1118 Foreign Tax Credit-Corporations

Caution: DRAFT—NOT FOR FILING
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DRAFT AS OF
August 7, 2018
DO NOT FILE

1118

Foreign Tax Credit—Corporations

Form
(Rev. December 2018)
Department of the Treasury
Internal Revenue Service

▶

For calendar year 20

Name of corporation

▶ Attach to the corporation’s tax return.
Go to www.irs.gov/Form1118 for instructions and the latest information.

, or other tax year beginning

, 20

Use a separate Form 1118 for each applicable category of income (see instructions).
a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . .
b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions)
c If code RBT is entered on line a, enter the country code for the treaty country (see instructions) . .

Schedule A

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OMB No. 1545-0123

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Employer identification number

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Income or (Loss) Before Adjustments (Report all amounts in U.S. dollars. See Specific Instructions.)

A
B
C
Totals (add lines A through C)
6. Gross Rents, Royalties,
and License Fees

Gross Income or (Loss) From Sources Outside the United States

2. Foreign Country or
U.S. Possession
(enter two-letter code—use
a separate line for each)
(see instructions)

1. EIN or Reference ID
Number
(see instructions)*

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4. Dividends
(see instructions)

3. Inclusions Under Sections 951(a)(1) and 951A
(see instructions)

(a) Exclude Gross-Up

(b) Gross-Up (section 78)

(a) Exclude Gross-Up

(b) Gross-Up (section 78)

8. Gross Income From
Performance of Services

9. Section 986(c)
Gain or Loss

10. Section 987
Gain or Loss

11. Section 988
Gain or Loss

5. Interest

▶

7. Sales

12. Other
(attach schedule)

A
B
C
Totals

14. Allocable Deductions
13. Total
(add columns 3(a)
through 12)

(a) Dividends
Received Deduction
(see instructions)

(b) Deduction Allowed Under
Section 250(a)(1)(A)—Foreign
Derived Intangible Income

(c) Deduction Allowed Under
Section 250(a)(1)(B)—Global
Intangible Low-Taxed Income

Rental, Royalty, and Licensing Expenses
(d) Depreciation, Depletion,
and Amortization

(e) Other Allocable
Expenses

16. Net Operating
Loss Deduction

17. Total Deductions
(add columns 14(i)
through 16)

(f) Expenses Allocable
to Sales Income

A
B
C
Totals

14. Allocable Deductions (continued)
(g) Expenses Allocable
to Gross Income From
Performance of Services

(h) Other Allocable
Deductions

(i) Total Allocable Deductions
(add columns 14(a)
through 14(h))

15. Apportioned
Share of Deductions
(enter amount from
applicable line of Schedule H,
Part II, column (d))

18. Total Income or (Loss)
Before Adjustments
(subtract column 17
from column 13)

A
B
C
Totals

* For section 863(b) income, NOLs, income from RICs, high-taxed income, section 965, and section 951A, use a single line (see instructions).
For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 10900F

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule B

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 2

Foreign Tax Credit (Report all foreign tax amounts in U.S. dollars.)

Part I—Foreign Taxes Paid, Accrued, and Deemed Paid (see instructions)

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

1. Credit Is Claimed for Taxes
(check one):
Paid

Tax Withheld at Source on:

Accrued

Date Paid

Date Accrued

A
B
C
Totals (add lines A through C)

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(a) Dividends

(b) Distributions of
Previously Taxed Income

(c) Branch Remittances

(d) Interest

(e) Rents, Royalties,
and License Fees

(f) Other

▶

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

A
B
C

(h) Services Income

(i) Other

(j) Total Foreign Taxes Paid or Accrued
(add columns 2(a) through 2(i))

