1120-F Schedule I Instructions for Form 1120-F Schedule I

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2021

Department of the Treasury
Internal Revenue Service

Instructions for Schedule I
(Form 1120-F)

DRAFT AS OF
November 2, 2021

Interest Expense Allocation Under Regulations Section 1.882-5
Section references are to the Internal Revenue
Code unless otherwise noted.

(SOFR). For details, see the instructions
for line 10, later.

Future Developments

General Instructions

For the latest information about
developments related to Schedule I
(Form 1120-F) and its instructions, such
as legislation enacted after they were
published, go to IRS.gov/Form1120F.

What’s New
The following changes have been made
to the 2021 Schedule I (Form 1120-F).
On page 3 of Schedule I (Form 1120-F),
lines 24a, 24b, and 24c were amended
and lines 24d, 24e, and 24f were added
to reflect final regulations that provide
guidance about the limitation on the
deduction for business interest expense
(T.D. 9905, 85 FR 56760, Sept. 14,
2020, as amended by T.D. 9943, 86 FR
5529, Jan. 19, 2021). These changes
also provide for a more efficient flow of
information from Schedule I (Form
1120-F) to Schedule M-3 (Form
1120-F). See the instructions for lines
24a through 24f for details.
On Schedule I (Form 1120-F) and
throughout these instructions, line
references to Schedule P (Form
1120-F) have been updated because
Schedule P (Form 1120-F) was
extensively revised to reference new
Schedule K-3 (Form 1065).

Reminders
Line 10 (published rate election for
banks). On page 2 of the form, line 10
has been modified as follows. All
references to "30-day LIBOR" have
been deleted and replaced with
references to "a published rate" as
provided under Regulations section
1.882-5(d)(5)(ii)(B). These changes
were made to reflect that fact that on
October 9, 2019, proposed regulations
were issued pertaining to the transition
from interbank offered rates (IBORs) to
new rates. See REG-118784-18, 84 FR
54068. For tax years ending after
October 9, 2019, a corporation that is a
foreign bank may elect (on line 10) to
use a secured overnight financing rate
Oct 29, 2021

Purpose of Schedule

Schedule I (Form 1120-F) is used to
report the amount of interest expense
allocable to effectively connected
income (“ECI”) and the deductible
amount of such allocation for the tax
year under section 882(c) and
Regulations section 1.882-5. The
schedule discloses the basic
calculations for the year and also
identifies the various elections the
taxpayer uses under Regulations
sections 1.882-5(a)(7) and (d)(5), and
under the branch profits tax rules of
Regulations section 1.884-1(e)(3).

Note. The tax election under
Regulations section 1.884-1(e)(3) is not
effectuated under the regulations by its
identification on Schedule I (Form
1120-F). See the requirements for the
time, place, and manner for making the
branch profits tax liability reduction
election under Regulations section
1.884-1(e)(3).
Under Regulations section 1.882-5,
the amount of interest expense of a
foreign corporation that is allocable
under section 882(c) to income which is
effectively connected (or treated as
effectively connected) with the conduct
of a trade or business within the United
States is the sum of the interest
expense allocable by the foreign
corporation under the three-step
process set forth in Regulations
sections 1.882-5(b), (c), and (d), or (e)
and the directly allocated interest
expense determined under Regulations
section 1.882-5(a)(1)(ii). The interest
allocation rules of Regulations section
1.882-5 are the exclusive rules for
allocating interest expense under
section 882(c) to ECI and for attributing
interest expense to business profits of a
U.S. permanent establishment under all
income tax treaties other than treaties
that expressly permit attribution of
business profits to a U.S. permanent
establishment under application of the
Cat. No. 50606A

OECD Transfer Pricing Guidelines, by
analogy. If the foreign corporation files
its tax return using a treaty-based
method of the type provided in these
treaties, see Treaty-based return
positions below for reporting
requirements.

Who Must File

All foreign corporations that have
interest expense allocable to ECI under
section 882(c) must complete
Schedule I to report this allocation,
regardless of whether the amount
allocable under Regulations section
1.882-5 is deductible in the current year,
or is otherwise deferred or permanently
disallowed under other sections of the
Internal Revenue Code (for example,
sections 163(e), 163(j), 263A, 265(a)
and 267(a)(3)). The information
reported on Schedule I is also needed
to complete Form 1120-F, Section III
(the determination of the branch-level
interest tax under section 884(f)).
Interest expense that is treated as
“branch interest” under Regulations
section 1.884-4(b) may be subject to
information reporting under section
1461 or section 6049 and potential
withholding under sections 1441 and
1442. A foreign corporation that is a
reporting corporation and required to file
Form 1120-F must complete Schedule I
and attach it to Form 1120-F.
Reporting corporation. A reporting
corporation is any foreign corporation
that is engaged in a trade or business or
treated as engaged in a trade or
business within the United States
directly or indirectly at any time during
the tax year.
Treaty-based return positions. If the
corporation determines its interest
expense attributable to its business
profits of a U.S. permanent
establishment pursuant to the express
provisions and accompanying
documents of an applicable treaty, then
Schedule I still must be completed
based on the treaty method used
(substituting the amount of assets,
liabilities, and interest expense
determined under the treaty method for

the amounts that would have been
reported under Regulations section
1.882-5) and attached to Form 1120-F.
The corporation is also required to
complete and attach Form 8833,
Treaty-Based Return Position
Disclosure.

Exceptions from Filing
Schedule I

separate currency pools method is an
election that must generally be
maintained for a minimum 5-year
period. However, the election available
to foreign banks to use a published rate
under the AUSBL method in Step 3
must be made each year. If a
corporation is subject to Regulations
section 1.882-5 for the first time, the
election is due with a timely filed return
(excluding the additional extended
period provided by Regulations section
1.882-4(a)(3)) whether or not the
taxpayer files a protective return under
Regulations section 1.882-4(a)(3)(vi).
The protective election need not be filed
with subsequent protective returns filed
under Regulations section 1.882-4(a)(3)
(vi) for any subsequent year to which
the minimum 5-year period applies.
However, the indication of the election
with a protective return is only effective
for a year that the corporation is
engaged in trade or business within the
United States. Accordingly, if a
protective election is made for a first
year protective return and in fact the
taxpayer is not engaged in trade or
business until the second year of activity
within the United States, the protective
election made in the first year is not
effective for the corporation's second
year of activity because Regulations
section 1.882-5 is not applicable to the
corporation until such second year. The
elections used by a taxpayer for all
years in which it files Form 1120-F and
reports ECI must be shown on
Schedule I, including years subsequent
to the year in which an election under
Regulations section 1.882-5(a)(7) is
made.
A corporation that files a protective
return under Regulations section
1.882-4(a)(3)(vi) need not enter
amounts on Schedule I (other than for
the published rate election on line 10d)
in order to preserve an allocation
method. If a taxpayer files a protective
return under Regulations section
1.882-4(a)(3)(vi) and does not file
Schedule I to identify the relevant
elections under Regulations section
1.882-5 for an applicable year, then the
Director of Field Operations is
authorized to make all applicable
allocation method elections on behalf of
the corporation for such applicable year
if it is later determined that the taxpayer
was engaged in trade or business within
the United States and had ECI during
the year.

amended return. In addition, the relief
for late tax elections provided under the
rules of Regulations section 301.9100-1
(and any guidance promulgated
thereunder) is not available.

