Foreign Tax Credit Corporations

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Instructions for Form 1118
(Rev. December 2013)

Department of the Treasury
Internal Revenue Service

Foreign Tax Credit—Corporations
Section references are to the Internal Revenue
Code unless otherwise noted.

Future Developments
For the latest information about
developments related to Form 1118 and
its instructions, such as legislation
enacted after they were published, go to
www.irs.gov/form1118.

What's New
for 2013
Identifying numbers. On pages 3
through 8 of the form, two columns have
been added to Schedules C, D, and E.
New columns 1b request the employer
identification number of the distributing
foreign corporations and new columns 1c
request the reference ID number of these
corporations. See Reference ID numbers,
later for information on what to enter in
these columns.
Schedule C, Part I. On page 3 of the
form, columns 11 and 12 have been
added to Schedule C, Part I, to account for
taxes limited by section 960(c).
Previously, this limitation was entered on
the “Other reductions of taxes” line of
Schedule G.
Schedule G, Part I. On page 9 of the
form, new line E has been added to
Schedule G, Part I, to account for taxes
suspended under section 909. Previously,
this limitation was entered on the “Other
reductions of taxes” line of Schedule G.

General Instructions
Purpose of Form

Use Form 1118 to compute a
corporation's foreign tax credit for certain
taxes paid or accrued to foreign countries
or U.S. possessions. See Taxes Eligible
for a Credit, later.

Who Must File

Any corporation that elects the benefits of
the foreign tax credit under section 901
must complete and attach Form 1118 to
its income tax return.

When to Make the Election
The election to claim the foreign tax credit
(or a deduction in lieu of a credit) for any
tax year may be made or changed at any
time before the end of a special 10-year
period described in section 6511(d)(3) (or
section 6511(c) if the period is extended
by agreement).

Jun 28, 2013

Computer-Generated
Form 1118

The corporation may submit a
computer-generated Form 1118 and
schedules if they conform to the IRS
version. However, if a software program is
used, it must be approved by the IRS for
use in filing substitute forms. This ensures
the proper placement of each item
appearing on the IRS version. For more
information, see Pub. 1167, General Rules
and Specifications for Substitute Forms
and Schedules.

How To Complete
Form 1118
Important. Complete a separate
Schedule A; Schedule B, Parts I & II;
Schedules C through G; Schedule I; and
Schedule K for each applicable separate
category of income. See Categories of
Income later. Complete Schedule B, Part
III; Schedule H; and Schedule J only once.
Use Schedule A to compute the
corporation's income or loss before
adjustments for each applicable category
of income.
Use Schedule B to determine the total
foreign tax credit after certain limitations.
Use Schedule C to compute taxes
deemed paid by the domestic corporation
filing the return.
Use Schedules D and E to compute
taxes deemed paid by lower-tier foreign
corporations.
Use Schedule F to report gross income
and definitely allocable deductions from
foreign branches.
Use Schedule G to report required
reductions of tax paid, accrued, or
deemed paid.
Use Schedule H to apportion
deductions that cannot be definitely
allocated to some item or class of income.
Use Schedule I (a separate schedule)
to compute reductions of taxes paid,
accrued, or deemed paid on foreign oil
and gas extraction income.
Use Schedule J (a separate schedule)
to compute adjustments to separate
limitation income or losses in determining
the numerators of limitation fractions,
year-end recharacterization balances, and
overall foreign and domestic loss account
balances.
Use Schedule K (a separate schedule)
to reconcile the corporation's prior year
foreign tax carryover with its current year
foreign tax carryover.
Cat. No. 10905I

Categories of Income

Compute a separate foreign tax credit for
each applicable separate category
described below.

Passive Category Income

Passive category income includes passive
income and specified passive category
income.

Passive income. Generally, passive
income is:
Any income received or accrued that
would be foreign personal holding
company income (defined in section
954(c)) if the corporation were a controlled
foreign corporation (CFC) (defined in
section 957). This includes any gain on
the sale or exchange of stock that is more
than the amount treated as a dividend
under section 1248. However, in
determining if any income would be
foreign personal holding company income,
the rules of section 864(d)(6) will apply
only for income of a CFC.
Any amount includible in gross income
under section 1293 (which relates to
certain passive foreign investment
companies).
Passive income does not include:
Any financial services income that is
general category income (see General
Category Income, later),
Any export financing interest unless it is
also related person factoring income (see
section 904(d)(2)(G) and Temporary
Regulations section 1.904-4T(h)(3)),
Any high-taxed income (see General
Category Income and the instructions for
Schedule A, later), or
Any active rents or royalties. See
Temporary Regulations section
1.904-4T(b)(2)(iii) for definitions and
exceptions.
Note. Certain income received from a
CFC and certain dividends from a 10/50
corporation that would otherwise be
passive income may be assigned to
another separate category under the
look-through rules. See Look-Through
Rules, later.
Specified passive category income.
This term includes:
Dividends from a DISC or former DISC
(as defined in section 992(a)) to the extent
such dividends are treated as foreign
source income, and
Distributions from a former FSC out of
earnings and profits attributable to foreign
trade income or interest or carrying

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charges (as defined in section 927(d)(1),
before its repeal) derived from a
transaction which results in foreign trade
income (as defined in section 932(b),
before its repeal).

Section 901(j) Income

No credit is allowed for foreign taxes
imposed by and paid or accrued to certain
sanctioned countries. However, income
derived from each such country is subject
to a separate foreign tax credit limitation.
Therefore, the corporation must use a
separate Form 1118 for income derived
from each such country. On each Form
1118, check the box for section 901(j)
income at the top of page 1 and identify
the applicable country in the space
provided.
Sanctioned countries are those
designated by the Secretary of State as
countries that repeatedly provide support
for acts of international terrorism,
countries with which the United States
does not have diplomatic relations, or
countries whose governments are not
recognized by the United States. As of the
date these instructions were revised,
section 901(j) applied to income derived
from Cuba, Iran, North Korea, Sudan, and
Syria. For more information, see section
901(j).
Note. The President of the United States
has the authority to waive the application
of section 901(j) with respect to a foreign
country if it is (a) in the national interest of
the United States and will expand trade
and investment opportunities for U.S.
companies in such foreign country and (b)
the President reports to the Congress, not
less than 30 days before the waiver is
granted, the intention to grant such a
waiver and the reason for such waiver.
Note. Effective December 10, 2004, the
President waived the application of
section 901(j) with respect to Libya.
If the corporation paid taxes to a
country that ceased to be a sanctioned
country during the tax year, see Rev. Rul.
92-62, 1992-2 C.B. 193, for details on how
to figure the foreign tax credit for the
period that begins after the end of the
sanctioned period.

Income Re-sourced by Treaty

If a sourcing rule in an applicable income
tax treaty treats any U.S. source income
as foreign source, and the corporation
elects to apply the treaty, the income will
be treated as foreign source.
Important. The corporation must
compute a separate foreign tax credit
limitation for any such income for which it
claims benefits under a treaty, using a
separate Form 1118 for each amount of
re-sourced income from a treaty country.

On each Form 1118, check the box for
income re-sourced by treaty at the top of
page 1 and identify the applicable country
in the space provided. See sections
865(h), 904(d)(6), and 904(h)(10) and the
regulations under those sections
(including Regulations section 1.904-5(m)
(7)) for any grouping rules and exceptions.

General Category Income

This category includes all income not
described above. This includes high-taxed
income that would otherwise be passive
category income. Usually, income is
high-taxed if the total foreign income taxes
paid, accrued, or deemed paid by the
corporation for that income exceed the
highest rate of tax specified in section 11
(and with reference to section 15, if
applicable), multiplied by the amount of
such income (including the amount treated
as a dividend under section 78). For more
information, see Regulations section
1.904-4(c). Also see the instructions for
Schedule A, later, for additional reporting
requirements.
This category also includes financial
services income (defined below) if the
corporation is a member of a financial
services group (as defined in section
904(d)(2)(C)(ii)) or is predominantly
engaged in the active conduct of a
banking, insurance, financing, or similar
business.
Financial services income. Financial
services income is income received or
accrued by a member of a financial
services group or any corporation
predominantly engaged in the active
conduct of a banking, insurance,
financing, or similar business, if the
income is:
Described in section 904(d)(2)(D)(ii),
Passive income (determined without
regard to section 904(d)(2)(B)(iii)(II)), or
Incidental income described in
Regulations section 1.904-4(e)(4).

