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

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Form

1120-F

Department of the Treasury
Internal Revenue Service

Type
or
Print

U.S. Income Tax Return of a Foreign Corporation
For calendar year 2018, or tax year beginning
▶

, 2018, and ending

Name

Employer identification number

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

Check box(es) if:

Initial return

DRAFT AS OF
August 21, 2018
DO NOT FILE

City or town, state or province, country, and ZIP or foreign postal code

Country of incorporation

B

Foreign country under whose laws the income reported on this return
is also subject to tax
Date incorporated

D

2018

, 20

Go to www.irs.gov/Form1120F for instructions and the latest information.

A

C

OMB No. 1545-0123

E

Final return

First post-merger return

Amended return

Schedule M-3 attached

Protective return

If the corporation had an agent in the United States at any time during
the tax year, enter:
(1) Type of agent
(2) Name
(3) Address

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

F

(2) Principal location of worldwide business

Name or address change

See the instructions and enter the corporation’s principal:

(1) Business activity code number ▶
(2) Business activity ▶
(3) Product or service ▶
G Check method of accounting: (1)
Other (specify) ▶
(3)

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

Cash

(2)

Accrual

Computation of Tax Due or Overpayment

1

Tax from Section I, line 11, page 3

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Tax from Section II, Schedule J, line 9, page 5 . .
Tax from Section III (add lines 6 and 10 on page 6) .

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5a
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Total tax. Add lines 1 through 3 . .
2017 overpayment credited to 2018 .
2018 estimated tax payments . . .

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5a
5b
5c (
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Estimated tax penalty (see instructions). Check if Form 2220 is attached . . . . .
Amount owed. If line 5j is smaller than the total of lines 4 and 6, enter amount owed .
Overpayment. If line 5j is larger than the total of lines 4 and 6, enter amount overpaid .

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Less 2018 refund applied for on Form 4466 .
Combine lines 5a through 5c . . . . .

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5d

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Tax deposited with Form 7004 . . . . . . . . . . . .
Credit for tax paid on undistributed capital gains (attach Form 2439).

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5e
5f

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Credit for federal tax paid on fuels (attach Form 4136). See instructions
Refundable credit from Form 8827, line 8c . . . . . . . . .

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5g
5h

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U.S. income tax paid or withheld at source (add line 12, page 3, and amounts
from Forms 8288-A and 8805 (attach Forms 8288-A and 8805)) . . . . .
Total payments. Add lines 5d through 5i . . . . . . . . . . . .

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Amount of overpayment on line 8a resulting from tax deducted and withheld under Chapters 3 and 4
(from Schedule W, line 7, page 8) . . . . . . . . . . . . . . . . . . . . . . .
Enter portion of line 8a you want Credited to 2019 estimated tax ▶
Refunded ▶

Paid
Preparer
Use Only

Signature of officer
Print/Type preparer’s name

Date
Preparer’s signature

▲

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

▲

Sign
Here

8b
9

Yes

Title
Date

Check
if
self-employed

Firm’s name

▶

Firm’s EIN

Firm’s address

▶

Phone no.

For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 11470I

No

PTIN

▶

Form 1120-F (2018)

Page 2

Form 1120-F (2018)

Additional Information (continued from page 1)
H Did the corporation’s method of accounting change
from the preceding tax year? . . . . . . . .
If “Yes,” attach a statement with an explanation.
I Did the corporation’s method of determining income
change from the preceding tax year? . . . . .

Yes

V At the end of the tax year, did any individual, partnership, corporation,
estate, or trust own, directly or indirectly, 50% or more of the
No
corporation’s voting stock? (See section 267(c) for rules of attribution.)
If “Yes,” attach a statement showing the name and
identifying number. (Do not include any information already
entered in item T.) Enter percentage owned ▶

Yes

No

W (1) Is the corporation taking a position on this return that a
U.S. tax treaty overrules or modifies an Internal Revenue
law of the United States, thereby causing a reduction of tax?

DRAFT AS OF
August 21, 2018
DO NOT FILE

If “Yes,” attach a statement with an explanation.

J Did the corporation file a U.S. income tax return for
the preceding tax year? . . . . . . . . .
K (1) At any time during the tax year, was the
corporation engaged in a trade or business in the
United States? . . . . . . . . . . . .