Other Forms and Schedules
Related to Schedule I

DRAFT AS OF
November 2, 2021

A foreign corporation is not required to
file Schedule I if it (a) does not have a
trade or business within the United
States, (b) has no worldwide interest
expense for the tax year to allocate
under Regulations section 1.882-5, or
(c) conducts limited activities in the
United States for the tax year that it
determines do not give rise to ECI or do
not give rise to a U.S. permanent
establishment to which business profits
are attributable, and the corporation
files a protective income tax return
under Regulations section 1.882-4(a)(3)
(vi).

Protective elections on protective
returns. A corporation that files a
protective tax return on Form 1120-F
under Regulations section 1.882-4(a)(3)
(vi) may voluntarily file Schedule I with
the protective return to preserve timely
elections under Regulations section
1.882-5(a)(7) if the return is filed by the
original due date (including extensions)
of the corporation's Form 1120-F. The
protective elections are not effective if
filed during the additional extended
period described under Regulations
section 1.882-4(a)(3). The foreign
corporation need only complete the
relevant portions of Schedule I that
identify its right to use the following
elections:
• The Adjusted U.S.-Booked Liability
method (“AUSBL”) or Separate
Currency Pools (“SCP”) method (item B
checkboxes);
• The actual or fixed ratio in Step 2
(line 6 checkboxes);
• The published rate election for banks
under the AUSBL method in Step 3
(line 10 checkbox); and
• The de minimis foreign currency
election under the Separate Currency
Pools method in Step 3 (line 16b check
box).
The corporation need only identify
the protective election in the first year it
is required to be made under
Regulations section 1.882-5(a)(7) or in
any year a taxpayer is eligible to adopt
or change an election and chooses to
do so for that year. For example, an
election to use the adjusted
U.S.-booked liability method or the

Note. Under Regulations section
1.882-5(a)(7), no interest expense
allocation elections may be made on an
-2-

Form 1120-F, Schedule L, and
Schedule M-3 (Form 1120-F). The set
or set(s) of books that give rise to
U.S.-booked liabilities under
Regulations section 1.882-5(d)(2) are
the same sets of books and records that
are reportable as of the tax year end on
Form 1120-F, Schedule L. They are
also the same sets of books and
records that are used by foreign banks
to report income and expenses on
Schedule M-3 (Form 1120-F).

Form 1120-F, Section III, Part II
(branch-level interest tax). The
amount of interest expense from
Schedule I, line 24g is reportable on
Form 1120-F, Section III, Part II, line 7b.
The amount of the allocation under
Regulations section 1.882-5 reportable
on Schedule I, line 23 is reportable on
Form 1120-F, Section III, Part II, line 7c.
Schedule M-3 (Form 1120-F), Part III,
lines 26b and 26c. The amount of
interest expense allocation reportable
on Schedule I, line 23 is includible on
Schedule M-3 (Form 1120-F), Part III,
line 26b, columns (d) and (e). The
amounts subject to deferral and
disallowance on Schedule I, lines 24a
through 24f are reportable on
Schedule M-3 (Form 1120-F), Part III,
line 26c, columns (b), (c), and (e).
Schedule P (Form 1120-F). Enter
amounts from Schedule P (Form
1120-F), lines 13, 11, 8, and 7 on
Schedule I, line 5, column (b); line 8,
column (b); line 9, column (b), and
line 22; respectively, making any
necessary adjustments to comply with
the rules in Regulations section 1.882-5.
Form 8990, Limitation on Business
Interest Expense Under Section
163(j). Business interest expense
includes any interest paid or accrued on
indebtedness properly allocable to a
trade or business. Business interest
expense is generally limited to the sum
of business interest income, 30% of the
adjusted taxable income, and floor plan
financing interest. Form 8990 is
required, unless an exception for filing is
met. For more information, see section
163(j), Form 8990, and the Instructions
for Form 8990.

Instructions for Schedule I (Form 1120-F) (2021)

Assets and Liabilities Based on
Schedule L Set(s) of Books and
Records

Generally, the assets and liabilities
required to be reported on Schedule L
are the total assets and liabilities
reflected on the set or sets of books of
the foreign corporation that give rise to
income effectively connected with the
corporation's trade or business within
the United States and to U.S.-booked
liabilities (as defined in Regulations
section 1.882-5(d)(2)). The total assets
and liabilities reflected on such books
include the third party U.S. assets (as
defined in Regulations section
1.884-1(d)) and third party liabilities
(whether with related or unrelated
parties), as well as the interbranch
assets and liabilities and assets that
give rise to noneffectively connected
income in whole or in part. Such books
reflect the assets of the foreign
corporation located in the United States
and all other of its assets used in its
trade or business within the United
States (other than its assets giving rise
to ECI under sections 864(c)(6) or (7)),
as authorized under Regulations section
1.6012-2(g)(1)(iii). A foreign corporation
may instead report its worldwide assets,
liabilities, and equity on Schedule L.

Regulations section 1.884-4(a)(2).
Line 8, column (c), and line 9, column
(c) are also included in the interest
expense allocation computation in Step
3 of the AUSBL method if elected by the
corporation.
Lines 1 through 9 must be
completed by all corporations
CAUTION required to file Schedule I,
regardless of whether the corporation
allocates interest expense under the
AUSBL or Separate Currency Pools
method for the applicable year.

!

on Form 1120-F, Section III, Part II,
line 7c (branch-level interest tax).
Line 24. Deferrals and
disallowances under other Code
sections. The interest expense
allocation reportable on line 23 is
determined under Regulations section
1.882-5 before application of other
Code sections that defer or disallow the
interest deduction in whole or in part.
See Regulations section 1.882-5(a)(5).

DRAFT AS OF
November 2, 2021

If the foreign corporation has more
than one set of books and records
relating to assets located in the United
States or assets used in a trade or
business conducted in the United
States, it must report the combined
amounts on Schedule L and must
eliminate asset and liability amounts
recorded between these books.

