Schedule L (Form 1 Instructions for Schedule L (Form 1118), Foreign Tax Red

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Instructions for Schedule L
(Form 1118)

Department of the Treasury
Internal Revenue Service

(Rev. December 2023)

TREASURY/IRS
AND OMB USE
ONLY DRAFT
December 11, 2023
Section references are to the Internal Revenue
Code unless otherwise noted.

Future Developments

For the latest information about
developments related to Schedule L (Form
1118) and its instructions, such as
legislation enacted after they were
published, go to IRS.gov/Form1118.

What’s New

Schedule L will be electronically enabled
for tax year 2023. See
Computer-Generated Schedule L on
page 2 for additional information.

The entry spaces for the following
columns have been modified to allow for
the entry of a maximum of 12 characters.
• Page 1, Part I, column 13.
• Page 4, Part V, column 3.

The above columns request the reference
ID number for contested foreign income
tax. The instructions for those columns tell
filers to enter the reference ID number for
the contested foreign income tax that was
reported on the applicable Form 7204.
Because the reference ID number for
contested foreign income tax reported on
Form 7204 is limited to 12 characters, the
entry spaces for the above columns can
be limited to 12 characters.
On page 4 of the Schedule L, the
sentence “Do not complete Part V for the
tax year 2022” has been deleted in the
Part V heading.

General Instructions
Purpose of Schedule

Schedule L (Form 1118) is used to identify
foreign tax redeterminations that occur in
the current tax year in each applicable
separate category, the years to which they
relate, and other information that satisfies
the taxpayer’s obligation to notify the IRS
of foreign tax redeterminations related to
prior years.
Use Part I to report foreign income tax
redeterminations that resulted in an
increase in the amount of foreign taxes
accrued and paid by the taxpayer or by a
foreign corporation with respect to which
the taxpayer computed an amount of
foreign income taxes deemed paid.
Use Part II to report foreign income tax
redeterminations that resulted in a
Dec 6, 2023

decrease in the amount of foreign taxes
paid or accrued by the taxpayer or by a
foreign corporation with respect to which
the taxpayer computed an amount of
foreign income taxes deemed paid.

Use Part III to report foreign tax
redeterminations that resulted in a change
to the taxpayer’s income inclusions, a
change in the amount of foreign income
taxes paid, accrued, or deemed paid, or a
change in the amount of foreign tax credits
claimed in any relation back year.
Use Part IV to report foreign tax
redeterminations that resulted in a change
in the U.S. tax liability for any relation back
year or other affected tax year(s) (for
example, by reason of a change in
allowable foreign tax credit carryovers).

Use Part V, beginning with the 2023 tax
year, to satisfy the annual reporting
requirement under Regulations section
1.905-1(d)(4)(iv) for contested foreign
income taxes for which the taxpayer
claimed a provisional foreign tax credit.

Who Must File

Any taxpayer that has a foreign tax
redetermination under section 905(c) must
complete this schedule and attach it to the
income tax return for the taxable year in
which the foreign tax redetermination
occurs. This schedule must be submitted
irrespective of whether the foreign tax
redetermination changed the taxpayer’s
U.S. tax liability.
Note. If the U.S. tax liability for any year
changes by reason of the foreign tax
redetermination, the taxpayer must file an
amended return for the taxable year with
respect to which the U.S. tax liability is
adjusted, in addition to filing Schedule L
for the year in which the foreign tax
redetermination occurs. See Foreign Tax
Redeterminations in the Instructions for
Form 1118 for additional information
regarding foreign tax redeterminations that
result in a change in U.S. tax liability and
for the related reporting requirements.
If a foreign tax redetermination does
not change the amount of U.S. tax due for
any taxable year, the taxpayer does not
need to file an amended return. The
taxpayer satisfies its reporting
requirements under Regulations section
1.905-4(b)(1)(v) with respect to such
foreign tax redetermination by filing a
Schedule L with the return for the taxable
Cat. No. 38267T

year in which the foreign tax
redetermination occurs.

Definitions

Foreign tax redetermination. A foreign
tax redetermination means a change in
the liability for foreign income taxes
including if:
• Accrued foreign taxes when paid or
later adjusted differ from the amounts
claimed as credits (including corrections
to accrued amounts to reflect final foreign
tax liability and additional payments of tax
that accrue after the close of the taxable
year to which the tax relates);
• Accrued foreign taxes are not paid
within 24 months after the close of the tax
year to which they relate; or
• Any foreign tax paid is fully or partially
refunded.
Relation back year. Relation back year
means the U.S. tax year in which the
foreign taxes being redetermined were
originally taken into account.