Special Rules
Source Rules for Income

Determine income or (loss) for each
separate category on Schedule A using
the general source rules of sections 861
through 865 and related regulations; the
special source rules of section 904(h)
described below; and any applicable
source rules contained in any applicable
tax treaties.

Special source rules of section 904(h).
Usually, the following income from a
U.S.-owned foreign corporation, otherwise
treated as foreign source income, must be
treated as U.S. source income under
section 904(h):
Any subpart F income, foreign personal
holding company income, or income from
a qualified electing fund that a U.S.
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shareholder is required to include in its
gross income, if such amount is
attributable to the U.S.-owned foreign
corporation's U.S. source income;
Interest that is properly allocable to the
U.S.-owned foreign corporation's U.S.
source income; and
Dividends equal to the U.S. source ratio
(defined in section 904(h)(4)(B)).
The rules regarding interest and
dividends described above do not apply to
a U.S.-owned foreign corporation if less
than 10% of its E&P for the tax year is from
U.S. sources.

Amounts That Do Not
Constitute Income Under
U.S. Tax Principles

For tax years beginning after December
31, 2006, creditable foreign taxes that are
imposed on amounts that do not constitute
income under U.S. tax principles are
treated as imposed on general category
income. See section 904(d)(2)(H).

Look-Through Rules
CFCs. Generally, dividends, interest,
rents, and royalties received or accrued by
the taxpayer are passive category income.
However, if these items are received or
accrued by a 10% U.S. shareholder from a
CFC, they may be assigned to other
separate categories under the
look-through rules of section 904(d)(3).
This includes:
Interest, rents, and royalties based on
the amount allocable to E&P of the CFC in
a separate category and
Dividends paid out of the E&P of a CFC
in proportion to the ratio of the CFC's E&P
in a separate category to its total E&P.
Dividends include any amount included in
gross income under section 951(a)(1)(B).
Look-through rules also apply to
subpart F inclusions under section 951(a)
(1)(A) to the extent attributable to E&P of
the CFC in a separate category.
For more information and examples,
see section 904(d)(3) and Regulations
section 1.904-5.
10/50 corporations. Generally,
dividends received or accrued by the
taxpayer are passive category income.
However, dividends received or accrued
from a 10/50 corporation may be assigned
to other separate categories under the
look-through rules of section 904(d)(4). A
10/50 corporation is any foreign
corporation in which the taxpayer
(domestic corporation) meets the stock
ownership requirements of section 902.
See Regulations section 1.904-5(c)(4)(iii).
Certain amounts paid by a U.S. corporation to a related corporation.
Look-through rules also apply to foreign
source interest, rents, and royalties paid
by a U.S. corporation to a related

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corporation. See Regulations section
1.904-5(g).

Other Rules
Certain transfers of intangible property. See section 367(d)(2)(C) for a rule that
clarifies the treatment of certain transfers
of intangible property.

Reporting Foreign Tax
Information From Partnerships
If you received a Schedule K-1 from a
partnership that includes foreign tax
information, use the rules below to report
that information on Form 1118.

Gross income sourced at partner level.
This includes income from the sale of
most personal property other than
inventory, depreciable property, and
certain intangible property sourced under
section 865. This gross income will
generally be U.S.-source and therefore
will not be reported on Form 1118.
The remaining lines of the foreign tax
section of the Schedule K-1 are reported
on Form 1118 as follows:
Foreign gross income sourced at partnership level. Report on Schedule A.
Deductions allocated and apportioned
at partner level and partnership level.
Report on Schedule A or Schedule H.
Total foreign taxes paid or accrued.
Report on Schedule B.
Reduction in taxes available for credit.
Report on Schedule G.

Capital Gains

Foreign source taxable income or (loss)
before adjustments in all separate
categories in the aggregate should include
gain from the sale or exchange of capital
assets only up to the amount of foreign
source capital gain net income (which is
the smaller of capital gain net income from
sources outside the United States or
capital gain net income). Therefore, if the
corporation has capital gain net income
from sources outside the United States in
excess of the capital gain net income
reported on its tax return, enter a pro rata
portion of the net U.S. source capital loss
as a negative number on Schedule A,
column 9(d) for each separate category
with capital gain net income from sources
outside the United States. To figure the
pro rata portion of the net U.S. source
capital loss attributable to a separate
category, multiply the net U.S. source
capital loss by the amount of capital gain
net income from sources outside the
United States in the separate category
divided by the aggregate amount of capital
gain net income from sources outside the
United States in all separate categories
with capital gain net income from sources
outside the United States.

See section 904(b)(2)(B) for special
rules regarding adjustments to account for
capital gain rate differentials (as defined in
section 904(b)(3)(D)) for any tax year. At
the time these instructions went to print,
there was no capital gain rate differential
for corporations.

Credit Limitations
Taxes Eligible for a Credit
Domestic corporations. Generally, a
domestic corporation may claim a foreign
tax credit (subject to the limitation of
section 904) for the following taxes:
Income, war profits, and excess profits
taxes (defined in Regulations section
1.901-2(a)) paid or accrued during the tax
year to any foreign country or U.S.
possession;
Taxes deemed paid under sections 902
and 960; and
Taxes paid in lieu of income taxes as
described in section 903 and Regulations
section 1.903-1.
Some foreign taxes that are otherwise
eligible for the foreign tax credit must be
reduced. These reductions are reported
on Schedule G.
Note. A corporation may not claim a
foreign tax credit for foreign taxes paid to a
foreign country that the corporation does
not legally owe, including amounts eligible
for refund by the foreign country. If the
corporation does not exercise its available
remedies to reduce the amount of foreign
tax to what it legally owes, a credit is not
allowed for the excess amount.
Foreign corporations. Foreign
corporations are allowed (under section
906) a foreign tax credit for income, war
profits, and excess profits taxes paid or
accrued (or deemed paid under section
902) to any foreign country or U.S.
possession for income effectively
connected with the conduct of a trade or
business within the United States. The
credit is not applicable, however, if a
foreign country or U.S. possession
imposes the tax on income from U.S.
sources solely because the foreign
corporation was created or organized
under the law of the foreign country or
U.S. possession or is domiciled there for
tax purposes.
The credit may not be taken against
any tax imposed on income not effectively
connected with a U.S. business.
In computing the foreign tax credit
limitation, the foreign corporation's taxable
income includes only the taxable income
that is effectively connected with the
conduct of a trade or business within the
United States.
A foreign corporation claiming a foreign
tax credit will be treated as a domestic
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corporation in computing tax deemed paid
(section 902(a)) and dividend gross-up
(section 78).
Definition of foreign corporation for
purposes of the deemed paid credit. In
computing the deemed paid credit on
Schedules C, D, and E, the term “foreign
corporation” includes:
A DISC or former DISC, but only for
dividends from the DISC or former DISC
that are treated as income from sources
outside the United States and
A contiguous country life insurance
branch that has made an election to be
treated as a foreign corporation under
section 814(g).

Credit or Deduction

A corporation may choose to take either a
credit or a deduction for eligible foreign
taxes paid or accrued. The choice is made
annually. Generally, if a corporation elects
the benefits of the foreign tax credit for any
tax year, no portion of the foreign taxes
will be allowed as a deduction in that year
or any subsequent tax year.

Exceptions. However, a corporation that
elects the credit for eligible foreign taxes
may be allowed a deduction for certain
taxes for which a credit was not allowed.
These include:
Taxes for which the credit was denied
because of the boycott provisions of
section 908.
Certain taxes on the purchase or sale of
oil or gas (section 901(f)).
Certain taxes used to provide subsidies
(section 901(i)).
Taxes paid to certain foreign countries
for which a credit was denied under
section 901(j).
Certain taxes paid on dividends if the
minimum holding period is not met with
respect to the underlying stock, or if the
corporation is obligated to make related
payments with respect to positions in
similar or related property (section 901(k)).
Certain taxes paid on gain and income
other than dividends if the minimum
holding period is not met with respect to
the underlying property, or if the
corporation is obligated to make related
payments with respect to positions in
similar or related property (see section
901(l)).
In the case of a covered asset
acquisition (as defined in section 901(m)
(2)), the disqualified portion of any tax
determined with respect to the income or
gain attributable to the relevant foreign
assets (section 901(m)). Note. This rule
generally applies to covered asset
acquisitions after December 31, 2010.