Required Reporting on
Schedule I
Lines 1 through 9. Schedule I requires
disclosure of data and interest allocation
elections for all parts of the three-step
formula under Regulations section
1.882-5. On page 1, the corporation is
required to complete Step 1 (lines 1
through 5) to determine its average U.S.
assets, Step 2 (lines 6 through 7c) to
determine its U.S.-connected liabilities,
and Step 3 (lines 8 and 9) to determine
its U.S.-booked liabilities under
Regulations section 1.882-5(d)(2) and
its related U.S.-booked interest
expense. The total on line 9, column (c)
is also used for purposes of determining
the corporation's branch interest under
section 884(f)(1)(A) and Regulations
section 1.884-4(b), and in the
calculation of the corporation's
branch-level interest tax on excess
interest under section 884(f)(1)(B) and

Lines 10 through 20. Allocations, direct interest allocations, deferrals
and other disallowances. Step 3 of
the AUSBL method is provided on lines
10 through 15. Step 3 of the Separate
Currency Pools method is provided on
lines 16a through 20. These Step 3
methods are mutually exclusive and
cannot both apply to the corporation in
the same year. The methods are subject
to the general 5-year minimum period
election rules of Regulations section
1.882-5(a)(7).
AUSBL method filers. AUSBL
method filers complete all columns on
lines 1 through 15 and lines 21 through
25. Do not complete lines 16a through
20.
Separate currency pools method
filers. Separate Currency Pools
method filers complete all columns on
lines 1 through 9 and lines 16a through
25. Do not complete lines 10 through
15.
Lines 21 through 25. Summary – Interest expense allocation and deduction under Regulations section
1.882-5. All corporations required to file
Schedule I must report the summary
amounts requested on lines 21 through
25.
Line 22. Direct interest
allocations. Interest expense that is
directly allocable under Regulations
section 1.882-5(a)(1)(ii) in accordance
with the rules of Temporary Regulations
section 1.861-10T(b) or (c) is reported
on line 22.
Line 23. Summary of Regulations
section 1.882-5 allocation. The
amount of interest expense allocable to
ECI under Regulations section 1.882-5
is the sum of the amount allocated
under either the AUSBL or Separate
Currency Pools method on line 15 or 20,
and the amount directly allocated to ECI
and reportable on line 22. The resulting
amount allocable and reported on
line 23 is also reconciled and reported

Instructions for Schedule I (Form 1120-F) (2021)

-3-

Specific Instructions

Item A. Foreign banks. Check the box
in item A if the foreign corporation is a
bank as defined in Regulations section
1.882-5(c)(4). The term “bank” is
defined in the regulation as a bank that
meets the statutory definition applicable
to domestic banks (except for the fact
that the corporation is foreign) and
without regard to whether the
corporation's required banking activities
are effectively connected with its trade
or business within the United States.
The required banking activities need
only be conducted on a worldwide
basis. To qualify as a bank for interest
expense allocation purposes, the
foreign corporation must be subject to
bank regulatory supervision and
examination in its home country of a
type similar to that required of domestic
banks by a State or Federal authority
having supervision over banking
institutions, and a substantial amount of
the corporation's business must consist
of receiving deposits and making loans
and discounts, or of exercising fiduciary
powers similar to those permitted to
national banks under authority of the
Comptroller of the Currency. See
sections 581 and 585(a)(2).
Note. The reference to the definition of
the term “bank” for purposes of
determining the U.S.-booked liabilities
of banks under Regulations section
1.882-5(d)(2)(iii) requires that the
corporation meet the section 585(a)(2)
regulated banking requirements in its
trade or business within the United
States. The section 585(a)(2) standard
must also be satisfied at the
corporation's U.S. trade or business
level for purposes of electing the
deposit liability safe harbor applicable to
the reduction of excess interest under
Regulations section 1.884-4(a)(2)(iii).

Lines 1 Through 9: All
Foreign Corporations
Lines 1 Through 5. Step 1:
Determination of Total Value of
U.S. Assets

Assets includible on lines 1 through 5
are the U.S. assets of the corporation as
defined in Regulations sections
1.882-5(b) and 1.884-1(d). The U.S.
assets are valued on an average basis
for interest expense allocation
purposes.

corporation recognizes an amount
recorded as an interbranch asset, such
amount is treated as the allocation and
source of third-party securities dealing
income and is not eliminated from U.S.
assets on line 3a, column (a). Such
interbranch assets are eliminated only
to the extent they are allocated under
Proposed Regulations section
1.863-3(h) to foreign source non-ECI.
The allocable amount to non-ECI is
eliminated from U.S. assets on line 3c,
column (a) (total other non-ECI assets).

authority agreement. See Proposed
Regulations sections 1.884-1(d)(2)(vii)
and 1.884-1(d)(2)(xi), Example 8.
Attach a statement which describes
each type of “other” non-ECI asset
included on line 3c. For each type, show
the calculation of the amount included
on line 3c for that type, including a total
for each type.

DRAFT AS OF
November 2, 2021

Frequency of averaging. The
average value of assets for this step is
to be computed at the most frequent,
regular intervals for which data is
reasonably available. For foreign banks,
the minimum averaging period is
monthly (beginning of tax year and
monthly thereafter). For corporations
other than a bank, the minimum
averaging period is semi-annually
(beginning, middle, and end of the tax
year). See Regulations section
1.882-5(b)(3).
Line 1. Under section 864(e)(2), the
foreign corporation must value its U.S.
assets on the adjusted basis method
(see Regulations section 1.882-5(b)(2)
(i)). The adjusted basis method election
is subject to the minimum 5-year period
described in Regulations section
1.882-5(a)(7).
On line 1, you must check the
box for adjusted basis method.
CAUTION Do not check the box for fair
market value method.

!

Line 2, column (a). Total assets per
books. Enter the total average assets
derived from the combined set or sets of
books that are reportable on
Schedule L. The total average assets
include interbranch balances with other
sets of books of the corporation that are
not reportable on Schedule L.
Line 3a, column (a). Total interbranch assets. Enter on line 3a,
column (a), the total of the corporation's
average interbranch assets included on
line 2, column (a). The average
interbranch assets recorded on the
set(s) of Schedule L books do not
create U.S. assets under Regulations
section 1.882-5(b)(1)(iv) and are
disregarded for purposes of the interest
expense allocation rules.
Note. If under the global dealing
proposed regulations (Proposed
Regulations section 1.863-3(h), which
references the Proposed Regulations
section 1.482-8 principles), the

Line 3b, column (a). Total non-ECI
assets under section 864(c)(4)(D).
Enter on line 3b, column (a), the
average assets included on line 2,
column (a) that give rise to non-ECI
received from foreign-related
corporations under section 864(c)(4)
(D). Such amounts include assets from
transactions with foreign-related
corporations that give rise to foreign
source dividends, interest, rents or
royalties, whether or not such amounts
are attributable to a U.S. office of the
corporation under section 864(c)(5). A
foreign related corporation is a foreign
corporation the taxpayer owns (under
section 958(a)) or is treated as owning
(under section 958(b)) more than 50%
of the total combined voting power of all
classes of stock entitled to vote. Enter
the average asset number for assets
described in section 864(c)(4)(D) on
line 3b, column (a), regardless of
whether such assets give rise to
non-ECI under another Code section or
regulation. For example, report income
that is non-ECI under section 864(c)(4)
(D) on line 3b, column (a) even if such
income is also not attributable to a U.S.
office of a banking, financing, or similar
business under Regulations section
1.864-6(b)(2)(ii)(b) and the principles of
Regulations section 1.864-4(c)(5)(ii).

