Schedule L (Form 1 Foreign Tax Redeterminations

Foreign Tax Redeterminations

SCHEDULE L
(Form 1118)

For calendar year 20

(Rev. December 2023)

, or other tax year beginning

, 20

, and ending

, 20

.

OMB No. 1545-0123

Attach to Form 1118.
Go to www.irs.gov/Form1118 for instructions and the latest information.

Department of the Treasury
Internal Revenue Service

Employer identification number

Name of corporation

Use a separate Schedule L (Form 1118) for each applicable category of income (see instructions).
a Separate category (enter code—see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) . . . . . . . . . . . . . . . .
c If one of the RBT codes is entered on line a, enter the country code for the treaty country (see instructions) . . . . . . . . . . . . . .
d Check this box if election made under Regulations section 1.905-5(e) to account for foreign tax redeterminations with respect to pre-2018 tax years in
foreign corporation’s last pooling year (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I

Increase in Amount of Foreign Taxes Accrued (see instructions)

Enter redetermined amounts by payor entity for each separate relation back year (starting with the most recent) followed by a subtotal for each relation back year (see instructions).
1. U.S. Tax Year
of Taxpayer to
Which Tax Relates
(Relation Back Year)
(MM/DD/YYYY)

2a. Name of Payor Entity

B

2d. EIN or Reference ID Number of Owner

B

3. Country or
U.S. Possession
to Which Tax Is Paid
(enter code—
see instructions)

4. Date Additional
Foreign Tax Was Paid
(MM/DD/YYYY)

5. Foreign Tax Year
to Which Tax Relates
(MM/DD/YYYY)

6. Payor Entity’s Income
Subject to Tax in the
Foreign Jurisdiction
(see instructions)

7. Additional Tax Accrued
in Local Currency in Which
the Tax Is Payable

(1)
(2)
(3)
(1)
(2)
(3)
8. Additional Tax Accrued
in Functional Currency
of Taxpayer’s QBU
or Foreign Corporation

A

2c. Name of Owner of Payor Entity, if applicable
(see instructions)

(1)
(2)
(3)
(1)
(2)
(3)

A

A

2b. EIN or Reference ID Number of Payor Entity

9. Conversion Rate
of Local Currency
to U.S. Dollars

10. Additional Tax Accrued
in U.S. Dollars
(divide column 7
by column 9)

11. U.S. Dollar Tax
of Payor Entity per
Original/Amended
Return

12. Revised Tax
Accrued
(add column 10
and column 11)

13. Reference ID Number
for Contested Tax, if
applicable
(see instructions)

14. Check Box
if Change
Caused to High
Tax Exception/
Exclusion
(see instructions)

(1)
(2)
(3)

Subtotal by Relation Back Year of Taxpayer (add amounts in columns 10, 11, and 12)

B

(1)
(2)
(3)

Subtotal by Relation Back Year of Taxpayer (add amounts in columns 10, 11, and 12)

* Important: See Computer-Generated Schedule L in the separate instructions for Schedule L (Form 1118).
For Paperwork Reduction Act Notice, see the Instructions for Form 1118.

Cat. No. 75132H

Schedule L (Form 1118) (Rev. 12-2023)

Page 2

Schedule L (Form 1118) (Rev. 12-2023)
Employer identification number

Name of corporation

Part II

Decrease in Amount of Foreign Taxes Paid or Accrued (see instructions)

Enter redetermined amounts by payor entity for each separate relation back year (starting with the most recent) followed by a subtotal for each relation back year (see instructions).
1. U.S. Tax Year
of Taxpayer to
Which Tax Relates
(Relation Back Year)
(MM/DD/YYYY)

2a. Name of Payor Entity

B

2d. EIN or Reference ID Number of Owner

B

2c. Name of Owner of Payor Entity, if applicable
(see instructions)

(1)
(2)
(3)
(1)
(2)
(3)

A

A

2b. EIN or Reference ID Number of Payor Entity

3. Country or
U.S. Possession
From Which Tax
Was Refunded or
Deemed Refunded
(enter code—
see instructions)

4. Date Foreign Tax
Was Refunded or
Deemed Refunded
(MM/DD/YYYY)
(see instructions)

5. Foreign Tax Year
to Which Tax Relates
(MM/DD/YYYY)

6. Payor Entity’s Income
Subject to Tax in the
Foreign Jurisdiction
(see instructions)

7. Tax Refunded or
Deemed Refunded
in Local Currency
in Which the
Tax Is Payable

(1)
(2)
(3)
(1)
(2)
(3)
8. Refunded Amount
in Functional Currency
of Taxpayer’s QBU
or Foreign Corporation