If “Yes,” the corporation is generally required to complete
and attach Form 8833. See Form 8833 for exceptions.
Note: Failure to disclose a treaty-based return position may
result in a $10,000 penalty (see section 6712).

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

(2) Is the corporation claiming treaty benefits pursuant to, or
otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? . . .

L Did the corporation have a permanent establishment
in the United States for purposes of any applicable
tax treaty between the United States and a foreign
country?
. . . . . . . . . . . . .

If “Yes,” attach a copy of the Competent Authority
determination letter or Advance Pricing Agreement to your
return.

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

M Did the corporation have any transactions with related
parties? . . . . . . . . . . . . . .
If “Yes,” Form 5472 may have to be filed (see
instructions).
Enter number of Forms 5472 attached ▶

N Is the corporation a controlled foreign corporation?
(See section 957(a) for definition.) . . . . . .
O Is the corporation a personal service corporation?
(See instructions for definition.) . . . . . . .
P Enter tax-exempt interest received or accrued during
the tax year (see instructions) ▶ $
Q At the end of the tax year, did the corporation own,
directly or indirectly, 50% or more of the voting stock
of a U.S. corporation? (See section 267(c) for rules of
attribution.) . . . . . . . . . . . . .
If “Yes,” attach a statement showing (1) name and
EIN of such U.S. corporation; (2) percentage owned;
and (3) taxable income or (loss) before NOL and
special deductions of such U.S. corporation for the
tax year ending with or within your tax year.
R If the corporation has an NOL for the tax year and
is electing to forego the carryback period, check
here (see instructions) . . . . . . . . ▶
S Enter the available NOL carryover from prior tax years.
(Do not reduce it by any deduction on line 30a, page
4.) ▶ $
T Is the corporation a subsidiary in a parent-subsidiary
controlled group? . . . . . . . . . . .
If “Yes,” enter the parent corporation’s:
(1) EIN ▶
(2) Name ▶
U (1) Is the corporation a dealer under section 475? . .
(2) Did the corporation mark to market any securities
or commodities other than in a dealer capacity? . .

X During the tax year, did the corporation own any entity that
was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3? . .
If “Yes,” attach a statement listing the name, country under whose
laws the entity was organized, and EIN (if any) of each such entity.

Y (1) Did a partnership allocate to the corporation a
distributive share of income from a directly owned
partnership interest, any of which is ECI or treated as ECI by
the partnership or the partner?
. . . . . . . .
If “Yes,” attach Schedule P. See instructions.
(2) During the tax year, did the corporation own directly or
indirectly, at least a 10% interest, in any foreign partnership?
If “Yes,” see instructions for required attachment.
Z (1) Has the corporation engaged in any transactions the
results of which are subject to the arm’s length standard
under section 482 and its regulations? . . . . . .
(2) Has the corporation recognized any interbranch
amounts? If “Yes,” attach statement (see instructions) .

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AA Is the corporation required to file Schedule UTP (Form
1120), Uncertain Tax Position Statement (see instructions)?
If “Yes,” complete and attach Schedule UTP.
BB During the corporation’s tax year, did the corporation make
any payments that would require it to file Forms 1042 and
1042-S under chapter 3 (sections 1441 through 1464) or
chapter 4 (sections 1471 through 1474) of the Code? . .
CC Is the corporation (including the home office or any branch)
a qualified derivatives dealer (QDD)? . . . . . . .
(1) If “Yes,” attach the required statement (see instructions)
(2) If “Yes,” enter the QI-EIN ▶
DD Does the corporation have gross receipts of at least $500
million in any of the 3 preceding tax years (see sections 59A
(e)(2) and (3))?
. . . . . . . . . . . . .
If “Yes,” complete and attach Form 8991.
EE During the tax year, did the corporation pay or accrue any
interest or royalty for which a deduction is not allowed
under section 267A (see instructions)? . . . . . .
If “Yes,” enter the total amount of the
disallowed deductions . . . ▶ $

Form 1120-F (2018)

Page 3

Form 1120-F (2018)

Additional Information (continued from page 2)

HH During the tax year, did the corporation dispose of an
No
interest in a partnership that directly or indirectly engaged in
a trade or business within the United States? . . . .

Yes

FF Did the corporation have an election under section
163(j) for any real property trade or business or any
farming business in effect during the tax year (see
instructions)? . . . . . . . . . . . .

II

Yes

No

Is the corporation attaching Form 8996 to certify as a
Qualified Opportunity Fund? . . . . . . . . .

