Form 1118
(Rev. December 2020)
Department of the Treasury
Internal Revenue Service
Foreign Tax Credit—Corporations
▶ Attach to the corporation’s tax return.
▶ Go to www.irs.gov/Form1118 for instructions and the latest information.
For calendar year 20 , or other tax year beginning , 20 , and ending , 20
OMB No. 1545-0123
Attachment
Sequence No. 118
Name of corporation Employer identification number
Use a separate Form 1118 for each applicable category of income (see instructions).
a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) . . . . . . . . . . . . . . ▶
c If one of the RBT codes is entered on line a, enter the country code for the treaty country (see instructions) . . . . . . . . . . . . ▶
Schedule A Income or (Loss) Before Adjustments (Report all amounts in U.S. dollars. See Specific Instructions.)
1. EIN or Reference ID
Number
(see instructions)*
2. Foreign Country or
U.S. Possession
(enter two-letter code—use
a separate line for each)
(see instructions)
Gross Income or (Loss) From Sources Outside the United States
3. Inclusions Under Sections 951(a)(1) and 951A
(see instructions)
4. Dividends
(see instructions) 5. Interest
(a) Exclude Gross-Up (b) Gross-Up (section 78) (a) Exclude Gross-Up (b) Gross-Up (section 78)
A
B
C
Totals (add lines A through C) . . . . . . . ▶
6. Gross Rents, Royalties,
and License Fees
7. Sales
8. Gross Income From
Performance of Services
9. Section 986(c) Gain 10. Section 987 Gain 11. Section 988 Gain
12. Other
(attach schedule)
A
B
C
Totals
13. Total
(add columns 3(a)
through 12)
14. Allocable Deductions
(a) Dividends
Received Deduction
(see instructions)
(b) Deduction Allowed Under
Section 250(a)(1)(A)—Foreign
Derived Intangible Income
(c) Deduction Allowed Under
Section 250(a)(1)(B)—Global
Intangible Low-Taxed Income
Rental, Royalty, and Licensing Expenses
(d) Depreciation, Depletion,
and Amortization
(e) Other Allocable
Expenses
(f) Expenses Allocable
to Sales Income
A
B
C
Totals
14. Allocable Deductions (continued)
(g) Expenses Allocable
to Gross Income From
Performance of Services
(h) Other Allocable
Deductions (attach schedule)
(see instructions)
(i) Total Allocable Deductions
(add columns 14(a)
through 14(h))
15. Apportioned
Share of Deductions
(enter amount from
applicable line of Schedule H,
Part II, column (d))
16. Net Operating
Loss Deduction
17. Total Deductions
(add columns 14(i)
through 16)
18. Total Income or (Loss)
Before Adjustments
(subtract column 17
from column 13)
A
B
C
Totals
* For section 863(b) income, NOLs, income from RICs, high-taxed income, section 965, section 951A, and reattribution of income by reason of disregarded payments, use a s ...
Form 8960Department of the Treasury Internal Revenue Serv.docxhanneloremccaffery
Form 8960
Department of the Treasury
Internal Revenue Service (99)
Net Investment Income Tax—
Individuals, Estates, and Trusts
▶ Attach to your tax return.
▶ Information about Form 8960 and its separate instructions is at www.irs.gov/form8960.
OMB No. 1545-2227
2016
Attachment
Sequence No. 72
Name(s) shown on your tax return Your social security number or EIN
Part I Investment Income Section 6013(g) election (see instructions)
Section 6013(h) election (see instructions)
Regulations section 1.1411-10(g) election (see instructions)
1 Taxable interest (see instructions) . . . . . . . . . . . . . . . . . . . . . 1
2 Ordinary dividends (see instructions) . . . . . . . . . . . . . . . . . . . . 2
3 Annuities (see instructions) . . . . . . . . . . . . . . . . . . . . . . . 3
4a Rental real estate, royalties, partnerships, S corporations, trusts,
etc. (see instructions) . . . . . . . . . . . . . . . 4a
b Adjustment for net income or loss derived in the ordinary course of
a non-section 1411 trade or business (see instructions) . . . . 4b
c Combine lines 4a and 4b . . . . . . . . . . . . . . . . . . . . . . . . 4c
5a Net gain or loss from disposition of property (see instructions) . 5a
b Net gain or loss from disposition of property that is not subject to
net investment income tax (see instructions) . . . . . . . 5b
c Adjustment from disposition of partnership interest or S corporation
stock (see instructions) . . . . . . . . . . . . . . 5c
d Combine lines 5a through 5c . . . . . . . . . . . . . . . . . . . . . . 5d
6 Adjustments to investment income for certain CFCs and PFICs (see instructions) . . . . . 6
7 Other modifications to investment income (see instructions) . . . . . . . . . . . . 7
8 Total investment income. Combine lines 1, 2, 3, 4c, 5d, 6, and 7 . . . . . . . . . . . 8
Part II Investment Expenses Allocable to Investment Income and Modifications
9a Investment interest expenses (see instructions) . . . . . . 9a
b State, local, and foreign income tax (see instructions) . . . . 9b
c Miscellaneous investment expenses (see instructions) . . . . 9c
d Add lines 9a, 9b, and 9c . . . . . . . . . . . . . . . . . . . . . . . . 9d
10 Additional modifications (see instructions) . . . . . . . . . . . . . . . . . . 10
11 Total deductions and modifications. Add lines 9d and 10 . . . . . . . . . . . . . 11
Part III Tax Computation
12 Net investment income. Subtract Part II, line 11 from Part I, line 8. Individuals complete lines 13–
17. Estates and trusts complete lines 18a–21. If zero or less, enter -0- . . . . . . . . . 12
Individuals:
13 Modified adjusted gross income (see instructions) . . . . . 13
14 Threshold based on filing status (see instructions) . . . . . 14
15 Subtract line 14 from line 13. If zero or less, enter -0- . . . . 15
16 Enter the smaller of line 12 or line 15 . . . . . . . . . . . . . . . . . . . . 16
17 Net investment income tax for individuals. Multiply line 16 by 3.8% (.038). Enter here and
includ ...