9. Conversion Rate
of Local Currency
to U.S. Dollars

10. Refunded Amount
in U.S. Dollars
(divide column 7 by column 9)

11. U.S. Dollar Tax
of Payor Entity per
Original/Amended Return

12. Revised Tax
Paid or Accrued
(subtract column 10
from column 11)

13. Check Box if
Section 905(c)(2)
Two Year Rule
Applies
(see instructions)

14. Check Box if
Change Caused
to High Tax
Exception/Exclusion
(see instructions)

(1)
(2)
(3)
Subtotal by Relation Back Year of Taxpayer
(add amounts in columns 10, 11, and 12) . . . . . . . . .
(1)
B (2)
(3)
Subtotal by Relation Back Year of Taxpayer
(add amounts in columns 10, 11, and 12) . . . . . . . . .
* Important: See Computer-Generated Schedule L in the separate instructions for Schedule L (Form 1118).
A

Schedule L (Form 1118) (Rev. 12-2023)

Page 3

Schedule L (Form 1118) (Rev. 12-2023)
Employer identification number

Name of corporation

Part III

Change in Inclusions; Change in Foreign Taxes Paid, Accrued, or Deemed Paid; and Change in Foreign Tax Credits Claimed

Enter the information below for the change in inclusions, change to the amount of foreign taxes paid, accrued, or deemed paid, and change in foreign tax credits claimed for each
relation back year. This information is reported on an overall taxpayer basis and not on a per payor entity basis.
1. Relation Back Year
(MM/DD/YYYY)

2. Redetermined
Direct Section 901
and/or 903 Taxes
Paid or Accrued

3. Direct Section 901
and/or 903 Taxes
Paid or Accrued
per Original/Amended Return

4. Redetermined
Section 951(a)(1) Inclusion

5. Section 951(a)(1) Inclusion
per Original/Amended Return

6. Redetermined Taxes
Deemed Paid
Under Section 960(a)

7. Section 960(a)
Deemed Paid Taxes
per Original/Amended Return

8. Redetermined
Section 951A Inclusion

9. Section 951A Inclusion
per Original/Amended Return

10. Redetermined Taxes
Deemed Paid
Under Section 960(d)

11. Section 960(d)
Deemed Paid Taxes
per Original/Amended Return

12. Redetermined Taxes
Deemed Paid
Under Section 960(b)(1)

13. Section 960(b)(1)
Deemed Paid Taxes
per Original/Amended Return

14. Redetermined Taxes
Deemed Paid
Under Section 902

15. Section 902
Deemed Paid Taxes
per Original/Amended Return

16. Amount of FTC Claimed
per Original/Amended Return

17. Amount of FTC Claimed
After Redetermination

Part IV

Change in U.S. Tax Liability

Enter the below information for the change in U.S. tax liability for each relation back year and other affected year. This information is reported on an overall taxpayer basis and not
on a per payor entity basis.
1. Relation Back Year or Affected Tax Year
(MM/DD/YYYY)

2. Total Redetermined
U.S. Tax Liability

3. Total U.S. Tax Liability
per Original/Amended Return

4. Difference
(subtract column 3 from column 2)

* Important: See Computer-Generated Schedule L in the separate instructions for Schedule L (Form 1118).
Schedule L (Form 1118) (Rev. 12-2023)

Page 4

Schedule L (Form 1118) (Rev. 12-2023)
Employer identification number

Name of corporation

Part V

Annual Reporting for Contested Taxes

Beginning with tax year 2023, taxpayers will enter the information below for each contested foreign income tax liability (or portion thereof) for which the taxpayer has previously
made an election under Regulations section 1.905-1(d)(4) to claim a provisional foreign tax credit.
1. Relation Back Year
(MM/DD/YYYY)

2. Name of Payor Entity
(see instructions)

3. Reference ID Number
for the Contested Tax

4. Country or U.S. Possession
to Which Tax Was Paid
(enter code)

(i)
(ii)
(iii)
(iv)
(v)
5. Amount of Contested Tax
Provisionally Claimed as Credit

6. Contest Ongoing

7. Contest Resolved

8. Date Contest Resolved
(MM/DD/YYYY)

9. Tax Refunded or Additional Tax Paid, if any
(see instructions)

(i)
(ii)
(iii)
(iv)
(v)
* Important: See Computer-Generated Schedule L in the separate instructions for Schedule L (Form 1118).
Schedule L (Form 1118) (Rev. 12-2023)