Example. In U.S. taxable year 1, a
taxpayer took into account $2 million of
Country X foreign income taxes accrued
with respect to the foreign tax year that
ended within U.S. taxable year 1. In year 3,
Country X assessed an additional $1
million of foreign income taxes with
respect to the foreign taxable year that
ended within U.S. taxable year 1. The
relation back year is U.S. taxable year 1.

Affected tax year. Affected tax year
means any tax year for which the U.S. tax
liability is changed as a result of a foreign
tax redetermination. This includes tax
years in which the U.S. tax liability is
changed as a result of a change in a
carryover of a tax attribute, such as a
foreign tax credit carryover or a net
operating loss carryover, from a relation
back year.
Functional currency. Functional
currency means the dollar, or in the case
of a qualified business unit (QBU), the
currency of the economic environment in
which a significant part of such unit’s
activities are conducted and which is used
by such unit in keeping its books and
records. See section 985(b).
Reference ID number for contested
tax. See the Instructions for Form 7204
for the definition of and requirements for
the reference ID number for contested
foreign income tax.

Reporting Exchange Rates on
Schedule L

All exchange rates must be reported using
a “divide-by convention” rounded to at
least four places. That is, the exchange
rate must be reported in terms of the
amount by which the functional currency
amount must be divided in order to reflect
an equivalent amount of U.S. dollars. As
such, the exchange rate must be reported
as the units of foreign currency that equal
one U.S. dollar, rounded to at least four
places. Do not report the exchange rate
as the number of U.S. dollars that equal
one unit of foreign currency.

U.S. dollars, unless otherwise specified on
Schedule L.
Line a. On line a, enter the same
separate category code as that shown on
the Form 1118 to which this Schedule L
relates.
Line b. If code 901j is entered on line a,
enter on line b the same country code as
that shown on the Form 1118 to which this
Schedule L relates.

Column 3. Enter the code for the country
or U.S. territory to which tax is paid using
the country codes provided at IRS.gov/
CountryCodes.
Columns 4 and 5. Enter in column 4 the
date(s) the additional foreign taxes were
paid and enter in column 5 the ending
date of the foreign tax year to which such
taxes relate.

TREASURY/IRS
AND OMB USE
ONLY DRAFT
December 11, 2023
Note. You must round the result to more
than four places if failure to do so would
materially distort the exchange rate or the
equivalent amount of U.S. dollars.

Computer-Generated
Schedule L

Schedule L (Form 1118) will be
electronically enabled for tax year 2023.
Complete and file a separate Schedule L
using code "TOTAL" that aggregates all
amounts listed for each line and column of
all other separate category of income
Schedules L for Parts I, II, III, and V.
Complete this “TOTAL” Schedule L even if
you only have one separate category of
income. Because Part IV is based on
overall U.S. tax liability, complete Part IV
only once in the “TOTAL” version. Such
“TOTAL” Schedule L should be filed with
the same category of income that
completes Schedule B, Part III (see Form
1118, Schedule B, Part III instructions). If
Schedule L reports a foreign tax
redetermination in a category of income
for which a Form 1118 is not filed in the
current tax year, file such Schedule L with
the category of income that completes
Schedule B, Part III. In addition, complete
and file a separate Schedule L for each
category of income for Parts I, II, III, and V.
In some cases, Schedule L must be
expanded to properly report foreign tax
redeterminations. This applies in cases
such as the following:
• In cases where reporting is required for
more than three payor entities for a
relation back year, expand Schedule L for
those payor entities following the format of
Schedule L.
• In cases where reporting is required for
more than two relation back years, or there
are other affected years in addition to the
relation back years (Part IV), expand
Schedule L for those years following the
format of Schedule L.

Specific Instructions
Important. All information reported on
Schedule L (Form 1118) must be in
English. All amounts must be stated in

Line c. If one of the RBT codes is entered
on line a, enter on line c the same country
code as that shown on the Form 1118 to
which this Schedule L relates.
Line d. Check the box on line d if an
election has been made under
Regulations section 1.905-5(e) to account
for foreign tax redeterminations with
respect to pre-2018 tax years in the
foreign corporation's last pooling year.