Form 8582 Department of the Treasury Internal Revenue Ser.docxhanneloremccaffery
Form 8582
Department of the Treasury
Internal Revenue Service (99)
Passive Activity Loss Limitations
▶ See separate instructions.
▶ Attach to Form 1040 or Form 1041.
▶ Information about Form 8582 and its instructions is available at www.irs.gov/form8582.
OMB No. 1545-1008
2016
Attachment
Sequence No. 88
Name(s) shown on return Identifying number
Part I 2016 Passive Activity Loss
Caution: Complete Worksheets 1, 2, and 3 before completing Part I.
Rental Real Estate Activities With Active Participation (For the definition of active participation, see
Special Allowance for Rental Real Estate Activities in the instructions.)
1
a
Activities with net income (enter the amount from Worksheet 1,
column (a)) . . . . . . . . . . . . . . . . . . 1a
b
Activities with net loss (enter the amount from Worksheet 1, column
(b)) . . . . . . . . . . . . . . . . . . . . . 1b ( )
c
Prior years unallowed losses (enter the amount from Worksheet 1,
column (c)) . . . . . . . . . . . . . . . . . . 1c ( )
d Combine lines 1a, 1b, and 1c . . . . . . . . . . . . . . . . . . . . . . 1d
Commercial Revitalization Deductions From Rental Real Estate Activities
2 a Commercial revitalization deductions from Worksheet 2, column (a) . 2a ( )
b
Prior year unallowed commercial revitalization deductions from
Worksheet 2, column (b) . . . . . . . . . . . . . . 2b ( )
c Add lines 2a and 2b . . . . . . . . . . . . . . . . . . . . . . . . . 2c ( )
All Other Passive Activities
3
a
Activities with net income (enter the amount from Worksheet 3,
column (a)) . . . . . . . . . . . . . . . . . . 3a
b
Activities with net loss (enter the amount from Worksheet 3, column
(b)) . . . . . . . . . . . . . . . . . . . . . 3b ( )
c
Prior years unallowed losses (enter the amount from Worksheet 3,
column (c)) . . . . . . . . . . . . . . . . . . 3c ( )
d Combine lines 3a, 3b, and 3c . . . . . . . . . . . . . . . . . . . . . . 3d
4
Combine lines 1d, 2c, and 3d. If this line is zero or more, stop here and include this form with
your return; all losses are allowed, including any prior year unallowed losses entered on line 1c,
2b, or 3c. Report the losses on the forms and schedules normally used . . . . . . . . 4
If line 4 is a loss and: • Line 1d is a loss, go to Part II.
• Line 2c is a loss (and line 1d is zero or more), skip Part II and go to Part III.
• Line 3d is a loss (and lines 1d and 2c are zero or more), skip Parts II and III and go to line 15.
Caution: If your filing status is married filing separately and you lived with your spouse at any time during the year, do not complete
Part II or Part III. Instead, go to line 15.
Part II Special Allowance for Rental Real Estate Activities With Active Participation
Note: Enter all numbers in Part II as positive amounts. See instructions for an example.
5 Enter the smaller of the loss on line 1d or the loss on line 4 . . . . . . . . . . . . 5
6 Enter $150,000. If married filing sepa ...
Form 8960Department of the Treasury Internal Revenue Serv.docxhanneloremccaffery
Form 8960
Department of the Treasury
Internal Revenue Service (99)
Net Investment Income Tax—
Individuals, Estates, and Trusts
▶ Attach to your tax return.
▶ Information about Form 8960 and its separate instructions is at www.irs.gov/form8960.
