9
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 1120F, PAGE 6 of 6
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: HEAD TO FOOT
PAPER: WHITE, WRITING, SUB. 20
INK: BLACK
FLAT SIZE: 216mm (81⁄ 2 ") 3 835mm (327⁄ 8 "), FOLD TO: 216mm (81⁄ 2 ") 3 276mm (107⁄ 8 ")
PERFORATE: ON FOLDS
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Form 1120-F (2007)

Page

Note: Check if completing on

Schedule L

©

U.S. basis or a

©

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Balance Sheets per Books

Beginning of tax year

Assets
1

6

Worldwide basis.

Cash

2a Trade notes and accounts receivable
b Less allowance for bad debts
3

Inventories

4

U.S. government obligations

5

Tax-exempt securities (see instructions)

6a Interbranch current assets*
b Other current non-U.S. assets*
c Other current U.S. assets*
7

Loans to shareholders

8

Mortgage and real estate loans

9a Other loans and investments—non-U.S.
assets*
b Other loans and investments—U.S.
assets*
10a Buildings and other depreciable
assets
b Less accumulated depreciation

(a)

End of tax year

(b)

(c)

(

)

(

)

(

)

(

)

(

)

(

)

(

)

(

)

(d)

11a Depletable assets
b Less accumulated depletion
12

Land (net of any amortization)

13a Intangible assets (amortizable only)
b Less accumulated amortization
14

Assets held in trust

15

Other non-current interbranch assets*

16a Other non-current non-U.S. assets*
b Other non-current U.S. assets*
17 Total assets
Liabilities
18

Accounts payable

19

Mortgages, notes, bonds payable in less
than 1 year:
a Interbranch liabilities*
b Third-party liabilities*

20
21

Other current liabilities*
Loans from shareholders

22

Mortgages, notes, bonds payable in 1 year
or more:
a Interbranch liabilities*
b Third-party liabilities*

23 Liabilities held in trust
24a Other interbranch liabilities*
b Other third-party liabilities*
Equity (see instructions)
25

Capital stock:

a Preferred stock

26

Additional paid-in capital

27
28

Retained earnings—Appropriated*
Retained earnings—Unappropriated

29
30
31

Adjustments to shareholders’ equity*
Less cost of treasury stock
Total liabilities and shareholders’ equity

b Common stock

(

)

*Attach schedule—See instructions.

(

)
Form

Former Schedules M-1 and M-2 deleted and converted to separate Schedules
Printed on recycled paper

1120-F

(2007)