Line 3c, column (a). Total other
non-ECI assets. Enter on line 3c,
column (a), all other assets (or portion
thereof) included on line 2, column (a)
that give rise to domestic or foreign
source non-ECI. If income from a
security is treated as partially ECI and
partially non-ECI under Regulations
section 1.864-4(c)(5)(ii), enter the
amount of the asset on line 3c, column
(a) in the proportion that the income,
gain, or loss from such asset that is
treated as non-ECI bears to the total
income, gain, or loss from such asset.
Do the same for the non-ECI portion of
any asset whose income is allocated
under the proposed global dealing
regulations or under an Advance Pricing
Agreement pursuant to a competent
-4-

Line 3d, column (a). Adjustments for
amounts from partnerships and certain disregarded entities included on
line 2, column (a). With respect to
amounts from partnerships included on
line 2, column (a), all such amounts
must be “backed out” on this line 3d,
column (a). Enter on line 3d, column (a),
all amounts on the Schedule L books for
investments in partnerships (whether
recorded as an investment in the
partnership interest or in the partnership
assets) included on line 2, column (a).
Note. Partnership interests are
reported in Step 1 as follows: The
corporation's adjusted outside basis in a
partnership (from Schedule P (Form
1120-F), line 13, “Total” column) that is
treated as a U.S. asset under
Regulations sections 1.882-5 and
1.884-1(d)(3) is generally entered on
Schedule I (Form 1120-F), line 5,
column (b).
With respect to amounts from
disregarded entities included on line 2,
column (a), enter on line 3d, column (a)
any adjustment needed to reflect the
following: Investments in disregarded
entities should not be included on line 2,
column (a) if the set(s) of books are
reportable on Schedule L. Instead, the
total assets of such disregarded entity's
Schedule L books should be combined
on line 2, column (a) with all other set(s)
of books reportable on Schedule L. If
another Schedule L book reflects an
investment in a disregarded entity
whose books are not reportable on
Schedule L, then the assets of the
disregarded entity are not reported on
line 2, column (a). The amount of the
investment in the disregarded entity that
is included in the total assets reported
on line 2, column (a) must be reversed
on line 3d, column (a) to reflect its
disregarded treatment in Regulations
section 1.882-5.
Line 3e, column (a). Adjustments for
assets that give rise to direct interest expense allocations under Regulations section 1.882-5(a)(1)(ii).
Enter on line 3e, column (a), the
average value of the portion of all assets
included on line 2 that give rise to direct
interest expense allocations under

Instructions for Schedule I (Form 1120-F) (2021)

Regulations section 1.882-5(a)(1)(ii) in
accordance with the requirements of
Temporary Regulations section
1.861-10T(b) or (c), and Temporary
Regulations section 1.861-10T(d). A
foreign corporation that allocates its
interest expense under the direct
allocation rules shall reduce the basis of
the asset that meets the requirements of
Temporary Regulations section
1.861-10T (b) or (c) by the principal
amount of the indebtedness that meets
the requirements of Temporary
Regulations section 1.861-10T (b) or
(c). The amount of directly allocable
interest under Regulations section
1.882-5(a)(1)(ii) is reported on line 22.

amount on line 5, column (a). The
resulting amount is the total average
value of U.S. assets under Regulations
section 1.884-1(d) included on the
Schedule L set(s) of books, excluding
any partnership interests included on
line 2.
Line 5, column (b). Average value of
partnership interests that is a U.S.
asset. Because the corporation is
required to value its U.S. assets under
the adjusted basis method, enter on
line 5, column (b), the amount from
Schedule P (Form 1120-F), line 13
(“Total” column) that is treated as a U.S.
asset under Regulations sections
1.882-5 and 1.884-1(d)(3). This amount
is the sum of the corporation's outside
basis in partnership interests as
adjusted under Regulations section
1.884-1(d)(3). The amount entered from
Schedule P, line 13 may include the
corporation's outside basis in
partnerships whose book value is
included on line 2, column (a) as well as
partnership interests whose book value
is not recorded on the Schedule L
books and is not included on line 2,
column (a).

amount is the total average value of the
corporation's U.S. assets included in
Step 1 of the Regulations section
1.882-5 formula. If the corporation uses
the Separate Currency Pools method to
allocate interest expense in Step 3 of
the Regulations section 1.882-5
formula, see the instructions for
line 16a, later. The amount on line 5,
column (d) is also reportable on
Schedule H (Form 1120-F), line 22a.

DRAFT AS OF
November 2, 2021

Line 3f, column (a). Other adjustments to average assets included on
line 2. Enter on line 3f, column (a), the
average asset balances for any other
amounts included on line 2, column (a)
that do not constitute U.S. assets as
defined in Regulations section
1.884-1(d). Assets includible on this line
may include, for example, amounts with
respect to securities that are
marked-to-market for tax purposes
under section 475 that are not
marked-to-market on the set(s) of books
reported on line 2, column (a). If the
mark-to-market amount includible for
tax purposes is an increase to the basis
of the assets included on line 2, column
(a), include such increase as a negative
number on line 3f, column (a). Similarly,
if the mark-to-market amount decreases
the basis of the assets included on
line 2, column (a), include such
decrease as a positive number on
line 3f, column (a). Other adjustments
for book-to-tax differences with respect
to asset values on line 2, column (a),
such as depreciation and amortization
for taxpayers using the adjusted basis
method for valuing U.S. assets, are also
reportable on line 3f, column (a). Enter
an aggregate net increase as a negative
number. Enter an aggregate net
decrease as a positive number.
Line 4, column (a). Combine lines 3a
through 3f and enter the result on line 4,
column (a). The result on line 4, column
(a) constitutes the total net adjustment
to the average book assets from the
Schedule L set(s) of books reported on
line 2, column (a).

Line 5. Total Value of U.S. Assets
for the Tax Year
Line 5, column (a). Average U.S. assets on set(s) of Schedule L books.
Subtract the amount on line 4, column
(a) from line 2, column (a) and enter the

Line 5, column (c). Average U.S. assets not includible in set(s) of
Schedule L books reported on line 5,
column (a), or from partnerships reported on line 5, column (b). Enter
on line 5, column (c), the average value
of U.S. assets (other than the
corporation's outside basis in
partnership interests that is a U.S.
asset) from set(s) of books that are not
reportable on Schedule L. Such assets
may generally include certain securities
attributable to a U.S. office of a banking,
financing, or similar business under
Regulations section 1.864-4(c)(5)(iii)
that are booked in a foreign bank's
home office or other foreign location.
Other assets reportable on line 5,
column (c), may generally also include
assets that are no longer held in
connection with a trade or business
within the United States that give rise to
ECI under section 864(c)(6) or section
864(c)(7). However, not all assets that
give rise to ECI, including ECI
recognized under section 864(c)(7),
constitute U.S. assets under
Regulations section 1.884-1(d). See
Regulations section 1.884-1(d)(2)(xi),
example 5, and Regulations section
1.884-1(d)(5).
Line 5, column (d). Total average
value of U.S. assets included in Step
1. Combine the amounts on line 5,
columns (a), (b), and (c) and enter the
amount on line 5, column (d). This

Instructions for Schedule I (Form 1120-F) (2021)

-5-

Lines 6 Through 7c. Step 2:
Determination of
U.S.-Connected Liabilities Regulations Section 1.882-5(c)