3. Tax Deemed Paid
(see instructions)

Totals

Part II—Separate Foreign Tax Credit (Complete a separate Part II for each applicable category of income.)
1a Total foreign taxes paid or accrued (total from Part I, column 2(j)) . . . . . . . . . . . . . . . . . . . . . . .
b Foreign taxes paid or accrued by the corporation during prior tax years that were suspended due to the rules of section 909 and for
which the related income is taken into account by the corporation during the current tax year (see instructions) . . . . . . . .
2
Total taxes deemed paid (total from Part I, column 3) . . . . . . . . . . . . . . . . . . . . . . . . . . .
)
3
Reductions of taxes paid, accrued, or deemed paid (enter total from Schedule G) . . . . . . . . . . . . . . . . . . (
4
Taxes reclassified under high-tax kickout . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
Enter the sum of any carryover of foreign taxes (from Schedule K, line 3, column (xiv), and from Schedule I, Part III, line 3) plus any
carrybacks to the current tax year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
Total foreign taxes (combine lines 1a through 5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7
Enter the amount from the applicable column of Schedule J, Part I, line 11 (see instructions). If Schedule J is not required to be completed, enter the
result from the “Totals” line of column 18 of the applicable Schedule A . . . . . . . . . . . . . . . . . . . . . . . . . . .
8a Total taxable income from all sources (enter taxable income from the corporation’s tax return) . . . . . . . . . . . . . .
b Adjustments to line 8a (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
c Subtract line 8b from line 8a
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9
Divide line 7 by line 8c. Enter the resulting fraction as a decimal (see instructions). If line 7 is greater than line 8c, enter 1 . . . . . . . . . . .
10
Total U.S. income tax against which credit is allowed (regular tax liability (see section 26(b)) minus any American Samoa economic development credit)
11
Credit limitation (multiply line 9 by line 10) (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12
Separate foreign tax credit (enter the smaller of line 6 or line 11). Enter here and on the appropriate line of Part III . . . . . . . . . . . . ▶
Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule B

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 3

Foreign Tax Credit (continued) (Report all foreign tax amounts in U.S. dollars.)

Part III—Summary of Separate Credits (Enter amounts from Part II, line 12 for each applicable category of income. Do not include taxes paid to sanctioned countries.)
1
Credit for taxes on section 951A category income . . . . . . . . . . . . . . . . . . . . . . . . . . . .
2
Credit for taxes on foreign branch category income . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
Credit for taxes on passive category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4
Credit for taxes on general category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
Credit for taxes on section 901(j) category income (combine all such credits on this line) . . . . . . . . . . . . . . . .
6
Credit for taxes on income re-sourced by treaty (combine all such credits on this line) . . . . . . . . . . . . . . . .
7
Total (add lines 1 through 6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8
Reduction in credit for international boycott operations (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . .
9
Total foreign tax credit (subtract line 8 from line 7). Enter here and on the appropriate line of the corporation’s tax return . . . . . . . . . ▶

Schedule C

Tax Deemed Paid With Respect to Section 951(a)(1) Inclusions by Domestic Corporation Filing Return (Section 960(a))
Use this schedule to report the tax deemed paid by the corporation with respect to section 951(a)(1) inclusions of earnings from foreign corporations under
section 960(a).

1a. Name of Foreign Corporation

1b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see instructions)

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country
code—see
instructions)

4. E&P for Tax Year
Indicated
(in functional currency)

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

Total (add amounts in column 7). Enter the result here and include on the “Totals” line of Schedule B, Part I, column 3 .

6. Section 951(a)(1) Inclusions
(a) Functional Currency

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7. Tax Deemed Paid
(see instructions)

(b) U.S. Dollars

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▶
Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule D

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 4

Tax Deemed Paid With Respect to Section 951A Income by Domestic Corporation Filing the Return (Section 960(d))

Use this schedule to figure the tax deemed paid by the corporation with respect to section 951A inclusions of earnings from foreign corporations under
section 960(d).
Part I—Foreign Corporation’s Tested Income and Foreign Taxes
1a. Name of Foreign Corporation

Total (add amounts in column 4) . . . .
Total (add amounts in column 5) . . . .
Part II—Foreign Income Tax Deemed Paid
1. Global Intangible Low-Taxed Income
(Section 951A Inclusion)

1b. EIN or Reference ID
Number of the
Foreign Corporation
(see instructions)

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2. Tax Year End
(Year/Month)
(see instructions)

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2. Inclusion Percentage.
Divide Part II, Column 1, by
Part I, Column 4 Total

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3. Country of Incorporation
(enter country code—
see instructions)

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5. Pro Rata Share of Tested
Foreign Income Taxes
Paid or Accrued by CFC

4. Pro Rata Share of CFC’s
Tested Income

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3. Multiply Part I, Column 5 Total, by
Part II, Column 2 Percentage

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4. Tax Deemed Paid
(Multiply Part II, column 3, by 80%.
Enter the result here and include on the
“Totals” line of Schedule B, Part I, column 3.)