OMB No. 1545-2227
2016
Attachment
Sequence No. 72
Name(s) shown on your tax return Your social security number or EIN
Part I Investment Income Section 6013(g) election (see instructions)
Section 6013(h) election (see instructions)
Regulations section 1.1411-10(g) election (see instructions)
1 Taxable interest (see instructions) . . . . . . . . . . . . . . . . . . . . . 1
2 Ordinary dividends (see instructions) . . . . . . . . . . . . . . . . . . . . 2
3 Annuities (see instructions) . . . . . . . . . . . . . . . . . . . . . . . 3
4a Rental real estate, royalties, partnerships, S corporations, trusts,
etc. (see instructions) . . . . . . . . . . . . . . . 4a
b Adjustment for net income or loss derived in the ordinary course of
a non-section 1411 trade or business (see instructions) . . . . 4b
c Combine lines 4a and 4b . . . . . . . . . . . . . . . . . . . . . . . . 4c
5a Net gain or loss from disposition of property (see instructions) . 5a
b Net gain or loss from disposition of property that is not subject to
net investment income tax (see instructions) . . . . . . . 5b
c Adjustment from disposition of partnership interest or S corporation
stock (see instructions) . . . . . . . . . . . . . . 5c
d Combine lines 5a through 5c . . . . . . . . . . . . . . . . . . . . . . 5d
6 Adjustments to investment income for certain CFCs and PFICs (see instructions) . . . . . 6
7 Other modifications to investment income (see instructions) . . . . . . . . . . . . 7
8 Total investment income. Combine lines 1, 2, 3, 4c, 5d, 6, and 7 . . . . . . . . . . . 8
Part II Investment Expenses Allocable to Investment Income and Modifications
9a Investment interest expenses (see instructions) . . . . . . 9a
b State, local, and foreign income tax (see instructions) . . . . 9b
c Miscellaneous investment expenses (see instructions) . . . . 9c
d Add lines 9a, 9b, and 9c . . . . . . . . . . . . . . . . . . . . . . . . 9d
10 Additional modifications (see instructions) . . . . . . . . . . . . . . . . . . 10
11 Total deductions and modifications. Add lines 9d and 10 . . . . . . . . . . . . . 11
Part III Tax Computation
12 Net investment income. Subtract Part II, line 11 from Part I, line 8. Individuals complete lines 13–
17. Estates and trusts complete lines 18a–21. If zero or less, enter -0- . . . . . . . . . 12
Individuals:
13 Modified adjusted gross income (see instructions) . . . . . 13
14 Threshold based on filing status (see instructions) . . . . . 14
15 Subtract line 14 from line 13. If zero or less, enter -0- . . . . 15
16 Enter the smaller of line 12 or line 15 . . . . . . . . . . . . . . . . . . . . 16
17 Net investment income tax for individuals. Multiply line 16 by 3.8% (.038). Enter here and
includ ...
Form 8582 Department of the Treasury Internal Revenue Ser.docxhanneloremccaffery
Form 8582
Department of the Treasury
Internal Revenue Service (99)
Passive Activity Loss Limitations
▶ See separate instructions.
▶ Attach to Form 1040 or Form 1041.
▶ Information about Form 8582 and its instructions is available at www.irs.gov/form8582.
OMB No. 1545-1008
2016
Attachment
Sequence No. 88
Name(s) shown on return Identifying number
Part I 2016 Passive Activity Loss
Caution: Complete Worksheets 1, 2, and 3 before completing Part I.
Rental Real Estate Activities With Active Participation (For the definition of active participation, see
Special Allowance for Rental Real Estate Activities in the instructions.)
1
a
Activities with net income (enter the amount from Worksheet 1,
column (a)) . . . . . . . . . . . . . . . . . . 1a
b
Activities with net loss (enter the amount from Worksheet 1, column
(b)) . . . . . . . . . . . . . . . . . . . . . 1b ( )
c
Prior years unallowed losses (enter the amount from Worksheet 1,
column (c)) . . . . . . . . . . . . . . . . . . 1c ( )
d Combine lines 1a, 1b, and 1c . . . . . . . . . . . . . . . . . . . . . . 1d
Commercial Revitalization Deductions From Rental Real Estate Activities
2 a Commercial revitalization deductions from Worksheet 2, column (a) . 2a ( )
b
Prior year unallowed commercial revitalization deductions from
Worksheet 2, column (b) . . . . . . . . . . . . . . 2b ( )
c Add lines 2a and 2b . . . . . . . . . . . . . . . . . . . . . . . . . 2c ( )
All Other Passive Activities
3
a
Activities with net income (enter the amount from Worksheet 3,
column (a)) . . . . . . . . . . . . . . . . . . 3a
b
Activities with net loss (enter the amount from Worksheet 3, column
(b)) . . . . . . . . . . . . . . . . . . . . . 3b ( )
c
Prior years unallowed losses (enter the amount from Worksheet 3,
column (c)) . . . . . . . . . . . . . . . . . . 3c ( )
d Combine lines 3a, 3b, and 3c . . . . . . . . . . . . . . . . . . . . . . 3d
4
Combine lines 1d, 2c, and 3d. If this line is zero or more, stop here and include this form with
your return; all losses are allowed, including any prior year unallowed losses entered on line 1c,
2b, or 3c. Report the losses on the forms and schedules normally used . . . . . . . . 4
If line 4 is a loss and: • Line 1d is a loss, go to Part II.