Line 6. Actual ratio or fixed ratio
method. Check the applicable box to
specify whether the corporation uses
the actual ratio or the fixed ratio method
for the tax year to determine its
U.S.-connected liabilities in Step 2 of
the allocation formula. The amount of
U.S.-connected liabilities is the total
value of U.S. assets for the tax year
(line 5, column (d)) multiplied by the
actual ratio or the applicable fixed ratio
the corporation has timely elected and is
eligible to use for the tax year. The
actual ratio or fixed ratio election must
be made on a timely filed tax return for
the first year the corporation is subject
to Regulations section 1.882-5 and is
subject to the minimum 5-year period
under Regulations section 1.882-5(a)
(7). An election to change the method
after such minimum 5-year period is
also subject to the minimum 5-year
period.
Actual ratio information. If the
corporation uses the actual ratio,
complete lines 6a through 6c and skip
line 6d.
Fixed ratio information. If the
corporation uses the fixed ratio, skip
lines 6a through 6c and enter the
applicable fixed ratio on line 6d. For
foreign banks (described in Regulations
section 1.882-5(c)(4)), the fixed ratio is
95%. For corporations other than
foreign banks and insurance
companies, the fixed ratio is 50%.

Actual Ratio Filers — Regulations
Section 1.882-5(c)
Line 6a. Average worldwide liabilities. Enter on line 6a the average
worldwide liabilities as adjusted for U.S.
tax principles for the year. The
corporation's worldwide liabilities
include the liabilities of only the
corporation filing the Form 1120-F, plus
the corporation's share of partnership
liabilities and any liabilities of any

disregarded entities that are treated as
liabilities of the foreign corporation
under U.S. tax principles. The books of
the foreign corporation and any such
disregarded entities must be combined,
with applicable eliminating entries for
transactions between them. See
Regulations section 1.882-5(c)(2)(viii).
The classification of the worldwide
liabilities is determined under U.S. tax
principles. See Regulations section
1.882-5(c)(2)(ii). The value of the
worldwide liabilities must be determined
substantially in accordance with U.S.
tax principles. Foreign banks must
average the worldwide liabilities using
the beginning, middle, and end of year
values. Corporations other than banks
must average the worldwide liabilities
using the year-to-year values of its
liabilities.

the liability reduction election and the
separate disclosures required to be
attached to Form 1120-F for each
liability reduction election made.
If the corporation uses the Separate
Currency Pools Method for Step 3 (lines
16a through 20), the amount included
on line 7b must also be allocated to
determine the U.S.-connected liabilities
for each currency. See the instructions
for lines 7c below and line 17b, later. If
no liability reduction election is made for
the tax year, enter -0- on line 7b.

liability amounts on line 8a to the extent
they give rise to directly allocable
interest under Regulations section
1.882-5(a)(1)(ii) or are partnership
liabilities includible in column (b).
• Corporations other than banks.
The definition of U.S.-booked liability for
a foreign corporation other than a bank
is described in Regulations section
1.882-5(d)(2)(ii). Liabilities reflected on
the Schedule L books must be recorded
on such books reasonably
contemporaneous to the time the
liability is incurred.
• Foreign banks. The liability
recorded on the set(s) of Schedule L
books must be that of a foreign bank
that conducts regulated banking
operations in the United States as
described in section 585(a)(2)(B). Note:
This requirement applies only for the
determination of U.S.-booked liabilities
and corresponding U.S.-booked interest
expense. It does not apply for other
purposes such as determining the
eligibility for the fixed ratio under Step 2,
reportable on line 6d. The liability must
be recorded on the Schedule L books
before the close of the day on which the
liability is incurred unless an inadvertent
error is shown under the facts and
circumstances. See the definition and
requirements for U.S.-booked liabilities
of foreign banks under Regulations
section 1.882-5(d)(2)(iii). Note: The
section 585(a)(2)(B) standard also
applies for eligibility to reduce excess
interest using the deposit liability safe
harbor under the branch-level interest
tax on excess interest under
Regulations section 1.884-4(a)(2)(iii).

DRAFT AS OF
November 2, 2021

Line 6b. Average worldwide assets.
Enter the average worldwide assets as
adjusted for U.S. tax principles on
line 6b, using the same nonconsolidated
books for reporting average worldwide
liabilities on line 6a. Transactions with
disregarded entities included in the
actual ratio computation constitute
interbranch transactions under U.S. tax
principles and must be eliminated. See
Regulations section 1.882-5(c)(2)(viii).
Use the same averaging period
applicable to worldwide liabilities. If the
corporation uses the actual ratio
method, the amount entered on line 6b
is also reported on Schedule H (Form
1120-F), line 22b.

Fixed Ratio Filers — Regulations
Section 1.882-5(c)(4)
Line 7a. U.S.-connected liabilities
before Regulations section
1.884-1(e)(3) election(s). Multiply the
average U.S. assets from line 5, column
(d), by the ratio entered on line 6e and
enter the result on line 7a. The result is
the amount of U.S.-connected liabilities
determined before the application of any
liability reduction election(s) made
under Regulations section 1.884-1(e)
(3).
Line 7b. U.S. liability reduction election amount. Enter the total amount of
U.S. liability reductions made under
Regulations section 1.884-1(e)(3) for
the current year.
Note. A liability reduction election may
be made only to the extent needed to
reduce a dividend equivalent amount
under section 884(b) to zero. See
Regulations section 1.884-1(e)(3)(iv) for
the time, place, and manner for making

Line 7c. U.S.-connected liabilities.
Subtract line 7b from line 7a and enter
the amount on line 7c. The amount
entered is the amount of
U.S.-connected liabilities for purposes
of determining the amount of interest
expense allocable to ECI in Step 3. If
the corporation uses the Separate
Currency Pools Method for Step 3, the
sum of all U.S.-connected liabilities
shown on line 17b (including any
statements for lines 16a through 19 for
additional separate currency pool
computations) must equal the amount
shown on line 7c after the liability
reduction election has been taken into
account.

Lines 8 and 9. Step 3: Interest
Expense Allocation (Including
U.S.-Booked Liabilities and
U.S.-Booked Interest Expense
Included in the Determination
of Branch Interest)
Line 8. Average Third Party
U.S.-Booked Liabilities
Line 8, column (a). Schedule L
U.S.-booked liabilities. Enter on
line 8, column (a), the average amount
of third-party U.S.-booked liabilities from
the set(s) of books reportable on
Schedule L using the most frequent
averaging period available but not less
frequently than the minimum averaging
periods required for U.S. assets
reported on line 5. The average
U.S.-booked liabilities include all
third-party liabilities on the set(s) of
Schedule L books whether interest
bearing or not. Exclude interbranch
liabilities shown on the Schedule L
books unless such amounts are treated
as allocations of third-party amounts
with respect to a global dealing
operation under Proposed Regulations
section 1.863-3(h) (for example,
mark-to-market valuations of dealer
derivative securities may constitute
liabilities that are treated as
U.S.-booked liabilities includible on
line 8, column (a)). Do not include
-6-

Line 8, column (b). U.S.-booked liabilities of partnership interests.
Enter on line 8, column (b), the portion
of the amount from Schedule P, line 11
(“Total” column) that constitutes U.S.
booked liabilities under Regulations
section 1.882-5(d)(2). This amount is
the corporation's average U.S.-booked
liabilities with respect to its distributive
share of liabilities during the averaging
period from partnerships engaged in
trade or business within the United
States. The amount reportable on line 8,
column (b), is the corporation's share of
partnership liabilities for which it is
allocated a distributive share of interest
expense. See Regulations section
1.884-1(d)(3)(vi).