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule E

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 5

Tax Deemed Paid With Respect to Previously Taxed Income by Domestic Corporation Filing the Return (Section 960(b))

Part I—Tax Deemed Paid by Domestic Corporation
Use this schedule to report the tax deemed paid by the domestic corporation with respect to distributions of previously taxed earnings from foreign corporations under section 960(b).
1a. Name of Distributing Foreign Corporation

1b. EIN or Reference ID
Number of the
Foreign Corporation
(see instructions)

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of Incorporation
(enter country code—
see instructions)

4. Distribution of Previously
Taxed Income (PTI)

5. Foreign Income Taxes
Properly Attributable to PTI and
Not Previously Deemed Paid

Total (add amounts in column 5). Enter the result here and include on the “Totals” line of Schedule B, Part I, column 3 . . . . . . . . . ▶
Part II—Tax Paid or Deemed Paid by First- and Lower-Tier Foreign Corporations
Use this schedule to report the tax paid or deemed paid by a foreign corporation with respect to distributions of previously taxed earnings from lower-tier foreign corporations
under section 960(b) that relate to distributions reported in Part I (see instructions).

1a. Name of Distributing
Foreign Corporation

1b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see instructions)

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country
code—see
instructions)

4a. Name of Recipient
Foreign Corporation

4b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see instructions)

5. Tax Year End
(Year/Month)
(see instructions)

6. Country of
Incorporation
(enter country
code—see
instructions)

7. Previously Taxed
Income (PTI)
Distributed

8. Foreign Income
Taxes Properly
Attributable to PTI
and Not Previously
Deemed Paid

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule F-1

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 6

Tax Deemed Paid by Domestic Corporation Filing Return—Pre-2018 Taxable Years of Foreign Corporations
Use this schedule to figure the tax deemed paid by the corporation with respect to dividends from a first-tier foreign corporation under section 902(a), and
deemed inclusions of earnings from a first- or lower-tier foreign corporation under section 960(a). Report all amounts in U.S. dollars unless otherwise
specified.

IMPORTANT:

Applicable to dividends or inclusions from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend or inclusion, do not complete Schedule F-1 (see instructions).

Part I—Dividends and Deemed Inclusions From Post-1986 Undistributed Earnings
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)

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

1b. EIN (if any)
of the
Foreign
Corporation

1c. Reference ID
Number
(see instructions)

2. Tax Year End
(Year/Month)
(see instructions)

8. Dividends and Deemed Inclusions
(a) Functional
Currency

(b) U.S. Dollars

3. Country of
Incorporation
(enter country
code—see
instructions)

9. Divide Column 8(a)
by Column 4

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

10. Multiply Column 7
by Column 9

Total (add amounts in column 12). Enter the result here and include on the “Totals” line of Schedule B, Part I, column 3

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

5. Opening Balance
in Post-1986 Foreign
Income Taxes

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(a) Taxes Paid

11. Section 960(c) Limitation

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(b) Taxes Deemed Paid
(see instructions)

12. Tax Deemed Paid
(subtract column 11
from column 10)

▶
Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule F-1
IMPORTANT:

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 7

Tax Deemed Paid by Domestic Corporation Filing Return—Pre-2018 Taxable Years of Foreign Corporations (continued)
Applicable to dividends or inclusions from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend or inclusion, do not complete Schedule F-1 (see instructions).

