Form Schedule O (Form 1 Schedule O (Form 1 Consent Plan and Apportionment Schedule for a Controlled

Schedule O (Form 1120), Consent Plan and
Apportionment Schedule for a Controlled Group
(Rev. December 2009)
Purpose: This is the first circulated draft of the Schedule O (Form 1120) (Rev.
December 2009) for your review and comments. See below for a discussion of the
major changes.
TPCC Meeting: None, but one may be arranged if requested.
Prior Version: The Schedule O (Form 1120) (Rev. December 2008) is available at:
http://www.irs.gov/pub/irs-pdf/f1120so.pdf.
Instructions: The Instructions for Schedule O (Form 1120) (Rev. December 2009) will
be circulated at a later date. The December 2008 revision is available at
http://www.irs.gov/pub/irs-pdf/i1120so.pdf.
Other Products: Circulations of draft tax forms, instructions, notices, and publications
are posted at:
http://taxforms.web.irs.gov/Circulations/index.htm.
Comments: Please email, fax, call, or mail any comments by July 1, 2009, to me at
the address below and email the reviewer at [email protected].
Emile R. Beausejour
Tax Forms and Publications
SE:W:CAR:MP:T:B:C
Email: [email protected]
Phone: 202-622-8003
Fax: 202-622-3262

Major Changes
New line 4 was added to clarify if the termination on line 3c or 3d was voluntary or
involuntary.
Renumbered old lines 4, 5, and 6 to now read lines 5, 6, and 7.

1

For line 7:
• The lead-in sentence was changed from “Elections under section 1561. See
instructions” now reads “Required information and elections. Check the applicable
box(es) (see instructions).”
• The apportionment of tax items is different if only one or more members of the group
has a short tax year that does not include December 31. Line 7c was added to
identify such a member and clarify how the allocations on pages 2 and 3 were
determined.
All changes were made at the request of the Chief Counsel and Schedule O work
group.

2

Version A, Cycle 1

Consent Plan and Apportionment Schedule
for a Controlled Group

SCHEDULE O
(Form 1120)
(Rev. December 2009)

Department of the Treasury
Internal Revenue Service
Name

Part I

 Attach

OMB No. 1545-0123

to Form 1120, 1120-C, 1120-F, 1120-FSC, 1120-L, 1120-PC, 1120-REIT, or 1120-RIC.
 See separate instructions.
Employer identification number

Apportionment Plan Information

1

Type of controlled group:
a
Parent-subsidiary group
b
Brother-sister group
c
Combined group
d
Life insurance companies only

2
This corporation has been a member of this group:
a
For the entire year.
From
, 20
, until
b
3
a

DRAFT AS OF
May 28, 2009
, 20

.

This corporation consents and represents to:
Adopt an apportionment plan. All the other members of this group are adopting an apportionment plan effective for
the current tax year which ends on
, 20
, and for all succeeding tax years.
b
Amend the current apportionment plan. All the other members of this group are currently amending a previously
adopted plan, which was in effect for the tax year ending
, 20
, and for all succeeding tax
years.
c
Terminate the current apportionment plan and not adopt a new plan. All the other members of this group are not adopting
an apportionment plan.
d
Terminate the current apportionment plan and adopt a new plan. All the other members of this group are adopting
an apportionment plan effective for the current tax year which ends on
, 20
, and for all
succeeding tax years.

4

If you checked box 3c or 3d above, check the applicable box below to indicate if the termination of the current apportionment
plan was:
a
Voluntary
b
Involuntary

5

If you did not check a box on line 3 above, check the applicable box below concerning the status of the group’s apportionment
plan (see instructions).
a
No apportionment plan is in effect and none is being adopted.
b
An apportionment plan is already in effect. It was adopted for the tax year ending
, 20
, and
for all succeeding tax years.

6

If all the members of this group are adopting a plan or amending the current plan for a tax year after the due date
(including extensions) of the tax return for this corporation, is there at least one year remaining on the statute of limitations
from the date this corporation filed its amended return for such tax year for assessing any resulting deficiency?
See instructions.
a
Yes.
(i)
The statute of limitations for this year will expire on
, 20
.
(ii)
On
, 20
, this corporation entered into an agreement with the
Internal Revenue Service to extend the statute of limitations for purposes of assessment until
, 20
.
b
No. The members may not adopt or amend an apportionment plan.

7
a

Required information and elections under section 1561. Check the applicable box(es) (see instructions).
The corporation will determine its tax liability by applying the maximum tax rate under section 11 to the entire amount of its
taxable income.
b
The corporation and the other members of the group elect the FIFO method (rather than defaulting to the proportionate
method) for allocating the group’s section 11(b)(1) additional tax.
The corporation has a short tax year that does not include December 31.
c

For Privacy Act and Paperwork Reduction Act Notice,
see Instructions for Form 1120.

Cat. No. 48100N

Schedule O (Form 1120) (Rev. 12-2009)

Total

10

9

8

7

6

5

4

3

2

1

(a)
Group member’s name and
employer identification number

Schedule O (Form 1120) (Rev. 12-2009)

(c)
15%

(d)
25%

DRAFT AS OF
May 28, 2009

(b)
Tax year end
(Yr-Mo)
(e)
34%

(g)
Total (add columns
(c) through (f))

Schedule O (Form 1120) (Rev. 12-2009)

(f)
35%

Taxable Income Amount Allocated to
Each Bracket

Page 2
Part II
Taxable Income Apportionment (See instructions)
Caution: Each total in Part II, column (g) for each component member must agree with Form 1120, page 1, line 30 or the comparable line of such member’s
tax return.

Version A, Cycle 1

Total

10

9

8

7

6

5

4

3

2

1

Part III

(a)
Group member’s name

(c)
25%

(d)
34%

(e)
35%

(f)
5%

Income Tax Apportionment

DRAFT AS OF
May 28, 2009

(b)
15%

Income Tax Apportionment (See instructions)

Schedule O (Form 1120) (Rev. 12-2009)

(g)
3%

Schedule O (Form 1120) (Rev. 12-2009)

(h)
Total income tax
(combine lines
(b) through (g))

Page 3

Version A, Cycle 1

Total

10

9

8

7

6

5

4

3

2

1

Part IV

(a)
Group member’s name
(c) AMT
exemption amount

(d) Phaseout of
AMT exemption
amount

Other Apportionments
(e) Penalty for failure
to pay estimated tax

DRAFT AS OF
May 28, 2009

(b) Accumulated
earnings credit

Other Apportionments (See instructions)

Schedule O (Form 1120) (Rev. 12-2009)

Schedule O (Form 1120) (Rev. 12-2009)

(f)
Other

Page 4

Version A, Cycle 1