Line 9. U.S.-Booked Interest
Expense
Line 9, column (a). Schedule L
booked interest expense. Enter the
amount of third-party interest expense

Instructions for Schedule I (Form 1120-F) (2021)

from the Schedule L set(s) of books with
respect to liabilities reported on line 8,
column (a). Do not include interest
expense that is directly allocable under
Regulations section 1.882-5(a)(1)(ii),
including the corporation's distributive
share of direct interest expense
allocations from partnerships otherwise
reportable in column (b). All direct
interest expense allocations to ECI are
reported on line 22.

the box on line 10 and skip lines 10a
through 10c. Enter the published rate on
line 10d. See Regulations section
1.882-5(d)(5)(ii)(B) for additional
information. The published rate election
does not apply to corporations other
than foreign banks. For this purpose,
the corporation is eligible to make the
published rate election under the same
standard that qualifies the corporation
as a bank eligible to make the 95% fixed
ratio election in Regulations section
1.882-5(c)(4). The published rate
election is an annual election.

U.S.-booked liabilities or an average
arm's length rate of interest that would
be charged to the foreign corporation on
its interest-bearing U.S.-dollar
denominated liabilities. A U.S.-dollar
borrowing rate of zero would generally
not be considered reasonable.
If the rules set forth above apply to
the foreign corporation, attach a
statement to Schedule I (Form 1120-F)
explaining how the interest rate entered
on line 10e was derived.

DRAFT AS OF
November 2, 2021

Line 9, column (b). U.S.-booked interest expense from partnerships.
Enter on line 9, column (b), the portion
of the amount from Schedule P (Form
1120-F), line 8 (“Total” column) that is
interest expense on U.S.-booked
liabilities. Do not include interest
expense that is directly allocable under
Regulations section 1.882-5(a)(1)(ii)
from the corporation's distributive share
of a partnership's direct interest
expense allocations. All direct interest
expense allocations to ECI are reported
on line 22.

Line 9, column (c). Total
U.S.-booked interest expense. Add
the amounts on line 9, column (a), and
line 9, column (b) and enter the result on
line 9, column (c). This result is also
required to be reported on Form 1120-F,
Section III, line 8. This amount plus
line 22 is the corporation’s tentative
branch interest for purposes of the
branch level interest tax under
Regulations section 1.884-4(b). See the
instructions for Form 1120-F, Section III,
Part II, line 8.

Lines 10 Through 15. Step
3: Adjusted U.S.-Booked
Liabilities Method

If the amount on line 7c exceeds the
amount on line 8, column (c), the
corporation has “excess interest” as
defined in section 884(f)(1)(B).
Complete lines 10 through 13, and skip
lines 14a and 14b. If the amount on
line 7c is less than or equal to the
amount on line 8, column (c), skip lines
10 through 13, and complete the
determination of the scaling ratio on
lines 14a and 14b.

Lines 10 Through 13.
Computation of AUSBL Method
Allocation with Excess Interest
Line 10. Published rate election for
banks. If the corporation is a foreign
bank that elects to compute excess
interest under the AUSBL method using
a published 30-day LIBOR for the tax
year (or another published rate as
explained in the "Note" below), check

Note. For tax years ending after
October 9, 2019, a corporation that is a
foreign bank may elect to use a secured
overnight financing rate (SOFR). For
details, see proposed regulations
(REG-118784-18), which propose
changes to Regulations section
1.882-5(d)(5)(ii)(B).

Lines 10a Through 10c. Excess
Interest – Average Actual U.S.
Dollar Rate
Line 10a. Actual U.S. dollar interest.
If the corporation does not properly
make or is not eligible to make a
published rate election for the tax year,
enter the interest expense paid or
accrued by the corporation for the tax
year on its average worldwide U.S.
dollar liabilities, excluding U.S.-booked
liabilities included on line 8, column (c).
Line 10b. Enter on line 10b the
average worldwide U.S. dollar
denominated liabilities (whether or not
interest bearing) that are not
U.S.-booked liabilities included on
line 8, column (c). See Regulations
section 1.882-5(d)(5)(ii).
Line 10e. If the amount on line 10b is
zero and the foreign corporation does
not properly make or is not eligible to
make the published rate election, enter
on line 10e an interest rate that is
reasonable under the facts and
circumstances. One reasonable
approach in determining such interest
rate would include using an interest rate
that:
• Approximates the foreign
corporation's actual average U.S.-dollar
borrowing rate with respect to
interest-bearing U.S.-dollar
denominated liabilities, and
• Is consistently applied by the foreign
corporation from year to year.
Examples of interest rates that would
generally be considered reasonable
include the actual average interest rate
on interest-bearing U.S.-dollar
denominated liabilities that are

Instructions for Schedule I (Form 1120-F) (2021)

-7-

Line 12. Excess interest. Multiply the
rate on line 10e by the amount of
excess U.S.-connected liabilities on
line 11 and enter the result on line 12.
This amount is the corporation's excess
interest expense portion of its overall
Regulations section 1.882-5 allocation
that is allocable to ECI under the
AUSBL method in Regulations section
1.882-5(d)(5). The amount on line 12
also constitutes the corporation's
excess interest under section 884(f)(1)
(B). See Regulations section 1.884-4(a)
(2).
Line 13. Interest expense allocation.
Add the amount reported on line 12 and
the amount of U.S.-booked interest
expense from line 9, column (c) and
enter the result on line 13. This amount
is the corporation's total amount of
interest expense allocable under the
three-step formula when
U.S.-connected liabilities exceed
U.S.-booked liabilities under the AUSBL
method. It does not include any
amounts directly allocable to ECI under
Regulations section 1.882-5(a)(1)(ii).

Lines 14a Through 15.
Computation of AUSBL Method
Allocation Under the
Scale-Down Ratio

If U.S.-connected liabilities on line 7c
are less than U.S.-booked liabilities on
line 8, column (c), the AUSBL method
allocation is subject to a “scale-down” of
the U.S.-booked interest expense
reported on line 9, column (c). Complete
lines 14a and 14b in lieu of lines 10
through 13. If line 7c exceeds line 8,
column (c), leave lines 14a and 14b
blank.