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

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

1b. EIN (if any)
of the
Foreign Corporation

1c. Reference ID
Number
(see instructions)

6. Dividends Paid
(a) Functional Currency

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of Incorporation
(enter country code—
see instructions)

8. Tax Deemed Paid (see instructions)

7. Divide Column 6(a)
by Column 4

(b) U.S. Dollars

(a) Functional Currency

Total (add amounts in column 8b). Enter the result here and include on the “Totals” line of Schedule B, Part I, column 3
Part III—Deemed Inclusions From Pre-1987 Earnings and Profits
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)

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

1b. EIN (if any)
of the
Foreign Corporation

1c. Reference ID
Number
(see instructions)

6. Deemed Inclusions
(a) Functional Currency

(b) U.S. Dollars

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

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2. Tax Year End
(Year/Month)
(see instructions)

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(b) U.S. Dollars

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3. Country of Incorporation
(enter country code—
see instructions)

8. Tax Deemed Paid
(multiply column 5 by column 7)

7. Divide Column 6(a)
by Column 4

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

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

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▶
Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule F-2

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 8

Tax Deemed Paid by First- and Second-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Taxable Years of Foreign
Corporations
Use Part I to compute the tax deemed paid by a first-tier foreign corporation with respect to dividends from a second-tier foreign corporation. Use Part II to
compute the tax deemed paid by a second-tier foreign corporation with respect to dividends from a third-tier foreign corporation. Report all amounts in U.S.
dollars unless otherwise specified.

IMPORTANT:

Applicable to dividends from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete Schedule F-2 (see instructions).
Part I—Tax Deemed Paid by First-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (Include the column 10 results in Schedule F-1, Part I, column 6(b).)
1a. Name of Second-Tier Foreign Corporation
and Its Related First-Tier Foreign Corporation

1b. EIN (if any)
of the Second-Tier
Foreign Corporation

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

(b) Taxes Deemed Paid
(see instructions)

1c. Reference ID
Number
(see instructions)

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

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country code—
see instructions)

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

(b) of First-Tier Corporation

4. Accumulated Profits
for Tax Year Indicated
(in functional currency—
see instructions)

5. Opening Balance
Post-1986 Foreign
Income Taxes

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

9. Divide Column 8(a)
by Column 4

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

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

1b. EIN (if any)
of the Second-Tier
Foreign Corporation

1c. Reference ID
Number
(see instructions)

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

(b) of First-Tier Corporation

2. Tax Year End
(Year/Month)
(see instructions)

7. Divide Column 6(a)
by Column 4

3. Country of
Incorporation
(enter country code—
see instructions)

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

8. Tax Deemed Paid
(see instructions)
(a) Functional Currency
of Second-Tier Corporation

(b) U.S. Dollars

Form 1118 (Rev. 12-2018)

DRAFT AS OF
August 7, 2018
DO NOT FILE

Form 1118 (Rev. 12-2018)

Schedule F-2
IMPORTANT:

Page 9

Tax Deemed Paid by First- and Second-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Taxable Years of Foreign
Corporations (continued)
Applicable to dividends from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete Schedule F-2 (see instructions).

Part II—Dividends Deemed Paid by Second-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (In general, include the column 10 results in Section A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b), for an exception.)
1a. Name of Third-Tier Foreign Corporation
and Its Related Second-Tier Foreign Corporation

1b. EIN (if any)
of the Third-Tier
Foreign Corporation

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

(b) Taxes Deemed Paid (from
Schedule F-3, Part I, column 10)

1c. Reference ID
Number
(see instructions)

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

2. Tax Year End
(Year/Month)
(see instructions)

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

3. Country of
Incorporation
(enter country code—
see instructions)

8. Dividends Paid
(in functional currency)
(a) of Third-Tier Corporation

(b) of Second-Tier Corporation

5. Opening Balance in
Post-1986 Foreign
Income Taxes

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

9. Divide Column 8(a)
by Column 4

Section B—Dividends Paid Out of Pre-1987 Accumulated Profits (In general, include the column 8(b) results in Section A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b) for an exception.)
1a. Name of Third-Tier Foreign Corporation
and Its Related Second-Tier Foreign Corporation