No Credit or Deduction

No foreign tax credit (or deduction) is
allowed for certain taxes including:

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Taxes on mineral income that were
reduced under section 901(e).
Certain taxes paid on distributions from
possessions corporations (section
901(g)).
Taxes on combined foreign oil and gas
income that were reduced under section
907(a).
Taxes attributable to income excluded
under section 814(a) (relating to
contiguous country branches of domestic
life insurance companies).
Taxes paid or accrued to a foreign
country or U.S. possession with respect to
income excluded from gross income on
Form 8873, Extraterritorial Income
Exclusion. However, see section 943(d)
for an exception for certain withholding
taxes.

Carryback and Carryforward of
Excess Foreign Taxes

If the allowable foreign taxes paid,
accrued, or deemed paid in a tax year in a
separate category exceed the foreign tax
credit limitation for the tax year for that
separate category, the excess may be:
Carried back 1 year to offset taxes
imposed in the same category.
Carried forward 10 years to offset taxes
imposed in the same category (5 years for
excess foreign taxes which may be carried
only to tax years ending before October
23, 2004).
The excess is applied first to the
earliest of the years to which it may be
carried, then to the next earliest year, etc.
The corporation may not carry a credit to a
tax year for which it claimed a deduction,
rather than a credit, for foreign taxes paid
or accrued. Furthermore, the corporation
must reduce the amount of any carryback
or carryforward by the amount it would
have used if it had chosen to claim a credit
rather than a deduction in that tax year.
See section 904(c) and Regulations
section 1.904-2 for more details.
How to claim the excess credit. If the
corporation is carrying back the excess
credit to an earlier year, file an amended
tax return with a revised Form 1118 and
schedules (including a revised Schedule K
(Form 1118)).
Special rules apply to:
The carryback and carryover of foreign
taxes paid or accrued on combined
foreign oil and gas income or related taxes
(see section 907(f)) and
An excess foreign tax credit for which
an excess limitation account was
established under section 960(b)(2).
Special rules for carryforwards of
pre-2007 unused foreign taxes. The
foreign taxes carried forward generally are
allocated to the post-2006 separate
categories to which those taxes would
have been allocated if the taxes were paid

or accrued in a tax year beginning after
2006. Alternatively, the corporation can
allocate unused foreign taxes in its
pre-2007 passive income category to the
post-2006 separate category for passive
category income, and can allocate all
other unused foreign taxes in pre-2007
separate categories that were eliminated
in 2007 to the post-2006 separate
category for general category income.

Treaty-Based Return
Positions

Corporations that adopt a return position
that any U.S. treaty overrides or modifies
any provision of the Internal Revenue
Code, and causes (or potentially causes)
a reduction of any tax incurred at any time,
generally must disclose this position.
Complete Form 8833, Treaty-Based
Return Position Disclosure Under Section
6114 or Section 7701(b), and attach it to
Form 1118. See section 6114 and
Regulations section 301.6114-1 for
details.
Failure to make such a report may
result in a $10,000 penalty.

Proof of Credits

Form 1118 must be carefully filled in with
all the information called for and with the
calculations of credits indicated.
Important. Documentation (that is,
receipts of payments or a foreign tax
return for accrued taxes) is not required to
be attached to Form 1118. However, proof
must be presented upon request by the
IRS to substantiate the credit. See
Regulations section 1.905-2.
If the corporation claims a foreign tax
credit for tax accrued but not paid, the IRS
may require a bond to be furnished on
Form 1117, Income Tax Surety Bond,
before the credit is allowed. See
Regulations section 1.905-2(c).

Foreign Tax Credit
Redeterminations

The corporation's foreign tax credit and
U.S. tax liability generally must be
redetermined if:
Accrued foreign taxes when paid differ
from the amounts claimed as credits;
Accrued foreign taxes are not paid
within 2 years after the close of the tax
year to which they relate; or
Any foreign tax paid is fully or partially
refunded.
Except as provided in Temporary
Regulations section 1.905-3T(d)(3), a
redetermination of U.S. tax liability is not
required to account for the effect of a
redetermination of foreign tax paid or
accrued by a foreign corporation on the
amount of foreign taxes deemed paid
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under section 902 or 960. Instead, the
foreign corporation's pools of E&P and
foreign taxes are adjusted in the year of
the foreign tax redetermination.

Reporting Requirements

If the corporation must redetermine its
U.S. tax liability, the corporation must:
File an amended return and Form 1118
with the Service Center where it filed the
tax return on which it claimed the affected
foreign tax credit and
Provide identifying information such as
the corporation's name, address,
employer identification number (EIN), and
the tax year or years that are affected by
the redetermination.
Additional information required. If the
redetermination was because of one of the
following, the corporation must provide the
additional information as indicated.
Refund of foreign taxes paid—
1. The date or dates on which the
foreign taxes were accrued, paid, and
refunded;
2. The amount of foreign taxes
accrued, paid, and refunded on each date
(in foreign currency); and
3. The exchange rates used to
translate such amounts.
Foreign taxes that when paid differ
from the accrued amounts claimed as
credits for a year beginning before
1998—
1. The date on which the foreign taxes
were accrued;
2. The dates on which the foreign
taxes were paid;
3. The exchange rate for each date
the foreign taxes were accrued and paid;
and
4. The amount of foreign taxes
accrued or paid on each such date (in
foreign currency).
Foreign taxes that when paid differ
from accrued amounts claimed as
credits for a tax year beginning after
1997 because the corporation paid
more or less foreign tax than was
originally accrued or failed to pay
accrued taxes within 2 years—
1. The date on which the foreign taxes
were accrued;
2. The dates on which the foreign
taxes were paid;
3. The average exchange rate for the
year for which the foreign taxes were
accrued;
4. For taxes paid more than 2 years
after the year to which they relate, the
exchange rate at the time of payment; and
5. The amount of tax accrued or paid
for each such date, and the amount of

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accrued tax that was not paid within 2
years (in foreign currency).

section 1.905-4T(e) for additional
information.

Foreign taxes deemed paid under
section 902 or 960—If the corporation is
required to make a redetermination under
Temporary Regulations section
1.905-3T(d)(3), include the following basic
information as an attachment to the tax
return for the year for which the
redetermination applies:
1. The dates and amounts of any
dividend distributions or other inclusions
from E&P for the affected year or years;
2. The amount of E&P from which
such dividends were paid for the affected
year or years;
3. The current balances of the pools
of E&P and foreign taxes before and after
the foreign tax adjustment; and
4. The information described above
for foreign taxes paid or accrued, as
applicable.

If the corporation does not comply with
the requirements discussed above within
the time for filing specified, the penalty
provisions of section 6689 (and the related
regulations) will apply.

If foreign taxes deemed paid under
sections 902 or 960 are adjusted and the
corporation is not required to redetermine
its U.S. tax liability, adjust the appropriate
pools of foreign taxes and E&P using the
rules outlined in Temporary Regulations
sections 1.905-3T(d)(2)(ii) and
1.905-4T(b)(2).
Amended returns for all years affected
by foreign tax redeterminations that result
in U.S. tax deficiencies and that occurred
in the three tax years immediately
preceding the corporation's first tax year
beginning on or after November 7, 2007
(and tax years of foreign subsidiaries
ending with or within such tax years of
their domestic corporate shareholders),
are due no later than the due date (with
extensions) of the corporation's return for
its second tax year beginning on or after
November 7, 2007. Amended returns for
all years affected by foreign tax
redeterminations that result in U.S. tax
deficiencies and that occur in tax years
beginning after November 7, 2007 (and
tax years of foreign subsidiaries ending
with or within such tax years of their
domestic corporate shareholders), are
due no later than the due date (with
extensions) of the corporation's return for
its tax year in which the foreign tax
redetermination occurs. For special rules
relating to corporations under the
jurisdiction of the Large Business &
International Division, see Temporary
Regulations sections 1.905-4T(b)(3) and
1.905-4T(f)(2)(iii).

Interest and Penalties

In most cases, interest is computed on the
deficiency or overpayment that resulted
from the foreign tax adjustment (sections
6601 and 6611 and the related
regulations). See Temporary Regulations

Specific Instructions
Report all amounts in U.S. dollars unless
otherwise specified. If it is necessary to
convert from a foreign currency, attach a
statement explaining how the conversion
rate was determined.