Line 14b. Scaled-down U.S. book interest. Multiply the amount of U.S.
booked interest on line 9, column (c), by
the scale-down ratio on line 14a, and
enter the result on line 14b. The
allocated amount is the total amount of
the AUSBL method allocation under
Regulations section 1.882-5(d)(4). The
amount on line 14b does not include
any amount directly allocable to ECI

under Regulations section 1.882-5(a)(1)
(ii).
Hedging amounts. If the
corporation has income, expense, gain,
or loss from a hedging transaction of a
U.S.-booked liability that gives rise to
interest expense subject to the
scale-down ratio, such hedging income,
expense, gain, or loss amount is also
subject to reduction under the same
scaling ratio reported on line 14a. See
Regulations section 1.882-5(d)(4) and
Proposed Regulations section
1.882-5(d)(2)(vi). Do not report such
scale-down reductions of hedging
income, expense, gains, or losses
on line 14b. The ratio reported on
line 14a shall be applied to each type of
item in accordance with its
characterization and the scaled down
hedging income, expense, gain, or loss
is reported on Form 1120-F, Section II in
the appropriate category to which the
hedging item is characterized. For
instance, periodic expense from an
interest rate notional principal contract
hedging transaction that is recorded on
the sets of books reportable on
Schedule L, and that is subject to the
scaling ratio, is reported on Form
1120-F, Section II, line 27. Such amount
is also subject to reporting on
Schedule H (Form 1120-F), line 38a, as
allocable in part to ECI and in part to
non-ECI in accordance with the scaling
ratio of line 14a.

election, attach separate sheets using
the same size and format as shown on
the schedule and provide the
information requested on lines 16a
through 19 on the attached sheets for all
such additional currencies. Report on
Schedule I, line 20, column (d), the total
results for all separate currency
allocations shown on line 19 for
columns (a) through (d), plus any
additional line 19 amounts shown on
attached separate sheets (if any).

reduction shown on line 7b must be
allocated to each of the separate
currency pools in proportion to the U.S.
assets in each pool. The amount
entered on line 17b for each column is
computed as:
1. The amount on line 16a multiplied
by the ratio on line 17a, less
2. The amount of the liability
reduction election entered on line 7b
multiplied by the proportion that the
average U.S. assets in the separate
currency pool bears to all of the U.S.
assets in all separate currencies (that is,
the total average U.S. assets entered on
line 5, column (d)).

DRAFT AS OF
November 2, 2021

Lines 16a Through 20.
Step 3: Separate Currency
Pools Method

Corporations that allocate interest
expense under a Separate Currency
Pools election report the allocations
under a three-step method for each
currency in which the corporation has
U.S. assets (as defined in Regulations
section 1.884-1(d)), on Schedule I, lines
16a through 20. The amount of the
interest expense allocation is the sum of
the separate interest expense
allocations in each currency. If the
corporation makes a 3% currency
election under Regulations section
1.882-5(e)(1)(i), check the box on
line 16b and include the U.S. dollar
value of all currencies for which the 3%
currency election applies in the U.S.
dollar denominated column on line 16a.
Schedule I accommodates reporting
of the interest expense allocations in
four currencies (including the U.S. dollar
and the foreign corporation's functional
currency). If the foreign corporation has
U.S. assets in more than four currencies
that are not subject to a 3% currency

Line 16a. U.S. Assets — U.S. dollar
value denominated in currency.
Enter the U.S. dollar value of the
average amount of U.S. assets in the
appropriate column (a) through (d) (or
on the attached separate sheets for
additional currencies). Enter in column
(a) the U.S. dollar denominated U.S.
assets, plus the U.S. dollar value of any
U.S. assets for which a 3% currency
election is applicable for the tax year. In
column (b), enter the average U.S.
dollar value of U.S. assets denominated
in the corporation's home country
functional currency. Enter the average
U.S. assets of all other currency pools
beginning with column (c).
Note. The sum of all U.S. assets in
columns (a) through (d) (and in any
columns shown on any attached
separate sheets) must equal the total
average U.S. assets entered on line 5,
column (d).
A transaction that hedges a U.S.
asset is taken into account for purposes
of determining the currency
denomination and the value of the U.S.
asset. See Regulations section
1.882-5(e)(1)(i).
Line 17b. U.S.-connected liabilities
per currency. Complete line 17b as
follows:

Determination of U.S.-connected
liabilities if no U.S. liability reduction
election is made. For each applicable
column, multiply the U.S. assets on
line 16a by the U.S.-connected liability
ratio on line 17a and enter the amount
on line 17b. The resulting amount
constitutes the U.S.-connected liabilities
for each currency pool when the
corporation does not make a U.S.
liability reduction election under
Regulations section 1.884-1(e)(3).
Determination of U.S.-connected
liabilities if a U.S. liability reduction
election is made. If the corporation
makes one or more U.S. liability
reduction elections for the tax year
under Regulations section 1.884-1(e)
(3), the total amount of the liability
-8-

Attach a statement showing the
computation and the allocation of the
liability reduction election to each
separate currency pool.

Line 18a. Worldwide book interest
expense for each separate currency
pool. Enter for each column on line 18a
the corporation's worldwide interest
expense paid or accrued for the tax year
in the separate currency pool. In column
(a), enter the worldwide U.S. dollar
interest paid or accrued. For all other
separate currency pools, enter the
worldwide interest expense in the
functional currency of the currency pool.
Do not enter the U.S. dollar value of the
functional currency pool in column (b) or
for any other non-U.S. dollar currencies
for which a separate currency pool
allocation is made in additional
columns. See Regulations section
1.882-5(e)(2). The worldwide interest
expense in each currency pool includes
interest expense in each currency that is
recorded on the Schedule L books and
reportable on Schedule I, line 9, column
(c).
Line 18b. Worldwide average liabilities in each separate currency pool.
Enter on line 18b the average liabilities
(whether or not interest bearing)
denominated in each separate currency
pool. In column (a), enter the average
worldwide liabilities (whether or not
interest bearing) denominated in U.S.
dollars. For all other separate currency
pools, enter the average amount of
liabilities (whether or not interest
bearing) denominated in the currency of
the currency pool. Do not enter the U.S.
dollar value of the currency pool for any
column other than column (a). In
determining the average worldwide
borrowing rate, the liabilities in each
currency pool include the amounts
recorded on the sets of books
reportable on Schedule L and included
on Schedule I, line 8, column (c).

Instructions for Schedule I (Form 1120-F) (2021)

Determine the average third-party
liabilities using the most frequent
averaging period for which data is
reasonably available in accordance with
the principles of Regulations sections
1.882-5(b)(3) and (c)(2)(iv).
Line 18c. Borrowing rate. Divide
line 18a by line 18b. The result is the
average worldwide borrowing rate for
each separate currency pool.

1.861-10T(b) or (c). The rules of
Temporary Regulations section
1.861-10T(c) apply only to non-financial
institutions. Financial institutions are
permitted to directly allocate interest
expense only under the non-recourse
indebtedness rules described in
Temporary Regulations section
1.861-10T(b).

made. See Regulations section
1.882-5(a)(5) and Regulations section
1.882-5(a)(8), examples (3) and (4).
Treaty-exempt income may include
income that is ECI under the force of
attraction principle of section 864(c)(3)
but which is business profits not
attributable to a U.S. permanent
establishment of the corporation under
an applicable treaty to which
Regulations section 1.882-5 applies in
determining the attributable business
profits. For such treaties, the amount
allocable to ECI reported on line 23
requires additional allocation and
apportionment between taxable ECI and
treaty-exempt ECI under Regulations
section 1.882-5(a)(5). Also include on
line 24a any other interest expense that
is permanently disallowed by a section
of the Internal Revenue Code (for
example, section 163(f)(2)) or an
income tax treaty. Include in the
attached statement the amount of
interest expense disallowed for each
applicable provision or income tax
treaty.