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

1b. EIN (if any)
of the Third-Tier
Foreign Corporation

1c. Reference ID
Number
(see instructions)

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

(b) of Second-Tier Corporation

2. Tax Year End
(Year/Month)
(see instructions)

7. Divide Column 6(a)
by Column 4

3. Country of
Incorporation
(enter country code—
see instructions)

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

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

(b) U.S. Dollars

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule F-3

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 10

Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Taxable Years of
Foreign Corporations
Use this schedule to report taxes deemed paid with respect to dividends from eligible post-1986 undistributed earnings of fourth-, fifth-, and sixth-tier
controlled foreign corporations. Report all amounts in U.S. dollars unless otherwise specified.

IMPORTANT:

Applicable to dividends from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete Schedule F-3 (see instructions).

Part I—Tax Deemed Paid by Third-Tier Foreign Corporations (In general, include the column 10 results in Schedule F-2, Part II, Section A, column 6(b). However, see
instructions for Schedule F-1, Part I, column 6(b), for an exception.)
1a. Name of Fourth-Tier Foreign Corporation
and Its Related Third-Tier Foreign Corporation

1b. EIN (if any)
of the Fourth-Tier
Foreign Corporation

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

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

1c. Reference ID
Number
(see instructions)

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

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country code—
see instructions)

8. Dividends Paid
(in functional currency)
(a) of Fourth-Tier CFC

(b) of Third-Tier CFC

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

9. Divide Column 8(a)
by Column 4

5. Opening Balance in
Post-1986 Foreign
Income Taxes

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

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule F-3
IMPORTANT:

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 11

Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Taxable Years of
Foreign Corporations (continued)
Applicable to dividends from taxable years of foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete Schedule F-3 (see instructions).

Part II—Tax Deemed Paid by Fourth-Tier Foreign Corporations (In general, include the column 10 results in column 6(b) of Part I. However, see instructions for Schedule F-1,
Part I, column 6(b), for an exception.)
1a. Name of Fifth-Tier Foreign Corporation
and Its Related Fourth-Tier Foreign Corporation

1b. EIN (if any)
of the Fifth-Tier
Foreign Corporation

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

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

1c. Reference ID
Number
(see instructions)

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

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country code—
see instructions)

8. Dividends Paid
(in functional currency)
(a) of Fifth-Tier CFC

(b) of Fourth-Tier CFC

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

9. Divide Column 8(a)
by Column 4

5. Opening Balance in
Post-1986 Foreign
Income Taxes

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

Part III—Tax Deemed Paid by Fifth-Tier Foreign Corporations (In general, include the column 10 results in column 6(b) of Part II, above. However, see instructions for Schedule
F-1, Part I, column 6(b), for an exception.)
1a. Name of Sixth-Tier Foreign Corporation
and Its Related Fifth-Tier Foreign Corporation

6. Foreign Taxes Paid
for Tax Year Indicated

1b. EIN (if any)
of the Sixth-Tier
Foreign Corporation

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

1c. Reference ID
Number
(see instructions)

2. Tax Year End
(Year/Month)
(see instructions)

3. Country of
Incorporation
(enter country code—
see instructions)

8. Dividends Paid
(in functional currency)
(a) of Sixth-Tier CFC

(b) of Fifth-Tier CFC

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

9. Divide Column 8(a)
by Column 4

5. Opening Balance in
Post-1986 Foreign
Income Taxes

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

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule G

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 12

Reductions of Taxes Paid, Accrued, or Deemed Paid

Part I—Reduction Amounts
A

Reduction of Taxes Under Section 901(e)—Attach separate schedule

B

Reduction of Foreign Oil and Gas Taxes—Enter amount from Schedule I, Part II, line 4

C

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

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D

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

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E

Taxes suspended under section 909 .

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F

Other Reductions of Taxes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1. Enter code—see instructions ▶
2. If more than one code is entered on line F1 or if code OTH is entered on line F1, attach schedule (see instructions).