DRAFT AS OF
August 21, 2018
DO NOT FILE

GG Does the corporation satisfy one of the following
conditions and the corporation does not own a passthrough entity with current year, or prior year
carryover, excess business interest expense (see
instructions)? . . . . . . . . . . . .

If “Yes,” enter amount from Form
8996, line 13 . . . . . . ▶ $

(1) The corporation’s aggregate average annual gross
receipts (determined under section 448(c)) for the 3 tax
years preceding the current tax year do not exceed $25
million, and the corporation is not a tax shelter.

(2) The corporation only has business interest expense
from (a) an electing real property trade or business, (b) an
electing farming business, or (c) certain utility businesses
under section 163(j)(7).
If “No,” complete and attach Form 8990.

SECTION I— Income From U.S. Sources Not Effectively Connected With the Conduct of a Trade or Business in
the United States—Do not report items properly withheld and reported on Form 1042-S. See instructions.
Report all gross transportation income subject to 4% tax on line 9. Report other column (a) income items only if not properly withheld and reported on
Form 1042-S. The rate of tax on these gross income items is 30% or such lower rate specified by tax treaty. No deductions are allowed against these
types of income. Enter treaty rates where applicable. If the corporation is claiming a lower treaty rate, also complete item W on page 2. If multiple
treaty rates apply to a type of income (for example, subsidiary and portfolio dividends or dividends received by disregarded entities), attach a
statement showing the amounts, tax rates, and withholding for each.

Name of treaty country, if any ▶
(a)
Class of income (see instructions)

1
2
3
4
5

Interest
Dividends
Rents .
Royalties
Annuities

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(b)
Gross amount

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(c)
Rate of tax (%)

(d)
Amount of tax liability

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

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6 Gains from disposal of timber, coal, or
domestic iron ore with a retained economic
interest (attach supporting statement)
. .
7 Gains from sale or exchange of patents, copyrights, etc.
8 Fiduciary distributions (attach supporting statement)
9 Gross transportation income (see instructions)
10 Other items of income . . . . . . .

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

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

Yes

No

Form 1120-F (2018)

Page 4

Form 1120-F (2018)

SECTION II—Income Effectively Connected With the Conduct of a Trade or Business in the United States
(see instructions)

Income

Important: Fill in all applicable lines and schedules. If you need more space, see Assembling the Return in the instructions.
1a
2

Gross receipts or sales
b Less returns and allowances
Cost of goods sold (attach Form 1125-A) . . . . . . . . . .

3
4

17
18
19

DRAFT AS OF
August 21, 2018
DO NOT FILE

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c Bal ▶
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1c
2

Gross profit (subtract line 2 from line 1c)
Dividends (Schedule C, line 13)
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3
4

Interest
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Gross rents .
Gross royalties

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6
7

Capital gain net income (attach Schedule D (Form 1120))
. . .
Net gain or (loss) from Form 4797, Part II, line 17 (attach Form 4797)
Other income (see instructions—attach statement) . . . . . .

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9
10

Total income. Add lines 3 through 10 . . . . . . . .
Compensation of officers (see instructions—attach Form 1125-E)
Salaries and wages (less employment credits) . . . . . .

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13

Repairs and maintenance . . . . . . . . . . . . . . . .
Bad debts (for bad debts over $500,000, attach a list of debtors and amounts) .
Rents . . . . . . . . . . . . . . . . . . . . . .

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16

Taxes and licenses . . . . . . . . . . . .
Interest expense from Schedule I, line 25 (see instructions)
Charitable contributions . . . . . . . . . . .

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19

20
21
22

Depreciation from Form 4562 not claimed on Form 1125-A or elsewhere on return (attach Form 4562) .
Depletion . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Advertising
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20
21
22

23
24
25

Pension, profit-sharing, etc., plans
Employee benefit programs
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Reserved for future use . . . .

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24
25

26
27
28

Deductions allocated and apportioned to ECI from Schedule H, line 20 (see instructions) .
Other deductions (attach statement) . . . . . . . . . . . . . . . .
Total deductions. Add lines 12 through 27 . . . . . . . . . . . . . .