Separate Category
of Income Boxes
The corporation must complete a separate
Form 1118 for each applicable category of
income. See Categories of Income,
earlier.

Schedule A

Report gross income or (loss) from
sources outside the United States for the
applicable separate category in columns 2
through 7. Gross income equals gross
receipts reduced by cost of goods sold.
Report the applicable deductions to this
gross income in columns 9 and 10. Report
any net operating loss carryover in column
11. Be sure to include in all columns the
gross income and deductions that pertain
to foreign branches.
Section 863(b) gross income and deductions. Aggregate all section 863(b)
gross income and deductions and report
the totals on a single line. It may be
necessary to enter amounts in multiple
columns on that single line, depending
upon the nature of the section 863(b)
gross income and deductions. For
example, enter “863(b)” in column 1 and
enter (as a positive number) all section
863(b) gross income (in columns 2
through 8) and all section 863(b)
deductions (in columns 9a through 12).
Also enter the net amount in column 13.
Note that the totals are being reported on
a single line because it is not necessary to
report section 863(b) gross income and
deductions on a per-country basis.
RIC pass-through amounts. Aggregate
all income passed through from regulated
investment companies (RICs) and report
the total on a single line. Enter “RIC” in
column 1 and report the total in column 13.
Note that the totals are being reported on
a single line because it is not necessary to
report the RIC pass-through amounts on a
per-country basis.
Net operating losses. Report any net
operating loss carryover on a single line.
Enter “NOL” in column 1 and report the
-5-

total in column 11. Note that the totals are
being reported on a single line because it
is not necessary to report the NOL on a
per-country basis.
Reclassifications of high-taxed income. Aggregate all reclassifications of
high-taxed income and report the total on
a single line. With respect to passive
category income, for items of income that
have been included on Schedule A and
that must be reclassified under the rules of
Regulations section 1.904-4(c), enter
“HTKO” in column 1 and enter (as a
negative number) in column 13 the net
amount of income that is being
reclassified from passive category
income. With respect to general category
income, enter “HTKO” in column 1 and
enter (as a positive number) in column 13
the net amount of income that is being
reclassified to general category income.
Note that the reclassifications are being
reported on a single line because it is not
necessary to report them on a per-country
basis. Also note that tax reclassifications
are needed on Schedule B. See those
instructions for more information. Also see
General Category Income, earlier, for
general additional information about
high-taxed income.
Column 1. Enter the two-letter codes
(from the list at www.irs.gov/
countrycodes) of all foreign countries and
U.S. possessions within which income is
sourced and/or to which taxes were paid,
accrued, or deemed paid.
For section 863(b) income, enter
“863(b)” instead of a two-letter code.
For income passed through from a RIC,
enter “RIC” instead of a two-letter code.
For a net operating loss, enter “NOL”
instead of a two-letter code.
For income adjustments for high-taxed
income, enter “HTKO” instead of a
two-letter code.
When you enter a country code in
Schedule A, column 1, the
CAUTION
information entered on the
corresponding line of Schedule B, Part I,
must pertain to that country code.

!

Column 2(a). If the corporation is a U.S.
shareholder in a CFC, report all income
deemed received under section 951(a)(1)
(A) (before gross-up). See section 904(d)
(3) and Look-Through Rules, earlier, for
more information. If the corporation is a
U.S. shareholder in a passive foreign
investment company (PFIC) and receives
distributions from stock in that PFIC,
report all income deemed received (before
gross-up) under section 1291.
Column 3(a). Report all other dividends
(before gross-up) not included in column
2(a) from sources outside the United
States for the applicable separate

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category. Other dividends include
amounts included in gross income under
section 951(a)(1)(B).
Note. All dividends from a domestic
corporation are of U.S. source, including
dividends from a domestic corporation
which has 80% or more of its gross
income from sources outside the United
States.
Columns 2(b) and 3(b). Include taxes
deemed paid by a domestic corporation
under section 902 or section 960 on
distributions by a foreign corporation in
income as dividend gross-up. See
Regulations section 1.960-3(b) for
exceptions.
Column 4. Enter all interest received
from foreign sources. See section 861(c)
for the treatment of interest from a
domestic corporation that meets the
foreign business requirement.
Column 6. Include gross income,
including compensation, commissions,
fees, etc., for technical, managerial,
engineering, construction, scientific, or
similar services outside the United States.
Be sure to include gross income from
services performed through a foreign
branch.
Column 7. Include all other gross income
from sources outside the United States for
the applicable separate category,
including all other gross income of foreign
branches and pass-through entities and
any exchange gain or loss recognized
under sections 986(c) or 987(3) on a
distribution or remittance of previously
taxed amounts. Attach a schedule
identifying the gross income by type and
by the foreign country or U.S. possession
from which it was sourced.
Column 9(d). Include all other
deductions definitely allocable to income
from sources outside the United States
(dividends, interest, etc.) for the applicable
separate category. Include deductions
allocable to income of foreign branches.
Include any reduction of foreign source
capital gain net income. If foreign source
capital gain net income from all separate
categories is more than the capital gain
net income reported on the corporation's
tax return, enter a pro rata portion of the
excess as a negative number in each
separate category. See Capital Gains,
earlier.
Column 10. Enter only the apportioned
share from Schedule H, Part II, column (d)
that relates to gross income reported in
columns 2 through 7.
Note. If the corporation qualified as a
financial services entity because it treated
certain amounts as active financing
income that are not listed in Regulations
sections 1.904-4(e)(2)(i)(A) through (X),

but that are described as similar items in
Regulations section 1.904-4(e)(2)(i)(Y),
attach a statement to Form 1118 showing
the types and amounts of the similar
items.
Column 11. Enter the corporation's net
operating loss as defined in section 172
that is attributable to foreign source
income in the separate limitation category.
If the net operating loss is part of an
overall foreign loss, see Temporary
Regulations section 1.904(g)-3T for
allocation rules that apply in determining
the amount to enter in column 11.
It is not necessary to report the NOL
adjustment on a per-country basis. See
Net Operating Losses, earlier.

Note. For any given tax year, the
corporation can use the cash method or
the accrual method, but not both. If a
credit for taxes accrued is claimed, show
both the date accrued and the date paid (if
paid).
If the cash method of accounting is
used, an election under section 905(a)
may be made to claim the credit based on
accrued taxes. If this election is made,
figure the foreign tax credit for all
subsequent tax years on the same basis.
Also, the credits are subject to the
redetermination provisions of section
905(c). See Foreign Tax Credit
Redeterminations, earlier, for details.

Schedule B

Column 2(d). Include foreign taxes paid
or accrued on foreign branch taxable
income to which the rules of section
863(b) apply.

Part I—Foreign Taxes Paid,
Accrued, and Deemed Paid

Note. Do not include these overlapping
amounts in column 2(e).

Report only foreign taxes paid, accrued, or
deemed paid for the separate category for
which this Form 1118 is being completed.
Report all amounts in U.S. dollars. If the
corporation must convert from foreign
currency, attach a schedule showing the
amounts in foreign currency and the
exchange rate used.
For corporations claiming the credit on
the accrual basis, the exchange rate for
translating foreign taxes into U.S. dollars
will generally be an average exchange
rate for the tax year to which the taxes
relate. However, the exchange rate on the
date of payment must be used if the
foreign taxes (a) are paid more than 2
years after the close of the tax year to
which they relate or (b) are paid in a tax
year prior to which they relate. In addition,
for tax years beginning after December
31, 2004, taxpayers may elect to use the
exchange rate on the date of payment.
Taxpayers may elect to use the payment
date exchange rates for all creditable
foreign income taxes or only those taxes
that are attributable to qualified business
units with U.S. dollar functional currencies.
The election is made by attaching a
statement to a timely-filed (including
extensions) Form 1118 that indicates the
corporation is making the election under
section 986(a)(1)(D). Once made, the
election applies for all subsequent tax
years and is revocable only with the
consent of the IRS. See section 986(a).
The information entered on each
line of Schedule B, Part I must
CAUTION
pertain to the country code
specified on the corresponding line of
Schedule A, column 1.

!