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G

Check this box if, during the tax year, the corporation paid or accrued any foreign tax that was disqualified for credit under section 901(m)

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▶

H

Check this box if, during the tax year, the corporation paid or accrued any foreign tax that was disqualified for credit under section 901(j), (k), or (l) .

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▶

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Total (add lines A through F). Enter here and on Schedule B, Part II, line 3 .
Part II—Other Information

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Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule H

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 13

Apportionment of Certain Deductions (Complete only once for all categories of income.)

Part I—Research and Experimental Deductions

(a) Sales Method

Product Line #1 (SIC Code:
(i) Gross Sales

1
2

Totals (see instructions)
Total to be apportioned

3

Apportionment among
statutory groupings
(see instructions):
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line a . . .
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line b . . .
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line c . . .
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line d . . .
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line e . . .
Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line f . . .
Total foreign (add lines
3a(3), 3b(3), 3c(3), 3d(3),
3e(3), and 3f(3)) . . ▶

a

b

c

d

e

f

4

(ii) R&E
Deductions

Important: See Computer-Generated Schedule H in instructions.

)

(b) Gross Income Method—Check method used:

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

(iv) R&E
Deductions

)

Product Line #1 (SIC Code:
(v) Gross Income

(vi) R&E
Deductions

)

Option 1

Option 2
)

Product Line #2 (SIC Code:

(vii) Gross Income

(viii) R&E
Deductions

(c) Total R&E
Deductions
(enter the sum of all
amounts entered in all
applicable “R&E
Deductions” columns)

Form 1118 (Rev. 12-2018)

Form 1118 (Rev. 12-2018)

Schedule H

DRAFT AS OF
August 7, 2018
DO NOT FILE

Page 14

Apportionment of Certain Deductions (Complete only once for all categories of income.) (continued)

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

(a) Average Value of Assets—
Check method used:
Tax book value
Alternative tax book value

(i) Nonfinancial
Corporations

(ii) Financial
Corporations

(b) Interest Deductions

(iii) Nonfinancial
Corporations

(c) All Other
Deductions
(see instructions)

(iv) Financial
Corporations

1a Totals (see instructions) . . . . . . . . . . . . .
b Amounts specifically allocable under Temporary Regulations
section 1.861-10T(e) . . . . . . . . . . . . . .
c Other specific allocations under Temporary Regulations section 1.861-10T
d Assets excluded from apportionment formula . . . . . .
2
Total to be apportioned (subtract the sum of lines 1b, 1c, and
1d from line 1a) . . . . . . . . . . . . . . . .
3
Apportionment among statutory groupings (see instructions):
a Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line a . . . . . . . . . . . . . . . .
b Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line b . . . . . . . . . . . . . . . .
c Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line c . . . . . . . . . . . . . . . .
d Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line d . . . . . . . . . . . . . . . .
e Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line e . . . . . . . . . . . . . . . .
f Enter Code
(1) Section 245A dividend . . . . . . . . . . . .
(2) Other . . . . . . . . . . . . . . . . . .
(3) Total line f . . . . . . . . . . . . . . . .
4
Total foreign (add lines 3a(3), 3b(3), 3c(3), 3d(3), 3e(3), and 3f(3)) ▶
Section 904(b)(4) Adjustments
Expenses Allocated and Apportioned to Foreign Source Section 245A Dividend. Enter the sum of lines 3a(1), 3b(1), 3c(1), 3d(1), 3e(1), and 3f(1). Include the
5
column (d) result as a negative amount on Schedule B, Part II, line 8b . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
Enter expenses allocated and apportioned to U.S. source section 245A dividend. Include the column (d) result as a negative amount on Schedule B, Part II, line 8b
Important: See Computer-Generated Schedule H in instructions.

(d) Totals
(add the
corresponding
amounts from
column (c), Part I;
columns (b)(iii) and
(b)(iv), Part II; and
column (c), Part II)
Additional note:
Be sure to also enter
the totals from lines
3a(2), 3b(2), 3c(2),
3d(2), 3e(2), and 3f(2)
below in column 15
of the corresponding
Schedule A.

Form 1118 (Rev. 12-2018)