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28

29
30

Taxable income before NOL deduction and special deductions (subtract line 28 from line 11)
Less: a Net operating loss deduction (see instructions) . . . .
30a
b Special deductions (Schedule C, line 14) . . . . . .
30b

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29

c Add lines 30a and 30b . . . . . . .
Taxable income or (loss). Subtract line 30c from line 29

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7
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9
10

Deductions (See instructions for limitations on deductions.)

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14
15
16

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Form 1120-F (2018)

Page 5

Form 1120-F (2018)

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

1

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

2
3
4

Dividends from 20%-or-more-owned domestic corporations (other than
debt-financed stock)
. . . . . . . . . . . . . . . .
Dividends on certain debt-financed stock of domestic and foreign corporations (section 246A)
Dividends on certain preferred stock of less-than-20%-owned public utilities

5
6
7

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

(b) %

(c) Special deductions:
(a) × (b)

50

DRAFT AS OF
August 21, 2018
DO NOT FILE
65

see
instructions

23.3
26.7
50
65

see
instructions

8
9
10
11
12

Subtotal. Add lines 1 through 7. See instructions for limitation .
Dividends from foreign corporations not included on lines 3, 6, or 7

13
14

Total dividends. Add lines 8 through 11. Enter here and on line 4, page 4 .
Total special deductions. Add lines 8 and 12. Enter here and on line 30b, page 4 .

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

Other dividends . . . . . . . . . . . . . . . . .
Deduction for dividends paid on certain preferred stock of public utilities

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1
2
3

Check if the corporation is a member of a controlled group (attach Schedule O (Form 1120)) .
Income tax . . . . . . . . . . . . . . . . . . . . . . . . .
Base erosion minimum tax (attach Form 8991) . . . . . . . . . . . . . .

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3

4
5a
b

Add lines 2 and 3 . . . . . . . .
Foreign tax credit (attach Form 1118) . .
General business credit (attach Form 3800)

Schedule J

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Credit for prior year minimum tax (attach Form 8827)
Bond credits from Form 8912 . . . . . . .
Total credits. Add lines 5a through 5d
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7
8

Subtract line 6 from line 4 . . . . .
Other taxes. Check if from:
Form 4255
Form 8866

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Form 8611
Form 8902

9

Total tax. Add lines 7 and 8. Enter here and on line 2, page 1 .

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▶

Tax Computation (see instructions)

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Form 8697
Other (attach statement) .
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9

Form 1120-F (2018)

Page 6

Form 1120-F (2018)

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

Enter the amount from Section II, line 29 .

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2

Enter total adjustments to line 1 to get effectively connected earnings and profits.
showing the nature and amount of adjustments.) (See instructions.) . . . . .
3 Effectively connected earnings and profits. Combine line 1 and line 2 . . . .
4a Enter U.S. net equity at the end of the current tax year. (Attach required statement.)

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(Attach required
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1

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statement
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2
3
4a

DRAFT AS OF
August 21, 2018
DO NOT FILE

b Enter U.S. net equity at the end of the prior tax year. (Attach required statement.)
. . . . . . . .
c Increase in U.S. net equity. If line 4a is greater than or equal to line 4b, subtract line 4b from line 4a. Enter the
result here and skip to line 4e . . . . . . . . . . . . . . . . . . . . . . . .
d Decrease in U.S. net equity. If line 4b is greater than line 4a, subtract line 4a from line 4b

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4b

4c
4d

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

4e

5

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

5

6

Branch profits tax. Multiply line 5 by 30% (0.30) (or lower treaty rate if the corporation is a qualified resident
or otherwise qualifies for treaty benefits). (See instructions.) Enter here and include on line 3, page 1. Also
complete item W on page 2 . . . . . . . . . . . . . . . . . . . . . . . .

6

Part II—Tax on Excess Interest (see instructions for this Part and for Schedule I (Form 1120-F))
7 a Enter the interest from Section II, line 18 .

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7a

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b Enter the inverse of the total amount deferred, capitalized, and disallowed from Schedule I, line 24d (i.e., if line
24d is negative, enter as a positive number; if line 24d is positive, enter as a negative number) . . . . .
c Combine lines 7a and 7b (amount must equal Schedule I, line 23) . . . . . . . . . . . . .
8

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

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

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7b
7c

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8
9a

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b If the foreign corporation is a bank, enter the excess interest treated as interest on deposits (see instructions
for rules for computing this amount). Otherwise, enter -0-. . . . . . . . . . . . . . . .
c Subtract line 9b from line 9a . . . . . . . . . . . . . . . . . . . . . . . .