Column 1. Claim the foreign tax credit for
the tax year in which the taxes were paid
or accrued, depending on the method of
accounting used.
-6-

Part II—Separate
Foreign Tax Credit
Line 1b. If the corporation had a foreign
tax credit splitting event in a prior tax year
that resulted in a suspension of foreign
taxes under section 909, enter the amount
of those taxes attributable to related
income taken into account in the current
tax year. The amount of taxes suspended
in a prior tax year should have appeared
on Schedule G, line E on your Form 1118
for that prior tax year. See the regulations
under section 909 for rules for determining
when related income is taken into account
and the amount of previously-suspended
taxes that are attributable to that related
income.
Line 4. If the corporation is reclassifying
high-taxed income from passive category
income to general category income, enter
the related tax adjustment on line 4.
Indicate whether adjustment is positive or
(negative). See General Category Income,
earlier, for additional information.
Line 5. Enter the total amount of foreign
taxes carried forward or back to the
current year. The amount of foreign taxes
carried forward to the current tax year is
the amount from Schedule K (Form 1118),
line 3, column (xiv) plus the amount from
Schedule I, Part III, line 3. Attach
Schedule I (Form 1118) and Schedule K
(Form 1118) to Form 1118.
Line 7. If the corporation has a current
year overall domestic loss or recapture of
an overall domestic loss account, or, in
any of its separate categories, a current
year separate limitation loss, an overall
foreign loss, recapture of an overall
foreign loss, or current year separate
limitation income in a category in which it
has a beginning balance of income that
must be recharacterized, adjustments

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must be made. See the separate
instructions for Schedule J to determine if
that schedule must be filed.

are permitted to enter both an EIN in
column 1b and a reference ID number in
column 1c.

Line 8b. Enter taxable income that
should not be taken into account in
computing the foreign tax credit limitation.

Reference ID numbers. A “reference ID
number” is a number established by or on
behalf of the U.S. corporation filing Form
1118. These numbers are used to
uniquely identify foreign corporations on
Schedules C, D, and E, in order to keep
track of those corporations from tax year
to tax year. The reference ID number must
meet the requirements set forth below.

Line 9. Divide line 7 by line 8c to
determine the limitation fraction. Enter the
fraction on line 9 as a decimal with the
same number of places as the number of
digits to the left of the decimal in adjusted
taxable income on line 8c. For example, if
adjusted taxable income on line 8c is
$100,000, compute the limitation fraction
to 6 decimal places.
Line 11. The limitation may be increased
under section 960(b) for any tax year that
the corporation receives a distribution of
previously taxed E&P. See section 960(b).
If an increase in the limit under section
960(b)(5) exceeds the corporation's U.S.
income tax liability, the excess is deemed
an overpayment and can be claimed on
the corporation's income tax return as a
refundable credit (Form 1120, Schedule J,
Part II, line 19d, or the corresponding line
of other corporate income tax returns).

Part III—Summary of
Separate Credits

Complete Part III only once. Enter on lines
1 through 3 the separate foreign tax
credits from Part II, line 12, for each
applicable separate category.
Note. Complete Part III only on the Form
1118 with the largest amount entered on
Part II, line 12.

Line 5. If the corporation participates in or
cooperates with an international boycott,
the foreign tax credit may be reduced.
Complete Form 5713, International
Boycott Report. If the corporation chooses
to apply the international boycott factor to
calculate the reduction in the credit, enter
the amount from line 2a(3) of Schedule C
(Form 5713) on line 5.

Schedules C, D, and E

If the corporation is a partner in a
partnership, for taxes of foreign
corporations for tax years beginning after
October 22, 2004, stock owned directly or
indirectly, by or for a partnership shall be
considered as being owned
proportionately by its partners. See
section 902(c)(7).

Identifying Numbers
On Schedules C, D, and E, columns 1b
request an employer identification number
(EIN) and columns 1c request a reference
ID number. A reference ID number is
required in columns 1c only in cases
where no EIN was entered for the foreign
corporation in column 1b. However, filers

Note. Because reference ID numbers are
established by or on behalf of the U.S
corporation filing Form 1118, there is no
need to apply to the IRS to request a
reference ID number or for permission to
use these numbers.
Note. In general, the reference ID number
assigned to a foreign corporation on Form
1118 has relevance only on Form 1118
(and on any other form that is attached to
or associated with Form 1118) and should
not be used with respect to the foreign
corporation on other IRS forms.
Requirements. The reference ID
number must be alphanumeric (defined
below) and no special characters or
spaces are permitted. The length of a
given reference ID number is limited to 50
characters.
For these purposes, the term
"alphanumeric" means the entry can be
alphabetical, numeric, or any combination
of the two.
The same reference ID number must
be used consistently from tax year to tax
year with respect to a given foreign
corporation. If for any reason a reference
ID number falls out of use (for example,
the foreign corporation no longer exists
due to disposition or liquidation), the
reference ID number used for that foreign
corporation cannot be used again for
another foreign corporation for purposes
of filing Form 1118.
There are some situations that warrant
correlation of a new reference ID number
with a previous reference ID number when
assigning a new reference ID number to a
foreign corporation. For example:
In the case of a merger or acquisition, a
Form 1118 filer must use a reference ID
number which correlates the previous
reference ID number with the new
reference ID number assigned to the
foreign corporation.
In the case of an entity classification
election that is made on behalf of a foreign
corporation on Form 8832, Regulations
section 301.6109-1(b)(2)(v) requires the
foreign corporation to have an EIN for this
election. For the first year that Form 1118
is filed after an entity classification election
is made on behalf of the foreign
corporation on Form 8832, the new EIN
-7-

must be entered in column 1b and the old
reference ID number must be entered in
column 1c. In subsequent years, the Form
1118 filer may continue to enter both the
EIN and the reference ID number, but
must enter at least the EIN in column 1b.
You must correlate the reference ID
numbers as follows: New reference ID
number [space] Old reference ID number.
If there is more than one old reference ID
number, you must enter a space between
each such number. As indicated above,
the length of a given reference ID number
is limited to 50 characters and each
number must be alphanumeric and no
special characters are permitted.
Note. This correlation requirement
applies only to the first year the new
reference ID number is used.

Schedule C
Part I—Dividends and Deemed
Inclusions From Post-1986
Undistributed Earnings
Column 1a. Enter the name of the foreign
corporation (or DISC or former DISC)
whose earnings were distributed to, or
included in income by, the domestic
corporation filing the return.
Columns 1b and 1c. See Reference ID
numbers, above.
Column 2. Enter the year and month in
which the foreign corporation's U.S. tax
year ended.
Example. When figuring foreign taxes
deemed paid in 2013 by a calendar year
domestic corporation with respect to
dividends and inclusions out of post-1986
undistributed earnings for the foreign
corporation's tax year that ended June 30,
2013, enter “1306.”
Column 3. Enter the applicable
two-letter codes from the list at
www.irs.gov/countrycodes.
Column 4. Enter the distributing
corporation's post-1986 undistributed
earnings pool for the separate category for
which the schedule is being completed.
Generally, this amount is the corporation's
E&P (computed in the corporation's
functional currency according to sections
964(a) and 986) accumulated in tax years
beginning after 1986, determined as of the
close of the corporation's tax year without
reduction for any earnings distributed or
otherwise included in income (that is,
under section 304, 367(b), 951(a), 1248,
or 1293) during the current tax year.
Post-1986 undistributed earnings are
reduced to account for distributions or
deemed distributions that reduced E&P
and inclusions that resulted in previously
taxed amounts described in section 959(c)
(1) and (2) or section 1293(c) in prior tax

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years beginning after 1986. See
Regulations section 1.902-1(a)(9). Also,
see section 902(c)(3) and Regulations
section 1.902-1(a)(13) for special rules
treating earnings accumulated in
post-1986 years as pre-1987 accumulated
profits when no U.S. shareholder was
eligible to claim a section 902 credit with
respect to taxes paid by the foreign
corporation.
Column 5. Enter the opening balance in
the distributing corporation's post-1986
foreign income taxes pool for the tax year
indicated. This amount is the foreign
income taxes paid, accrued, or deemed
paid (in U.S. dollars) by the foreign
corporation for prior tax years beginning
after 1986, reduced by foreign taxes
attributable to distributions or deemed
inclusions of earnings in prior tax years.
See Regulations section 1.902-1(a)(8)(i).
Column 6(a). Enter the foreign income
taxes paid or accrued by the foreign
corporation for the tax year indicated,
translated into U.S. dollars using the
exchange rate specified in section 986(a).
Column 6(b). Enter the foreign income
taxes deemed paid (under section 902(b))
by the corporation for the tax year
indicated (from Schedule D, Part I,
Section A, column 10, and Section B,
column 8(b)).
Column 8(a). Report the sum (in the
foreign corporation's functional currency)
of all dividends paid and deemed
inclusions out of post-1986 undistributed
earnings for the tax year indicated.
Column 8(b). Report the column 8(a)
amounts, translated into U.S. dollars at the
appropriate exchange rates (as defined in
section 989(b)). If the foreign corporation's
functional currency is the U.S. dollar, do
not complete column 8(b).
Column 11. Enter foreign income taxes
deemed paid during the current tax year
that exceed the limit (with respect to
section 956 inclusions) described in
section 960(c).