Election to account for foreign tax
redeterminations with respect to
pre-2018 taxable years in the foreign
corporation’s last pooling year. Under
Regulations section 1.905-5(e), an
irrevocable election may be made by a
foreign corporation’s controlling domestic
shareholders to account for all foreign tax
redeterminations that occur in taxable
years ending on or after November 2,
2020, with respect to pre-2018 taxable
years of foreign corporations as if they
occurred in the foreign corporation’s last
taxable year beginning before January 1,
2018 (last pooling year). Check the box on
line d if an election under Regulations
section 1.905-5(e) has been made or is
being made in the current tax year.

Column 6. Enter the payor entity’s
income subject to tax in the foreign
jurisdiction, as reported on the foreign tax
return.
Column 7. Enter the amounts of
additional tax accrued in the local
currency in which the tax is payable.

Column 8. Enter the amounts of the
additional tax denominated in the
functional currency of the taxpayer's QBU
(as defined under Regulations section
1.904-4(f)(3)(vii)) or foreign corporation
that accrued the additional tax.

Column 9. Enter the exchange rate
originally used to convert the local
currency (in which the redetermined
foreign tax was paid) to U.S. dollars. See
Reporting Exchange Rates on Schedule L,
earlier, for additional information.

Column 11. Enter the U.S. dollar amount
of foreign tax of each payor entity that was
reported by the taxpayer on its original or
amended return (not taking into account
the foreign tax redetermination).

Part I

Column 13. Enter the reference ID
number for contested foreign income tax,
if applicable, using the reference ID
number reported on the Form 7204 filed
with respect to the contested foreign
income tax.

Column 1. Enter the ending date of the
relation back year. See definition of
Relation back year, earlier. If an election
under Regulations section 1.905-5(e) has
been made, report all foreign tax
redeterminations with respect to pre-2018
taxable years under the last pooling year.

Column 14. Check the box if the foreign
tax redetermination changes the
determination as to whether a grouping of
income and related taxes of a foreign
corporation qualifies for the High Tax
Exception or Exclusion described in
section 954(b)(4).

Columns 2a through 2d. Enter in
columns 2a and 2b the name and the EIN
or reference ID number of the payor entity.
If the payor entity is not a corporation,
enter in columns 2c and 2d the name and
the EIN or reference ID number of the
domestic or foreign corporation that owns
the payor entity. In columns 2b and 2d, do
not enter “FOREIGNUS” or “APPLIED
FOR.” Instead, if an entity does not have
an EIN, the taxpayer must enter a
reference ID number that uniquely
identifies the payor entity or owner for
which such number is requested. See
Reference ID numbers in the Instructions
for Form 1118 for requirements and
additional details.

Part II

-2-

Columns 1, 2a, 2b, 2c, and 2d. Use the
instructions for Part I, columns 1, 2a, 2b,
2c, and 2d to complete the corresponding
columns in Part II.
Column 3. Enter the code for the country
or U.S. territory from which tax was
refunded using the country codes
provided at IRS.gov/CountryCodes.
Columns 4 and 5. Enter in column 4 the
date(s) the foreign taxes were refunded or
deemed refunded and enter in column 5
the ending date of the foreign tax year to
which such taxes relate. If the foreign
taxes are deemed refunded by reason of
the section 905(c)(2) two-year rule
described in the Note in the instructions

Instructions for Schedule L (Form 1118) (Rev. Dec. 2023)

for Column 13, enter in column 4 the date
that is 24 months after the close of the
taxable year to which the foreign taxes
relate.
Column 6. Use the instructions for Part I,
column 6 to complete Part II, column 6.
Column 7. Enter the amount of the tax
refunded or deemed refunded in the local
currency in which the tax is payable.

section 951(a)(1) inclusion on the
taxpayer’s original or previously amended
return.
Columns 6 and 7. Enter in column 6 the
redetermined amount of foreign income
taxes deemed paid under section 960(a)
and enter in column 7 the amount of
foreign income taxes deemed paid under
section 960(a) as reported on the
taxpayer’s original or previously amended
return.

Columns 2 through 4. Enter in column 2
the total redetermined U.S. tax liability and
enter in column 3 the total U.S. tax liability
reported on the taxpayer’s original or
previously amended return. In column 4,
enter the difference by subtracting column
3 from column 2 for each affected tax year.

Part V

TREASURY/IRS
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Column 8. Enter the amount refunded or
deemed refunded denominated in the
functional currency of the taxpayer's QBU
(as defined under Regulations section
1.904-4(f)(3)(vii)) or foreign corporation
that paid or accrued the refunded amount.

Columns 9 and 11. Use the instructions
for Part I, columns 9 and 11 to complete
the corresponding columns in Part II.
Column 13. Check the box if the foreign
tax redetermination is a result of the
application of the section 905(c)(2)
two-year rule.