9b
9c

Tax on excess interest. Multiply line 9c by 30% (0.30) (or lower treaty rate if the corporation is a qualified
resident or otherwise qualifies for treaty benefits). (See instructions.) Enter here and include on line 3, page 1.
Also complete item W on page 2 . . . . . . . . . . . . . . . . . . . . . .

10

Part III—Additional Information

Yes
11

No

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

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b The tax-free liquidation or reorganization of a foreign corporation? .

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c The tax-free incorporation of a U.S. trade or business?

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If 11a or 11b applies and the transferee is a domestic corporation, attach Form 8848. If 11c applies, attach the statement required
by Temporary Regulations section 1.884-2T(d)(5).
Form 1120-F (2018)

Page 7

Form 1120-F (2018)

Note: Check if completing on ▶

Schedule L

U.S. basis or

Worldwide basis.

Balance Sheets per Books
Beginning of tax year

Assets
1
2a
b
3
4
5
6a
b
c
7
8

(a)

Cash . . . . . . . . . .
Trade notes and accounts receivable
Less allowance for bad debts . . .
Inventories . . . . . . . .
U.S. government obligations . . .
Tax-exempt securities (see instructions)
Interbranch current assets*
. . .
Other current non-U.S. assets*
. .
Other current U.S. assets* . . . .
Loans to shareholders . . . . .
Mortgage and real estate loans . .

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End of tax year
(b)

(c)

(d)

DRAFT AS OF
August 21, 2018
DO NOT FILE
(

9a Other loans and investments—non-U.S.
assets* . . . . . . . . . . .
b Other loans and investments—U.S. assets* .
10a Buildings and other depreciable assets . .
(
b Less accumulated depreciation . . . .
11a Depletable assets . . . . . . . .
(
b Less accumulated depletion . . . . .
12 Land (net of any amortization) . . . . .
13a Intangible assets (amortizable only) . . .
(
b Less accumulated amortization . . . .
14 Assets held in trust . . . . . . . .
15 Other non-current interbranch assets* . .
16a Other non-current non-U.S. assets* . . .
b Other non-current U.S. assets*
. . . .
17 Total assets . . . . . . . . . .

)

(

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(

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(

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(

)

Liabilities
18

Accounts payable

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19

Mortgages, notes, bonds
1 year:
a Interbranch liabilities* .
b Third-party liabilities* .
20 Other current liabilities* .
21 Loans from shareholders
22
a
b
23
24a
b

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payable in less than
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Mortgages, notes, bonds payable in
more:
Interbranch liabilities* . . . .
Third-party liabilities* . . . .
Liabilities held in trust . . . .
Other interbranch liabilities* . .
Other third-party liabilities* . . .

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1 year or
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Equity
25
26
27
28
29
30
31

a Preferred stock . .
b Common stock . .
Additional paid-in capital . . . .
Retained earnings—Appropriated* .
Retained earnings—Unappropriated .
Adjustments to shareholders’ equity* .
Less cost of treasury stock . . . .
Total liabilities and shareholders’ equity
Capital stock:

*Attach statement—see instructions.

(

)

(

)
Form 1120-F (2018)

Page 8

Form 1120-F (2018)

Schedule W

Overpayment Resulting From Tax Deducted and Withheld Under Chapters 3 and 4

1 Total Chapter 3 and 4 payments. Enter the amount from page 1, line 5i

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2 Enter the tax amount from page 1, line 1 . . . . . . . . . . . .
3 Enter the portion of the tax amount shown on page 1, line 2 pertaining to
income associated with amounts deducted and withheld under sections 1445
and 1446 (see instructions for general guidelines) . . . . . . . . .

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1

2

DRAFT AS OF
August 21, 2018
DO NOT FILE

3
4 Total Chapter 3 and 4 tax. Combine lines 2 and 3
. . . . . . . . . . . . .
5 Tentative overpayment resulting from tax deducted and withheld under Chapters 3 and 4.
Subtract line 4 from line 1 . . . . . . . . . . . . . . . . . . . . .
6 Enter the amount from page 1, line 8a . . . . . . . . . . . . . .
7 Overpayment resulting from tax deducted and withheld under Chapters 3 and 4.
Enter the smaller of line 5 or line 6. Enter the result here and on page 1, line 8b . .

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4

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5
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7

Form 1120-F (2018)