• Line 2c is a loss (and line 1d is zero or more), skip Part II and go to Part III.
• Line 3d is a loss (and lines 1d and 2c are zero or more), skip Parts II and III and go to line 15.
Caution: If your filing status is married filing separately and you lived with your spouse at any time during the year, do not complete
Part II or Part III. Instead, go to line 15.
Part II Special Allowance for Rental Real Estate Activities With Active Participation
Note: Enter all numbers in Part II as positive amounts. See instructions for an example.
5 Enter the smaller of the loss on line 1d or the loss on line 4 . . . . . . . . . . . . 5
6 Enter $150,000. If married filing sepa ...
SCHEDULE E (Form 1040) Department of the Treasury In.docxkenjordan97598
SCHEDULE E
(Form 1040)
Department of the Treasury
Internal Revenue Service (99)
Supplemental Income and Loss
(From rental real estate, royalties, partnerships, S corporations, estates, trusts, REMICs, etc.)
▶ Attach to Form 1040, 1040NR, or Form 1041.
▶ Information about Schedule E and its separate instructions is at www.irs.gov/schedulee.
OMB No. 1545-0074
2014
Attachment
Sequence No. 13
Name(s) shown on return Your social security number
Part I Income or Loss From Rental Real Estate and Royalties Note. If you are in the business of renting personal property, use
Schedule C or C-EZ (see instructions). If you are an individual, report farm rental income or loss from Form 4835 on page 2, line 40.
A Did you make any payments in 2014 that would require you to file Form(s) 1099? (see instructions) Yes No
B If “Yes,” did you or will you file required Forms 1099? Yes No
1a Physical address of each property (street, city, state, ZIP code)
A
B
C
1b Type of Property
(from list below)
A
B
C
2 For each rental real estate property listed
above, report the number of fair rental and
personal use days. Check the QJV box
only if you meet the requirements to file as
a qualified joint venture. See instructions.
Fair Rental
Days
Personal Use
Days
QJV
A
B
C
Type of Property:
1 Single Family Residence
2 Multi-Family Residence
3 Vacation/Short-Term Rental
4 Commercial
5 Land
6 Royalties
7 Self-Rental
8 Other (describe)
Income: Properties: A B C
3 Rents received . . . . . . . . . . . . . 3
4 Royalties received . . . . . . . . . . . . 4
Expenses:
5 Advertising . . . . . . . . . . . . . . 5
6 Auto and travel (see instructions) . . . . . . . 6
7 Cleaning and maintenance . . . . . . . . . 7
8 Commissions. . . . . . . . . . . . . . 8
9 Insurance . . . . . . . . . . . . . . . 9
10 Legal and other professional fees . . . . . . . 10
11 Management fees . . . . . . . . . . . . 11
12 Mortgage interest paid to banks, etc. (see instructions) 12
13 Other interest. . . . . . . . . . . . . . 13
14 Repairs. . . . . . . . . . . . . . . . 14
15 Supplies . . . . . . . . . . . . . . . 15
16 Taxes . . . . . . . . . . . . . . . . 16
17 Utilities . . . . . . . . . . . . . . . . 17
18 Depreciation expense or depletion . . . . . . . 18
19 Other (list) ▶ 19
20 Total expenses. Add lines 5 through 19 . . . . . 20
21 Subtract line 20 from line 3 (rents) and/or 4 (royalties). If
result is a (loss), see instructions to find out if you must
file Form 6198 . . . . . . . . . . . . . 21
22 Deductible rental real estate loss after limitation, if any,
on Form 8582 (see instructions) . . . . . . . 22 ( ) ( ) ( )
23a Total of all amounts reported on line 3 for all rental properties . . . . 23a
b Total of all amounts reported on line 4 for all royalty properties . . . . 23b
c Total of all amounts reported on line 12 for all propertie.
Form 2106 Department of the Treasury Internal Revenue Se.docxbudbarber38650
Form 2106
Department of the Treasury
Internal Revenue Service (99)
Employee Business Expenses
▶ Attach to Form 1040 or Form 1040NR.
▶ Information about Form 2106 and its separate instructions is available at www.irs.gov/form2106.
OMB No. 1545-0074
2013
Attachment
Sequence No. 129
Your name Occupation in which you incurred expenses Social security number
Part I Employee Business Expenses and Reimbursements
Step 1 Enter Your Expenses
Column A
Other Than Meals
and Entertainment
Column B
Meals and
Entertainment
1 Vehicle expense from line 22 or line 29. (Rural mail carriers: See
instructions.) . . . . . . . . . . . . . . . . . . 1
2 Parking fees, tolls, and transportation, including train, bus, etc., that
did not involve overnight travel or commuting to and from work . 2
3 Travel expense while away from home overnight, including lodging,
airplane, car rental, etc. Do not include meals and entertainment . 3
4 Business expenses not included on lines 1 through 3. Do not include
meals and entertainment . . . . . . . . . . . . . . 4
5 Meals and entertainment expenses (see instructions) . . . . . 5
6 Total expenses. In Column A, add lines 1 through 4 and enter the
result. In Column B, enter the amount from line 5 . . . . . . 6
Note: If you were not reimbursed for any expenses in Step 1, skip line 7 and enter the amount from line 6 on line 8.
Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
7
Enter reimbursements received from your employer that were not
reported to you in box 1 of Form W-2. Include any reimbursements
reported under code “L” in box 12 of your Form W-2 (see
instructions) . . . . . . . . . . . . . . . . . . . 7
Step 3 Figure Expenses To Deduct on Schedule A (Form 1040 or Form 1040NR)
8
Subtract line 7 from line 6. If zero or less, enter -0-. However, if line 7
is greater than line 6 in Column A, report the excess as income on
Form 1040, line 7 (or on Form 1040NR, line 8) . . . . . . . 8
Note: If both columns of line 8 are zero, you cannot deduct
employee business expenses. Stop here and attach Form 2106 to
your return.
9
In Column A, enter the amount from line 8. In Column B, multiply line
8 by 50% (.50). (Employees subject to Department of Transportation
(DOT) hours of service limits: Multiply meal expenses incurred while
away from home on business by 80% (.80) instead of 50%. For
details, see instructions.) . . . . . . . . . . . . . . 9
10
Add the amounts on line 9 of both columns and enter the total here. Also, enter the total on
Schedule A (Form 1040), line 21 (or on Schedule A (Form 1040NR), line 7). (Armed Forces
reservists, qualified performing artists, fee-basis state or local government officials, and individuals
with disabilities: See the instructions for s.
VARIOUS FORMS OF INCOME TAX ,BASIC KNOWLEDGE OF GST PPT WHICH REQUIRED FOR A STUDENT TO UNDERSTAND DIRECT AND INDIRECT TAXATION. STUDENTS STUDYING B.COM AND M.COM WILL BE BENEFITED . FOR PRACTITIONERS ALSO WILL BENEFIT.
Form 4562Depreciation and AmortizationOMB No. 1545-0172.docxhanneloremccaffery
Form 4562
Depreciation and Amortization
OMB No. 1545-0172
2013
(Including Information on Listed Property)
Department of the Treasury
Attachment
Internal Revenue Service (99)
▶ See separate instructions.
▶ Attach to your tax return.
Sequence No. 179
Name(s) shown on return
Business or activity to which this form relates
Identifying number
Thom Jones Business 000-00-1111
Part I Election To Expense Certain Property Under Section 179
Note: If you have any listed property, complete Part V before you complete Part I.
1
Maximum amount (see instructions) . . . . . . . . . . . . . . . . . . . . . . .
2
Total cost of section 179 property placed in service (see instructions) . . . . . . . . . . .
3
Threshold cost of section 179 property before reduction in limitation (see instructions) . . . . . .
4
Reduction in limitation. Subtract line 3 from line 2. If zero or less, enter -0- . . . . . . . . . .
5
Dollar limitation for tax year. Subtract line 4 from line 1. If zero or less, enter -0-. If married filing
separately, see instructions . . . . . . . . . . . . . . . . . . . . . . . . .
1
2
3
4
5
6
(a) Description of property
(b) Cost (business use only)
(c) Elected cost
7
Listed property. Enter the amount from line 29 .
. . . . . . . .
7
8
Total elected cost of section 179 property. Add amounts in column (c), lines 6 and 7 . . . . . .
8
9
Tentative deduction. Enter the smaller of line 5 or line 8 . . . . . . . . . . . . . . . .
9
10
Carryover of disallowed deduction from line 13 of your 2012 Form 4562 . . . . . . . . . . .
10
11
Business income limitation. Enter the smaller of business income (not less than zero) or line 5 (see instructions)
11
12
Section 179 expense deduction. Add lines 9 and 10, but do not enter more than line 11 . . . . .
12
13
Carryover of disallowed deduction to 2014. Add lines 9 and 10, less line 12
▶
13
Note: Do not use Part II or Part III below for listed property. Instead, use Part V.
Part II Special Depreciation Allowance and Other Depreciation (Do not include listed property.) (See instructions.)
14
Special depreciation allowance for qualified property (other than listed property) placed
in
service
during the tax year (see instructions) . . . . . . . . . . . . . . . . . .
. .
. .
14
15
Property subject to section 168(f)(1) election . . . . . . . . . . . . . . . .
. .
. .
15
16
Other depreciation (including ACRS) . . . . . . . . . . . . . . . . . .
. .
. .
16
Part III
MACRS Depreciation (Do not include listed property.) (See instructions.)
Section A
17
MACRS deductions for assets placed in service in tax years beginning before 2013 . . .
. .
. .
17
18
If you are electing to group any assets placed in service during ...
You are assisting Dr. Jones with a procedure that has been classifie.docxShainaBoling829
You are assisting Dr. Jones with a procedure that has been classified as sterile. However, you later learn the patient acquired an iatrogenic infection. Who is ultimately responsible for this event? How would you determine responsibility? What information would be required to make this determination? Please support your answer with at least one reference.