Note. Under section 905(c)(2), if accrued
foreign income taxes are not paid on or
before the date that is 24 months after the
close of the taxable year to which they
relate (two-year rule), there is a resulting
foreign tax redetermination that is
accounted for as if the unpaid portion of
the foreign income taxes were refunded on
that date. Credit may be claimed for those
taxes if and when they are ultimately paid.
Foreign income taxes that first accrue after
the date 24 months after the close of the
taxable year to which such taxes relate
may not be claimed as a credit or added to
PTEP group taxes until paid.

Column 14. Use the instructions for Part
I, column 14 to complete Part II, column
14.

Part III
Column 1. Use the instructions for Part I,
column 1 to complete Part III, column 1.
Columns 2 and 3. Enter in column 2 the
redetermined direct section(s) 901 and/or
903 taxes paid or accrued and enter in
column 3 the direct section(s) 901 and/or
903 taxes paid or accrued per the
taxpayer’s original or previously amended
return.
Columns 4 and 5. Enter in column 4 the
redetermined amount of the taxpayer’s
section 951(a)(1) inclusion (including
inclusions under sections 956 and 965)
and enter in column 5 the amount of

Columns 8 and 9. Enter in column 8 the
redetermined amount of the taxpayer’s
section 951A inclusion and enter in
column 9 the amount of section 951A
inclusion reported on the taxpayer’s
original or previously amended return.

Columns 10 and 11. Enter in column 10
the redetermined amount of foreign
income taxes deemed paid under section
960(d) and enter in column 11 the amount
of foreign income taxes deemed paid
under section 960(d) on the taxpayer’s
original or previously amended return.
Columns 12 and 13. Enter in column 12
the redetermined taxes deemed paid
under section 960(b)(1) and enter in
column 13 the section 960(b)(1) deemed
paid taxes per original or previously
amended return.

Columns 14 and 15. Enter in column 14
the redetermined taxes deemed paid
under section 902 and enter in column 15
the section 902 deemed paid taxes per the
taxpayer’s original or previously amended
return.
Columns 16 and 17. Enter in column 16
the total amount of foreign tax credit
claimed in the separate category on the
taxpayer’s original or previously amended
return and enter in column 17 the total
amount of foreign tax credit claimed after
the foreign tax redetermination. Include
changes attributable to foreign tax
redeterminations that affect the amount of
foreign taxes deemed paid under section
902 prior to its repeal and under section
960(b) in these totals.

Part IV
Column 1. Enter the ending date of the
relation back year or affected year. See
definitions of Relation back year and
Affected tax year, earlier. If an election
under Regulations section 1.905-5(e) has
been made, report all foreign tax
redeterminations with respect to pre-2018
taxable years under the last pooling year.

Instructions for Schedule L (Form 1118) (Rev. Dec. 2023)

-3-

Beginning with tax year 2023, enter the
information requested on Schedule L, Part
V, using the instructions provided below.

Column 1. For taxpayers that claim
credits on the accrual basis, enter the
relation back year. For taxpayers that
claim credits on the cash basis, enter the
year in which the contested foreign
income tax was remitted to the foreign
country. The tax year entered in column 1
should correspond with the tax year
entered on line 1 on the Form 7204 that
was filed in order to claim a provisional
credit for the contested foreign income tax.
Columns 2 and 3. Enter in column 2 the
name of the payor entity and enter in
column 3 the reference ID number for the
contested foreign income tax that was
reported on the Form 7204.

Columns 4 and 5. Enter in column 4 the
code of the country or U.S. possession to
which the tax was paid using the country
codes provided at IRS.gov/CountryCodes
and enter in column 5 the amount of
contested foreign income tax that was
provisionally claimed as a credit.
Columns 6 and 7. Check the box in
column 6 if the contest is still ongoing and
check the box in column 7 if the contest
was resolved.

Columns 8 and 9. Enter in column 8 the
date the contest was resolved and enter in
column 9 the amount of tax refunded or
additional tax paid, if any. Any portion of a
contested foreign income tax for which a
provisional credit is claimed that is
subsequently refunded results in a foreign
tax redetermination that must be reported
on Schedule L and, if applicable, an
amended return for the taxable year(s)
with respect to the U.S. tax liability
changes as a result of such foreign tax
redetermination.

Additional Information

For more information, see section 905(c)
and Regulations sections 1.905-1,
1.905-3, 1.905-4, and 1.905-5.