DRAFT AS OF
November 2, 2021

Line 19. Interest expense allocation
by separate currency pool. For each
column, multiply the amount on line 17b
by the borrowing rate on line 18c and
enter the result on line 19. The amount
on line 19 is the amount of interest
expense allocable to ECI in each
separate currency pool.

Line 20. Total interest expense allocable to ECI under the separate currency pools method. On line 20, enter
the sum of the amounts in each column
on line 19 (including amounts from
line 19 of attached statement, if any).
The amount on line 20 is the total
amount of interest expense allocable to
ECI under the Separate Currency Pools
method. The amount on line 20 does
not include any amount of interest
expense directly allocable under
Regulations section 1.882-5(a)(1)(ii).

Lines 21 Through 25.
Summary – Interest
Expense Allocation and
Deduction Under
Regulations Section
1.882-5
Line 22. Interest expense directly allocable under Regulations section
1.882-5(a)(1)(ii). Enter the amount of
interest expense directly allocable to
ECI under Regulations section
1.882-5(a)(1)(ii), including such
amounts from Schedule P (Form
1120-F), line 7. A foreign corporation
that has a U.S. asset and indebtedness
that meet the requirements of
Temporary Regulations section
1.861-10T(b) or (c), as limited by
Temporary Regulations section
1.861-10T(d)(1), shall directly allocate
interest expense from such
indebtedness to income from such
asset in the manner and to the extent
provided in Temporary Regulations
section 1.861-10T.
Note. See Temporary Regulations
section 1.861-10T(d) for rules requiring
reductions in basis to assets required by
the direct interest allocation rules in
Temporary Regulations section

Line 23. Total interest expense allocable to ECI under Regulations section 1.882-5. Add lines 21 and 22 and
enter the result on line 23. This result is
the total amount of interest expense
allocable to ECI, including directly
allocated interest. This allocable amount
may not exceed the total interest
expense paid or accrued by the
corporation. See Regulations section
1.882-5(a)(3). The amount on line 23
does not include any interest expense
that was allocable to ECI under
Regulations section 1.882-5 in a
previous tax year and was subject to
limitation and deferral by another
section of the Internal Revenue Code in
that previous tax year but deductible in
the current tax year. If the corporation's
total interest expense paid or accrued is
less than the amount of allocation that
would result by adding lines 21 and 22,
enter such lesser amount on line 23.
The amount entered on line 23 is the
amount of interest expense taken into
account for branch-level interest tax
purposes under section 884(f)(1)(B) and
Regulations section 1.884-4(a),
regardless of whether the deductibility
of such amount is temporarily deferred
or disallowed for allocation to
tax-exempt income (including treaty
exempt income). The amount reportable
on line 23 is reconciled and reported on
Form 1120-F, Section III, line 7c, and on
Schedule M-3 (Form 1120-F), Part III,
line 26b, columns (d) and (e).
Line 24. Tax-exempt allocations, disallowances, deferrals and capitalization of interest expense allocation
from line 23. The amount of interest
expense allocable to ECI entered on
line 23 is subject to additional rules that
may defer or disallow deductibility in
whole or in part.
Line 24a. Tax-exempt allocations
and other permanently disallowed
interest expense. Enter on line 24a
the amount of allocable interest
expense on line 23 that is subject to
further allocation and apportionment to
tax-exempt income under section 265 or
under the provisions of an applicable
income tax treaty. Attach a statement
showing how such allocation between
exempt and non-exempt ECI has been

Instructions for Schedule I (Form 1120-F) (2021)

-9-

Note. Enter all amounts on line 24a as
a negative amount. These line 24a
amounts are a reduction of the
allocation in determining the deductible
interest expense for the year.
The amount reportable on line 24a is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (c).
Line 24b. Deferred interest
expense. Enter on line 24b the amount
of allocable interest expense on line 23
that is deferred as a deduction in the
current tax year by a provision of the
Internal Revenue Code other than
section 163(j) (for example, section
163(e) or section 267(a)(3)) but may be
allowed as a deduction in a subsequent
tax year. Attach a statement indicating
the amount of current year deferral for
each applicable provision.
Note. Enter all amounts on line 24b as
a negative amount. These line 24b
amounts are a reduction of the
allocation in determining the deductible
interest expense for the year.
The amount reportable on line 24b is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (b).
Line 24c. Disallowed business
interest expense under section
163(j). Enter on line 24c the amount of
allocable interest expense on line 23
that cannot be deducted in the current
year because it is disallowed business
interest expense under section 163(j).
Attach Form 8990, Limitation on

Business Interest Expense Under
Section 163(j).
Note. Enter all amounts on line 24c as
a negative amount. These line 24c
amounts are a reduction of the
allocation in determining the deductible
interest expense for the year.
The amount reportable on line 24c is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (b).

Line 24e. Current year deduction
of interest expense deferred in a
prior year. Enter on line 24e the
amount of allocable interest expense
deductible in the current tax year that
was deferred in a prior tax year under a
provision of the Internal Revenue Code
other than section 163(j) (for example,
section 163(e) or section 267(a)(3)).
Attach a statement indicating the
amount of current year deduction of a
prior year deferral for each applicable
provision.
The amount reportable on line 24e is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (b).

amounts are treated as an increase to
the deductible interest expense for the
year.
The amount reportable on line 24f is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (b).
Line 24g. Total deferrals and
disallowances. Combine lines 24a
through 24f and enter the result on
line 24g. The amount entered on
line 24g is also reported and reconciled
for its temporary and permanent
differences on Schedule M-3 (Form
1120-F), Part III, line 26c, columns (b)
and (c). See the Instructions for
Schedule M-3 (Form 1120-F), Part III,
line 26c.

DRAFT AS OF
November 2, 2021

Line 24d. Capitalized interest
expense. Enter on line 24d the amount
of allocable interest expense on line 23
that is capitalizable (for example, under
section 263A). Attach a statement
describing how such allocation has
been made.
Note. Enter all amounts on line 24d as
a negative amount. These amounts are
treated as a reduction of the allocation
in determining the deductible interest
expense for the year.
The amount reportable on line 24d is
included on Schedule M-3 (Form
1120-F), Part III, line 26c, column (c).

Line 24f. Current year deduction
of business interest expense
disallowed in a prior year under
section 163(j). Enter on line 24f the
amount of business interest expense
deductible in the current tax year that
was disallowed in a prior tax year under
section 163(j). Attach Form 8990.
Note. Enter all amounts on lines 24e
and 24f as positive amounts. These

-10-

Line 25. Amount of allocation deductible on Form 1120-F, Section II,
line 18. Combine lines 23 and 24g and
enter the result on line 25. The result is
the corporation's deductible amount of
interest expense allocation for the tax
year and is reportable on Form 1120-F,
Section II, line 18.

Instructions for Schedule I (Form 1120-F) (2021)