Why is it important to know what type of infection a patient has? An infection is an infection, is an infection. Does it matter where it comes from, why or why not, please explain?
.
You are an intelligence analyst for the Federal Bureau of Investigat.docxShainaBoling829
You are an intelligence analyst for the Federal Bureau of Investigation (FBI) assigned to the Counterintelligence (CI) Division. The FBI’s CI Division has been involved in the field of CI for decades. During this period, the CI division has conducted thousands of CI investigations, many of which have had a major impact on the history and national security of the United States. It is important as an intelligence analyst with the CI Division to have a clear understanding of these cases and to learn from both its past CI successes and failures.
You have been asked by your supervisor to research major espionage cases to produce an intelligence assessment from a historical perspective that will help to recognize anomalies that might indicate the presence of espionage and assist in the neutralization process in the future.
Assignment Guidelines
For this assignment, you must write a counterintelligence case study, approximately 750 words in length, on one of the following major espionage cases:
Robert P. Hanssen
Aldrich H. Ames
Ana B. Montes
John A. Walker
For your selected case study, you will address the following in detail:
Who
What was this person's personal background?
What was this person's professional background?
Were there any accomplices? If so, explain.
Which foreign powers were involved?
When
When did the espionage begin?
For how long did the espionage continue?
When was the spy apprehended?
Where
Where did the espionage take place?
Consider military intelligence, U.S. soil, agency/rank, and so on.
What
What information was being leaked?
For what purposes could that information have been used?
How
How was the information taken from U.S. facilities or databases? Explain in detail.
How was the information delivered to the foreign power or powers? Explain.
How was the spy apprehended? Explain.
Why
What was the motivation for the espionage? Explain.
Answer the following questions as well:
What lessons were learned after the selected case concluded?
What impact did this particular case have on U.S. policies and operational standards?
Consider successful and unsuccessful investigative techniques, implications, and recommendations.
Compile your responses in your final case study, and submit the file to your instructor.
All sources must be referenced using APA style.
.
More Related Content
Similar to Form 1118 (Rev. December 2020)Department of the Treasury
SCHEDULE E (Form 1040) Department of the Treasury In.docxkenjordan97598
SCHEDULE E
(Form 1040)
Department of the Treasury
Internal Revenue Service (99)
Supplemental Income and Loss
(From rental real estate, royalties, partnerships, S corporations, estates, trusts, REMICs, etc.)
▶ Attach to Form 1040, 1040NR, or Form 1041.
▶ Information about Schedule E and its separate instructions is at www.irs.gov/schedulee.
OMB No. 1545-0074
2014
Attachment
Sequence No. 13
Name(s) shown on return Your social security number
Part I Income or Loss From Rental Real Estate and Royalties Note. If you are in the business of renting personal property, use
Schedule C or C-EZ (see instructions). If you are an individual, report farm rental income or loss from Form 4835 on page 2, line 40.
A Did you make any payments in 2014 that would require you to file Form(s) 1099? (see instructions) Yes No
B If “Yes,” did you or will you file required Forms 1099? Yes No
1a Physical address of each property (street, city, state, ZIP code)
A
B
C
1b Type of Property
(from list below)
A
B
C
2 For each rental real estate property listed
above, report the number of fair rental and
personal use days. Check the QJV box
only if you meet the requirements to file as
a qualified joint venture. See instructions.
Fair Rental
Days
Personal Use
Days
QJV
A
B
C
Type of Property:
1 Single Family Residence
2 Multi-Family Residence
3 Vacation/Short-Term Rental
4 Commercial
5 Land
6 Royalties
7 Self-Rental
8 Other (describe)
Income: Properties: A B C
3 Rents received . . . . . . . . . . . . . 3
4 Royalties received . . . . . . . . . . . . 4
Expenses:
5 Advertising . . . . . . . . . . . . . . 5
6 Auto and travel (see instructions) . . . . . . . 6
7 Cleaning and maintenance . . . . . . . . . 7
8 Commissions. . . . . . . . . . . . . . 8
9 Insurance . . . . . . . . . . . . . . . 9
10 Legal and other professional fees . . . . . . . 10
11 Management fees . . . . . . . . . . . . 11
12 Mortgage interest paid to banks, etc. (see instructions) 12
13 Other interest. . . . . . . . . . . . . . 13
14 Repairs. . . . . . . . . . . . . . . . 14
15 Supplies . . . . . . . . . . . . . . . 15
16 Taxes . . . . . . . . . . . . . . . . 16
17 Utilities . . . . . . . . . . . . . . . . 17
18 Depreciation expense or depletion . . . . . . . 18
19 Other (list) ▶ 19
20 Total expenses. Add lines 5 through 19 . . . . . 20
21 Subtract line 20 from line 3 (rents) and/or 4 (royalties). If
result is a (loss), see instructions to find out if you must
file Form 6198 . . . . . . . . . . . . . 21
22 Deductible rental real estate loss after limitation, if any,
on Form 8582 (see instructions) . . . . . . . 22 ( ) ( ) ( )
23a Total of all amounts reported on line 3 for all rental properties . . . . 23a
b Total of all amounts reported on line 4 for all royalty properties . . . . 23b
c Total of all amounts reported on line 12 for all propertie.