Part II—Dividends Paid Out of
Pre-1987 Accumulated Profits

Use a separate line for each dividend
paid. If a dividend is paid out of the
accumulated profits of more than one
pre-1987 tax year, figure and show the tax
deemed paid on a separate line for each
tax year. In applying section 902, the IRS
may determine from which tax year's
accumulated profits the dividends were
paid. See Regulations section 1.902-3(g)
(4).
Important. The formula for calculating
foreign taxes deemed paid under section
902 with respect to dividends paid in a
post-1986 year out of pre-1987
accumulated profits requires that all

components (dividends, accumulated
profits, and taxes) be maintained in the
foreign corporation's functional currency
and translated into U.S. dollars at the
exchange rate in effect on the date of the
dividend distribution. See Regulations
section 1.902-1(a)(10)(ii) and (iii).
Column 1a. Enter the name of the
first-tier foreign corporation (or DISC or
former DISC) that paid a dividend out of
pre-1987 profits to the domestic
corporation filing the return.
Columns 1b and 1c. See Reference ID
numbers, earlier.
Column 2. Enter the year and month in
which the foreign corporation's pre-1987
tax year ended.
Column 3. Enter the applicable two-letter
codes from the list at www.irs.gov/
countrycodes.
Column 4. For each line, enter the
pre-1987 accumulated profits for the tax
year indicated in column 2, computed in
functional currency under section 902.
See Regulations section 1.902-1(a)(10)(i)
and (ii).
Column 5. Enter the foreign taxes paid
and deemed paid (in functional currency)
with respect to the pre-1987 accumulated
profits entered in column 4 for the tax year
indicated in column 2. See the instructions
for Schedule G, later, for information on
reduction of foreign taxes for failure to
furnish information required under section
6038.
Column 6(a). Enter the amount of each
dividend paid by the first-tier foreign
corporation (or DISC or former DISC) to
the domestic corporation (in functional
currency) out of the accumulated profits of
the pre-1987 tax year indicated in column
2.
Column 6(b). Enter the amount from
column 6(a) translated into U.S. dollars
using the spot exchange rate in effect on
the date of distribution. See Regulations
sections 1.902-1(a)(10)(ii) and 1.902-3(g)
(1).
Column 8(a). Multiply column 5 by
column 7. Enter this amount in column
8(a) in functional currency.
Column 8(b). Enter the amount from
column 8(a) translated into U.S. dollars at
the spot exchange rate in effect on the
date of distribution. See Regulations
section 1.902-1(a)(10)(iii).

Part III—Deemed Inclusions
From Pre-1987
Earnings and Profits

Important. The formula for calculating
foreign taxes deemed paid under section
960 with respect to deemed inclusions
(that is, under section 956 or 1248) in a
-8-

post-1986 year out of pre-1987 E&P
requires that earnings and profits and
foreign taxes be calculated in U.S. dollars
under the rules of Regulations section
1.964-1(a) through (e), and then
translated into the foreign corporation's
functional currency at the exchange rate in
effect on the first day of the foreign
corporation's first post-1986 tax year. See
Notice 88-70, 1988-2 C.B. 369. The
deemed inclusion is then translated into
U.S. dollars at the appropriate exchange
rate specified in section 989(b). Foreign
income taxes paid in pre-1987 tax years
are translated into U.S. dollars for
purposes of section 960 at the exchange
rate in effect when the foreign taxes were
paid. See Regulations section 1.964-1(d)
and Temporary Regulations section
1.905-5T(b)(1).
Column 1a. Enter the name of the first- or
lower-tier foreign corporation whose
earnings were deemed included in the
income of the domestic corporation filing
the return.
Columns 1b and 1c. See Reference ID
numbers, earlier.
Column 2. Enter the year and month in
which the corporation's pre-1987 tax year
ended. If the deemed inclusion is from the
accumulated E&P of more than one tax
year, figure and show the tax deemed paid
on a separate line for each year.
Column 3. Enter the applicable two-letter
codes from the list at www.irs.gov/
countrycodes.
Column 4. For each line, enter the E&P
calculated in U.S. dollars under
Regulations sections 1.964-1(a) through
(e), translated into functional currency
under Notice 88-70 for the tax year
indicated in column 2.
Column 5. Enter foreign taxes paid and
deemed paid (in U.S. dollars) with respect
to the E&P entered in column 4. See the
instructions for Schedule G on page 8 for
information on reduction of foreign taxes
for failure to furnish information required
under section 6038.
Column 6(b). Enter the amount from
column 6(a) translated into U.S. dollars at
the appropriate exchange rate specified in
section 989(b).

Schedule D
Part I—Tax Deemed Paid by
First-Tier Foreign Corporations
Section A—Dividends Paid Out of
Post-1986 Undistributed Earnings
Column 1a. Enter the name of the
second-tier foreign corporation and the
name of the first-tier foreign corporation to

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which it paid a dividend out of post-1986
undistributed earnings.
Example. The U.S. corporation filing
the return owns all of the stock of CFC1
and CFC2. CFC1 and CFC2 each own
50% of the stock of CFC3. In 2013, CFC3
pays a dividend to CFC1 and CFC2. Use
one line to report dividends from CFC3 to
CFC1 and another line to report dividends
from CFC3 to CFC2.
Columns 1b and 1c. See Reference ID
numbers, earlier.
Column 2. Enter the year and month in
which the distributing second-tier foreign
corporation's tax year ended.
Example. If a first-tier foreign
corporation that uses the calendar year
2013 as its tax year receives dividends out
of post-1986 undistributed earnings of a
second-tier foreign corporation for a tax
year that ended June 30, 2013, enter
“1306.”
Column 3. Enter the applicable two-letter
codes from the list at www.irs.gov/
countrycodes.
Column 4. Enter the second-tier foreign
corporation's post-1986 undistributed
earnings pool (in functional currency) for
the separate category for which the
schedule is being completed. See the
instructions for Schedule C, Part I, column
4.
Column 5. Enter the opening balance in
the second-tier foreign corporation's
post-1986 foreign income taxes pool for
the tax year indicated. See the instructions
for Schedule C, Part I, column 5.
Column 6(a). Enter the foreign income
taxes paid or accrued by the second-tier
foreign corporation for the tax year
indicated, translated from foreign currency
into U.S. dollars using the exchange rate
specified in section 986(a).
Column 6(b). Enter the foreign income
taxes deemed paid (under section 902(b))
by the second-tier foreign corporation for
the tax year indicated (from Schedule D,
Part II, Section A, column 10, and Part II,
Section B, column 8(b)).
Column 8(a). Report the sum (in the
second-tier foreign corporation's
functional currency) of all dividends paid
out of its post-1986 undistributed earnings
for the tax year indicated.
Column 8(b). Report the sum of the
column 8(a) amounts translated into the
functional currency of the first-tier foreign
corporation at the spot rate in effect on the
date of each distribution.

