Form 1120-F (Sched Exclusion of Income From the International Operation of

SCHEDULE S
(Form 1120-F)

Exclusion of Income From the International
Operation of Ships or Aircraft Under Section 883

Department of the Treasury
Internal Revenue Service



1a
b

c
2

a
b
c
d
e
f

2009

Attach to Form 1120-F.

Name of corporation

Part I

OMB No. 1545-0126

Employer identification number

Qualified Foreign Corporation

Enter the name of the qualified foreign country in which the foreign corporation was organized



Check one (and only one) of the following boxes to indicate the type of equivalent exemption granted by the foreign
country listed on line 1a above:
Domestic law
Exchange of notes
Income tax convention
Enter the applicable authority (i.e., the specific provision) of the equivalent exemption type indicated on line 1b (see
instructions) 
Enter the gross income in each of the following categories of qualified income for which the exemption is being claimed:
Note. If an amount is not readily determinable, enter a reasonable estimate. If an estimate is used on any of the lines
below, check here 
2a
Income from the carriage of passengers and cargo
2b
Time or voyage (full) charter income of a ship or wet lease income of an aircraft
2c
Bareboat charter income of a ship or dry lease income of an aircraft
2d
Incidental bareboat charter income of a ship or incidental dry lease income of an aircraft
2e
Incidental container-related income
Income incidental to the international operation of ships or aircraft other than incidental income
included on lines 2d and 2e above

2f

g Capital gains derived by a qualified foreign corporation engaged in the international operation of
ships or aircraft from the sale, exchange or other disposition of a ship, aircraft, container or
related equipment or other moveable property used by that qualified foreign corporation in the
international operation of ships or aircraft

2g

h

Income from participation in a pool, partnership, strategic alliance, joint operating agreement,
code-sharing arrangement, international operating agency, or other joint venture described in
Regulations section 1.883-1(e)(2)

2h

Stock ownership test of Regulations section 1.883-1(c)(2):
3

4
5

Check one (and only one) of the following boxes to indicate the test under which the stock ownership test of Regulations
section 1.883-1(c)(2) was satisfied:
The publicly-traded test of Regulations section 1.883-2(a). Complete Part II.
The CFC stock ownership test of Regulations section 1.883-3(a). Complete Part III.
The qualified shareholder stock ownership test of Regulations section 1.883-4(a). Complete Part IV.
Check the box if any of the shares of the foreign corporation’s stock or the stock of any direct, indirect, or constructive
shareholder are issued in bearer form
If the box on line 4 is checked, check the box on this line 5 if none of the bearer shares were relied on to satisfy any of the
stock ownership tests described in Regulations section 1.883-1(c)(2)

Part II

Stock Ownership Test for Publicly-Traded Corporations

6
7
8

Enter the name of the country in which the stock is primarily traded 
Enter the name of the securities market(s) on which the stock is listed 
Enter a description of each class of stock relied on to meet the “regularly traded test” of Regulations section 1.883-2(d)
(see instructions for description requirements) 

9

Do one or more 5% shareholders (see instructions for definition) own in the aggregate 50% or more
of the vote and value of the outstanding shares of any class of stock for more than half the number of days during
the tax year?
Yes
No
If “Yes,” complete line 10.
If “No,” skip line 10.
For each class of stock relied on to meet the “regularly traded test” of Regulations section 1.883-2(d), indicate:
(i) The days during the tax year of the corporation in which the class of stock was closely held, without regard to the
exception in Regulations section 1.883-2(d)(3)(ii) 
(ii) The total percentage of the vote and value of the class of stock that is owned by 5% shareholders during
%
such days 

10
a

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

Cat. No. 50766D

Schedule S (Form 1120-F) 2009

Page

Schedule S (Form 1120-F) 2009

b

2

For all qualified shareholders on which the corporation intends to rely to satisfy the closely-held exception test of
Regulations section 1.883-2(d)(3), and who own stock in the closely-held block (directly, indirectly, or by applying the
attribution rules of Regulations section 1.883-4(c)), enter:
(i) The total number of qualified shareholders, as defined in Regulations section 1.883-4(b)(1) 
(ii) The total percentage of the value of the shares of the class of stock owned, directly or indirectly, by such qualified
shareholders by country of residence (see instructions):
Country code (see instructions)

Percentage

(iii) The days during the tax year of the corporation that such qualified shareholders owned, directly or indirectly, their shares
in the closely-held block of stock 

Part III
11

Stock Ownership Test for Controlled Foreign Corporations

12

Enter the percentage of the value of the shares of the CFC that is owned by all “qualified U.S. persons” identified in the
qualified ownership statements required under Temporary Regulations section 1.883-3T(c)(2), applying the attribution of
%
ownership rules of Temporary Regulations section 1.883-3T(b)(4) 
Enter the period during which such qualified U.S. persons held such stock (see instructions) 

13

Enter the period during which the foreign corporation was a CFC (see instructions)

14

Is the CFC directly held by qualified U.S. persons?

Part IV
15

16
a



Yes

No

Qualified Shareholder Stock Ownership Test

Check the box if more than 50% of the value of the outstanding shares of the corporation is owned (or treated as owned
by reason of Regulations section 1.883-4(c)) by qualified shareholders for each category of income for which the
exemption is claimed
With respect to all qualified shareholders relied on to satisfy the 50% ownership test of Regulations section 1.883-4(a):
Enter the total number of such qualified shareholders as defined in Regulations section 1.883-4(b)(1)



b Enter the total percentage of the value of the outstanding shares owned, applying the attribution rules of Regulations
section 1.883-4(c), by such qualified shareholders by country of residence or organization, whichever is applicable:
Country code (see instructions)

c

Percentage

Enter the period during the tax year of the foreign corporation that such stock was held by qualified shareholders 

Schedule S (Form 1120-F) 2009