Form 2106 Department of the Treasury Internal Revenue Se.docxbudbarber38650
Form 2106
Department of the Treasury
Internal Revenue Service (99)
Employee Business Expenses
▶ Attach to Form 1040 or Form 1040NR.
▶ Information about Form 2106 and its separate instructions is available at www.irs.gov/form2106.
OMB No. 1545-0074
2013
Attachment
Sequence No. 129
Your name Occupation in which you incurred expenses Social security number
Part I Employee Business Expenses and Reimbursements
Step 1 Enter Your Expenses
Column A
Other Than Meals
and Entertainment
Column B
Meals and
Entertainment
1 Vehicle expense from line 22 or line 29. (Rural mail carriers: See
instructions.) . . . . . . . . . . . . . . . . . . 1
2 Parking fees, tolls, and transportation, including train, bus, etc., that
did not involve overnight travel or commuting to and from work . 2
3 Travel expense while away from home overnight, including lodging,
airplane, car rental, etc. Do not include meals and entertainment . 3
4 Business expenses not included on lines 1 through 3. Do not include
meals and entertainment . . . . . . . . . . . . . . 4
5 Meals and entertainment expenses (see instructions) . . . . . 5
6 Total expenses. In Column A, add lines 1 through 4 and enter the
result. In Column B, enter the amount from line 5 . . . . . . 6
Note: If you were not reimbursed for any expenses in Step 1, skip line 7 and enter the amount from line 6 on line 8.
Step 2 Enter Reimbursements Received From Your Employer for Expenses Listed in Step 1
7
Enter reimbursements received from your employer that were not
reported to you in box 1 of Form W-2. Include any reimbursements
reported under code “L” in box 12 of your Form W-2 (see
instructions) . . . . . . . . . . . . . . . . . . . 7
Step 3 Figure Expenses To Deduct on Schedule A (Form 1040 or Form 1040NR)
8
Subtract line 7 from line 6. If zero or less, enter -0-. However, if line 7
is greater than line 6 in Column A, report the excess as income on
Form 1040, line 7 (or on Form 1040NR, line 8) . . . . . . . 8
Note: If both columns of line 8 are zero, you cannot deduct
employee business expenses. Stop here and attach Form 2106 to
your return.
9
In Column A, enter the amount from line 8. In Column B, multiply line
8 by 50% (.50). (Employees subject to Department of Transportation
(DOT) hours of service limits: Multiply meal expenses incurred while
away from home on business by 80% (.80) instead of 50%. For
details, see instructions.) . . . . . . . . . . . . . . 9
10
Add the amounts on line 9 of both columns and enter the total here. Also, enter the total on
Schedule A (Form 1040), line 21 (or on Schedule A (Form 1040NR), line 7). (Armed Forces
reservists, qualified performing artists, fee-basis state or local government officials, and individuals
with disabilities: See the instructions for s.
VARIOUS FORMS OF INCOME TAX ,BASIC KNOWLEDGE OF GST PPT WHICH REQUIRED FOR A STUDENT TO UNDERSTAND DIRECT AND INDIRECT TAXATION. STUDENTS STUDYING B.COM AND M.COM WILL BE BENEFITED . FOR PRACTITIONERS ALSO WILL BENEFIT.
Form 4562Depreciation and AmortizationOMB No. 1545-0172.docxhanneloremccaffery
Form 4562
Depreciation and Amortization
OMB No. 1545-0172
2013
(Including Information on Listed Property)
Department of the Treasury
Attachment
Internal Revenue Service (99)
▶ See separate instructions.
▶ Attach to your tax return.
Sequence No. 179
Name(s) shown on return
Business or activity to which this form relates
Identifying number
Thom Jones Business 000-00-1111
Part I Election To Expense Certain Property Under Section 179
Note: If you have any listed property, complete Part V before you complete Part I.
1
Maximum amount (see instructions) . . . . . . . . . . . . . . . . . . . . . . .
2
Total cost of section 179 property placed in service (see instructions) . . . . . . . . . . .
3
Threshold cost of section 179 property before reduction in limitation (see instructions) . . . . . .
4
Reduction in limitation. Subtract line 3 from line 2. If zero or less, enter -0- . . . . . . . . . .
5
Dollar limitation for tax year. Subtract line 4 from line 1. If zero or less, enter -0-. If married filing
separately, see instructions . . . . . . . . . . . . . . . . . . . . . . . . .
1
2
3
4
5
6
(a) Description of property
(b) Cost (business use only)
(c) Elected cost
7
Listed property. Enter the amount from line 29 .
. . . . . . . .
7
8
Total elected cost of section 179 property. Add amounts in column (c), lines 6 and 7 . . . . . .