Section B—Dividends Paid Out of
Pre-1987 Accumulated Profits
Use a separate line for each dividend
paid. If a dividend is paid out of the
accumulated profits of more than one
pre-1987 tax year, figure and show the tax
deemed paid on a separate line for each
tax year. In applying section 902, the IRS
may determine from which tax year's
accumulated profits the dividends were
paid. See Regulations section 1.902-3(g)
(4).
Important. The formula for calculating
foreign taxes deemed paid by a first-tier
foreign corporation under section 902(b)
with respect to dividends paid by a
second-tier foreign corporation in a
post-1986 year out of pre-1987
accumulated profits requires that all
components (dividends, accumulated
profits, and taxes) be maintained in the
second-tier foreign corporation's
functional currency. Dividends are
translated into the first-tier foreign
corporation's functional currency and
added to its post-1986 undistributed
earnings at the exchange rate in effect on
the date of the dividend distribution. See
Regulations section 1.902-1(a)(9)(ii).
Foreign taxes are translated into U.S.
dollars, and added to the first-tier foreign
corporation's post-1986 foreign income
taxes, at the exchange rate in effect on the
date of the dividend distribution. See
Regulations section 1.902-1(a)(8)(ii).
Column 1a. Enter the name of the
second-tier foreign corporation and the
name of the first-tier foreign corporation to
which it paid a dividend out of pre-1987
accumulated profits.
Columns 1b and 1c. See Reference ID
numbers, earlier.
Column 2. For each pre-1987 tax year,
enter the year and month in which the
second-tier foreign corporation's tax year
ended.
Column 3. Enter the applicable
two-letter codes from the list at
www.irs.gov/countrycodes.
Column 4. For each line, enter the
pre-1987 accumulated profits for the tax
year indicated in column 2, computed in
the second-tier corporation's functional
currency under section 902. See
Regulations sections 1.902-1(a)(10)(i) and
(ii).
Column 5. Enter the foreign taxes paid
and deemed paid under section 902(b) (in
functional currency) with respect to the
accumulated profits entered in column 4
for the pre-1987 tax year indicated in
column 2. See the instructions for
Schedule G below for information on
reduction of foreign taxes for failure to

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furnish information required under section
6038.
Column 6(a). Enter each dividend paid
by the second-tier foreign corporation (in
functional currency) to the first-tier foreign
corporation out of the accumulated profits
of the pre-1987 tax year indicated in
column 2.
Column 6(b). Enter the amount from
column 6(a), translated into the first-tier
foreign corporation's functional currency
using the spot exchange rate in effect on
the date of distribution. See Regulations
sections 1.902-1(a)(10)(ii) and 1.902-3(g)
(1).
Column 8(a). Multiply column 5 by
column 7. Enter the result in column 8(a).
Column 8(b). Enter the amount from
column 8(a), translated in U.S. dollars at
the spot exchange rate in effect on the
date of distribution. See Regulations
section 1.902-1(a)(10)(iii).

Part II—Tax Deemed
Paid by Second-Tier
Foreign Corporations

Follow the instructions for the
corresponding columns of Schedule D,
Part I, substituting “second-tier foreign
corporation” for references to the “first-tier
foreign corporation” and “third-tier foreign
corporation” for references to the
“second-tier foreign corporation.”
Note. In completing Section A, column 5,
note that section 902(b) as in effect prior
to the Taxpayer Relief Act of 1997 did not
treat any foreign taxes as deemed paid by
a third- or lower-tier foreign corporation
with respect to dividends received from
lower-tier foreign corporations.

Schedule E

Use Schedule E to report foreign taxes
deemed paid with respect to dividends
from certain fourth-, fifth-, and sixth-tier
controlled foreign corporations out of
earnings accumulated in tax years
beginning after August 5, 1997. Follow the
instructions for the corresponding columns
of Schedule D, Part I, Section A,
substituting references to the next
lower-tier foreign corporation as
appropriate.
The post-1986 undistributed earnings
and taxes pools for the eligible CFCs
begin on the first day of the CFC's first tax
year beginning after August 5, 1997.
Earnings accumulated in tax years
beginning before August 6, 1997, will be
treated as pre-1987 accumulated profits
for section 902 purposes. See section
902(c)(6) and Regulations section
1.902-1(a)(10)(i). Foreign income taxes
attributable to these pre-pooling profits
must be reduced when the associated

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earnings are distributed. However, such
taxes are generally not eligible for the
deemed paid credit. See Regulations
sections 1.902-1(a)(10)(iii) and 1.902-1(c)
(8).
Note. In completing Part III, column 5,
note that, under section 902(b) as
amended by the Taxpayer Relief Act of
1997, no taxes are deemed paid by a
sixth- or lower-tier foreign corporation with
respect to dividends received from
lower-tier foreign corporations.

90-day period has expired. See section
6038(c) for limitations and special rules.
In addition, a $10,000 penalty is
imposed under section 6038(b) for failure
to supply the information required under
section 6038(a) for each entity within the
time prescribed. If the required information
is not submitted within 90 days after the
IRS has mailed notice to the U.S. person,
additional penalties may apply.

choosing SIC codes and changing a
product category.
Note. If the corporation has more than
two product lines, see
Computer-Generated Schedule H, above.

Columns (a)(i) and (a)(iii)
Line 1. Enter the worldwide gross sales
for the product lines.

Note. The reduction in foreign taxes
available for credit is reduced by any
dollar penalty imposed under section
6038(b).

Lines 3a through 3d. Enter the gross
sales that resulted in gross income for
each statutory grouping.

Enter the gross income and definitely
allocable deductions for each foreign
branch (including a disregarded entity) as
indicated. For each such foreign branch
for which Form 8858, Information Return
of U.S. Persons With Respect To Foreign
Disregarded Entities, is not filed, attach an
income statement, balance sheet, and
schedule of remittances.

Line E. Enter foreign income taxes paid
or accrued during the current tax year that
have been suspended due to the rules of
section 909.

Columns (a)(ii) and (a)(iv)

Schedule G

A computer-generated Schedule H may
be filed if it conforms to the IRS version. In
some cases, Schedule H can be
expanded to properly apportioned
deductions. This applies in cases such as
when the corporation:
Has more than two product lines (under
the sales method or the gross income
method of apportioning R&D deductions),
Has section 901(j) income from more
than one sanctioned country, or
Has income re-sourced by treaty for
more than one country.

Schedule F

Part I
Line A. If the corporation claims a
deduction for percentage depletion under
section 613 with respect to any part of its
foreign mineral income (as defined in
section 901(e)(2)) for the tax year, any
foreign taxes on that income must be
reduced by the smaller of:
1. The foreign taxes minus the tax on
that income or
2. The tax on that income determined
without regard to the deduction for
percentage depletion minus the tax on that
income.
The reduction must be made on a
country-by-country basis (Regulations
section 1.901-3(a)(1)). Attach a separate
schedule showing the reduction.
Line C. If the corporation chooses to
calculate the reduction in the foreign tax
by identifying taxes specifically
attributable to participation in or
cooperation with an international boycott,
enter the amount from Form 5713,
Schedule C, line 2b. See Form 5713 and
its separate Schedule C and instructions.
Line D. If the corporation controls a
foreign corporation or partnership and fails
to furnish any return or any information in
any return required under section 6038(a)
by the due date, reduce the foreign taxes
available for credit under sections 901,
902, and 960 by 10%. If the failure
continues for 90 days or more after the
date of written notice by the IRS, reduce
the tax by an additional 5% for each
3-month period or fraction thereof during
which the failure continues after the

Schedule H
Computer-Generated
Schedule H

Part I—Research and
Development Deductions

Use Part I to apportion the research and
development (R&D) deductions that
cannot be definitely allocated to some
item or class of gross income. Use either
the sales method or one of the gross
income methods described in Regulations
section 1.861-17.
Note. The line 4 totals will generally be
less than the totals on lines 1 and 2
because the line 4 totals do not include
the gross income and deductions that are
implicitly apportioned to the residual
grouping.

Column (a) Sales Method
Complete these columns only if the
corporation elects the sales method of
apportioning R&D deductions described in
Regulations section 1.861-17(c). Enter in
the spaces provided the SIC Code
numbers (based upon the Standard
Industrial Classification System) of the
product lines to which the R&D deductions
relate. See Regulations section
1.861-17(a)(2)(ii) and (iii) for details on
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Line 1. Enter the total R&D deductions
connected with the product lines.
Line 2. Reduce the line 1 totals by legally
mandated R&D (Regulations section
1.861-17(a)(4)), and a 50% exclusive
apportionment amount (Regulations
section 1.861-17(b)(1)(i)) if applicable.
The legally mandated R&D rules apply
to R&D undertaken solely to meet legal
requirements imposed by a particular
political entity for improvement or
marketing of specific products or
processes if the corporation does not
reasonably expect the results of that
research to generate gross income
(beyond de minimis amounts) outside a
single geographic source.
Under the exclusive apportionment
rules, 50% of the R&D deductions are
apportioned exclusively to the statutory
grouping of gross income, or the residual
grouping of gross income, as the case
may be, from the geographic source
where the R&D activities which account
for more than 50% of the amount of such
deduction were performed. If the 50% test
is not met, then no part of the deduction is
apportioned under these rules.
Lines 3a through 3d. To figure the
amount of R&D deductions to apportion to
each statutory grouping, divide the gross
sales apportioned to the statutory
grouping by the worldwide gross sales for
the product line. Multiply the result by the
R&D deductions to be apportioned.
Note. If the corporation had section 901(j)
income from more than one sanctioned
country or had income re-sourced by
treaty for more than one country, see
Computer-Generated Schedule H, above.
Example 1. To determine the amount
to enter on line 3a, column (a)(ii):
1. Divide the amount on line 3a,
column (a)(i) by the amount on line 1,
column (a)(i).
2. Multiply the result by the amount on
line 2, column (a)(ii).

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Example 2. To determine the amount
to enter on line 3b, column (a)(iv):
1. Divide the amount on line 3b,
column (a)(iii) by the amount on line 1,
column (a)(iii).
2. Multiply the result by the amount on
line 2, column (a)(iv).

Column (b) Gross Income Methods
Complete these columns only if the
corporation elects one of the gross income
methods of apportioning R&D deductions
described in Regulations section
1.861-17(d)(2) and (3). Check the box for
the option used. Use Option 1 only if
certain conditions are met. See
Regulations section 1.861-17(d)(2).
Note. If the corporation has more than
two product lines, see
Computer-Generated Schedule H, above.

Columns (b)(v) and (b)(vii)
Line 1. Enter the total gross income
(excluding exempt income according to
Temporary Regulations section
1.861-8T(d)(2)).
Lines 3a through 3d. Enter the gross
income within each statutory grouping.

Columns (b)(vi) and (b)(viii)
Line 1. Enter the total R&D deductions.
Line 2. Reduce the line 1 totals by legally
mandated R&D (Regulations section
1.861-17(a)(4)), and a 25% exclusive
apportionment amount (Regulations
section 1.861-17(b)(1)(ii)).
Lines 3a through 3d. If Option 1 is
checked, divide the gross income
apportioned to the statutory grouping by
the total gross income and multiply the
result by the R&D deductions to be
apportioned. If Option 2 is checked, enter
the appropriate amount as described in
Regulations section 1.861-17(d)(3).

Part II—Interest Deductions,
All Other Deductions,
and Total Deductions

Note. The line 4 totals will generally be
less than the totals on lines 1 and 2
because the line 4 totals do not include
the gross income and deductions that are
implicitly apportioned to the residual
grouping.

Columns (a)(i) through (b)(iv)
Use these columns to apportion interest
deductions. See Temporary Regulations
sections 1.861-8T through 1.861-13T for
rules on the apportionment of interest
deductions based on the fair market value,
tax book value, or adjusted tax book value
of assets.

If the corporation elected to use the fair
market value method to apportion interest
expense, see Temporary Regulations
section 1.861-9T(h). Also see Rev. Proc.
2003-37, 2003-1 C.B. 950, for procedures
for supplying certain documentation and
information.
For tax years beginning on or after
March 26, 2004, a corporation may elect
to use the alternative tax book value
method. See Regulations section
1.861-9(i).
Columns (a) and (b) are subdivided
into “Nonfinancial Corporations” and
“Financial Corporations.” In allocating
interest deductions, members of an
affiliated group that are financial
corporations must be treated as a
separate affiliated group. Complete
columns (a)(ii) and (b)(iv) for members of
the corporation's affiliated group that are
financial corporations and columns (a)(i)
and (b)(iii) for members that are
nonfinancial corporations.
See Regulations section 1.861-11 for
the definition of an affiliated group.

Columns (a)(i) and (a)(ii)
Line 1a. Enter the average of the total
assets of the affiliated group. See
Temporary Regulations section
1.861-9T(g)(2) for the definition of average
for these purposes.
Line 1b. Enter the assets included on
line 1a that are characterized as excess
related party indebtedness. See
Temporary Regulations section
1.861-10T(e) for an exception to the
general rule of fungibility for excess
related party indebtedness.
Line 1c. Enter all other assets that attract
specifically allocable interest deductions.
See Temporary Regulations section
1.861-10T for other exceptions to the
general rule of fungibility (such as qualified
nonrecourse indebtedness and integrated
financial transactions).
Line 1d. Enter the total of the exempt
assets and assets without directly
identifiable yield that are to be excluded
from the interest apportionment formula
(Temporary Regulations sections
1.861-8T(d)(2) and 1.861-9T(g)(3)).
Lines 3a through 3d. The assets on
line 2 are characterized as assets in one
of the statutory groupings or as belonging
to the residual grouping. Enter the value of
the assets in each of the statutory
groupings on line 3a through 3d. See
Temporary Regulations sections
1.861-9T(g)(3), 1.861-12T(g)(2), and
1.861-12T(h)(2) for the rules for
characterizing the assets.
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Columns (b)(iii) and (b)(iv)
Line 1a. Enter the total interest
deductions for the members of the
corporation's affiliated group. These
include any expense that is currently
deductible under section 163 (including
original issue discount), and interest
equivalents. See Temporary Regulations
section 1.861-9T for the definition of
interest equivalents and a list of the
sections that disallow or suspend interest
deductions or require the capitalization of
interest deductions.
Line 1b. Enter the interest deductions
associated with the assets on line 1b of
columns (a)(i) and (a)(ii), respectively, that
attract specifically allocable interest
deductions under Temporary Regulations
section 1.861-10T(e).
Note. These interest deductions will be
divided among the statutory groupings
and will appear as a definitely allocable
deduction in Schedule A, column 9(d).
Line 1c. Enter the interest deductions
associated with the assets on line 1c of
columns (a)(i) and (a)(ii), respectively, that
attract specifically allocable interest
deductions.
Lines 3a through 3d. To figure the
amount of interest deductions to apportion
to each statutory grouping, divide the
assets apportioned to the grouping by the
total assets apportioned and multiply the
result by the interest deductions to be
apportioned.
Example 1. To figure the amount to
enter on line 3a, column (b)(iii): (a) divide
the amount entered on line 3a, column (a)
(i), by the amount on line 2, column (a)(i);
and (b) multiply the result by the amount
on line 2, column (b)(iii).
Example 2. To figure the amount to
enter on line 3b, column (b)(iv): (a) divide
the amount on line 3b, column (a)(ii) by
the amount on line 2, column (a)(ii); and
(b) multiply the result by the amount on
line 2, column (b)(iv).

Column (c)
Complete this column to apportion all
other deductions not definitely allocable
(other than interest deductions and R&D
deductions). See Regulations sections
1.861-8 and 1.861-14 and Temporary
Regulations sections 1.861-8T and
1.861-14T.
Line 1a. Enter the total other deductions.
Examples include: stewardship expenses;
legal and accounting expenses; and other
expenses related to certain supportive
functions such as overhead, general and
administrative, advertising, and marketing.
Deductions for charitable contributions
made on or after July 28, 2004, generally

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are definitely related and allocable to all
gross income and apportioned solely to
domestic source income.
Lines 3a through 3d. Enter the amounts
apportioned to each statutory grouping.

Schedules I, J, and K

See the separate instructions for
Schedule I, Schedule J, and Schedule K

to see if the corporation must file these
schedules.

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the United
States. You are required to give us the information. We need it to ensure that you are complying with these laws and to allow us to
figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form
displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents
may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential,
as required by section 6103.
The time needed to complete and file this form and related schedules will vary depending on individual circumstances. The
estimated average times are:
Form

Recordkeeping

1118

71 hr., 16 min.

Sch. I (Form 1118)

9 hr., 19 min.

Sch. J (Form 1118)

22 hr., 43 min.

Learning about the law
or the form
17 hr., 44 min.

Preparing and sending
the form to the IRS
20 hr., 53 min.

1 hr.

1 hr., 11 min.

1 hr., 23 min.

1 hr., 49 min.

If you have comments concerning the accuracy of these time estimates or suggestions for making this form and related schedules
simpler, we would be happy to hear from you. See the instructions for the tax return with which this form is filed.

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