8
9
Tentative deduction. Enter the smaller of line 5 or line 8 . . . . . . . . . . . . . . . .
9
10
Carryover of disallowed deduction from line 13 of your 2012 Form 4562 . . . . . . . . . . .
10
11
Business income limitation. Enter the smaller of business income (not less than zero) or line 5 (see instructions)
11
12
Section 179 expense deduction. Add lines 9 and 10, but do not enter more than line 11 . . . . .
12
13
Carryover of disallowed deduction to 2014. Add lines 9 and 10, less line 12
▶
13
Note: Do not use Part II or Part III below for listed property. Instead, use Part V.
Part II Special Depreciation Allowance and Other Depreciation (Do not include listed property.) (See instructions.)
14
Special depreciation allowance for qualified property (other than listed property) placed
in
service
during the tax year (see instructions) . . . . . . . . . . . . . . . . . .
. .
. .
14
15
Property subject to section 168(f)(1) election . . . . . . . . . . . . . . . .
. .
. .
15
16
Other depreciation (including ACRS) . . . . . . . . . . . . . . . . . .
. .
. .
16
Part III
MACRS Depreciation (Do not include listed property.) (See instructions.)
Section A
17
MACRS deductions for assets placed in service in tax years beginning before 2013 . . .
. .
. .
17
18
If you are electing to group any assets placed in service during ...
You are assisting Dr. Jones with a procedure that has been classifie.docxShainaBoling829
You are assisting Dr. Jones with a procedure that has been classified as sterile. However, you later learn the patient acquired an iatrogenic infection. Who is ultimately responsible for this event? How would you determine responsibility? What information would be required to make this determination? Please support your answer with at least one reference.
Why is it important to know what type of infection a patient has? An infection is an infection, is an infection. Does it matter where it comes from, why or why not, please explain?
.
You are an intelligence analyst for the Federal Bureau of Investigat.docxShainaBoling829
You are an intelligence analyst for the Federal Bureau of Investigation (FBI) assigned to the Counterintelligence (CI) Division. The FBI’s CI Division has been involved in the field of CI for decades. During this period, the CI division has conducted thousands of CI investigations, many of which have had a major impact on the history and national security of the United States. It is important as an intelligence analyst with the CI Division to have a clear understanding of these cases and to learn from both its past CI successes and failures.
You have been asked by your supervisor to research major espionage cases to produce an intelligence assessment from a historical perspective that will help to recognize anomalies that might indicate the presence of espionage and assist in the neutralization process in the future.
Assignment Guidelines
For this assignment, you must write a counterintelligence case study, approximately 750 words in length, on one of the following major espionage cases:
Robert P. Hanssen
Aldrich H. Ames
Ana B. Montes
John A. Walker
For your selected case study, you will address the following in detail:
Who
What was this person's personal background?
What was this person's professional background?
Were there any accomplices? If so, explain.
Which foreign powers were involved?
When
When did the espionage begin?
For how long did the espionage continue?
When was the spy apprehended?
Where
Where did the espionage take place?
Consider military intelligence, U.S. soil, agency/rank, and so on.
What
What information was being leaked?
For what purposes could that information have been used?
How
How was the information taken from U.S. facilities or databases? Explain in detail.
How was the information delivered to the foreign power or powers? Explain.
How was the spy apprehended? Explain.
Why
What was the motivation for the espionage? Explain.
Answer the following questions as well:
What lessons were learned after the selected case concluded?
What impact did this particular case have on U.S. policies and operational standards?
Consider successful and unsuccessful investigative techniques, implications, and recommendations.
Compile your responses in your final case study, and submit the file to your instructor.
All sources must be referenced using APA style.
.
You are a Wichita Police Department detective working in the major c.docxShainaBoling829
You are a Wichita Police Department detective working in the major crimes unit, and you are assigned to a joint federal–state–city crime task force working on a number of major drug cases. Over a period of several months, your task force has been able to gather information and make cases on several of the drug suppliers, drug dealers, and drug buyers in the Wichita metropolitan area. The task force is about to complete its mission by filing criminal charges in the federal district court, the state district court, or the Wichita Municipal Court against these various suspects. These suspects will not be arrested until the warrants are issued.
Your job is to make recommendations concerning which jurisdictions should file the charges on which defendants. You will need to evaluate the criminal statutes and penalties in each jurisdiction and even the rules of evidence to determine where your task force has the best chance of obtaining a conviction and in getting the punishment to fit the crime.
The memo that you receive from your Drug Enforcement Administration (DEA) task force supervisor explains the situation:
MEMO
Re: Charging Decisions
You are the primary investigator in the cases against Jones, Smith, and Thompson. As I review your reports, it appears that each of these cases has strengths and weaknesses that we should evaluate before we determine whether to file charges in the U.S. District Court, the Sedgwick County District Court for the State of Kansas, or the Wichita Municipal Court. I will summarize those strengths and weaknesses here to make sure I am reading your reports correctly. I need you to give me advice on where you think these charges should be brought.
Jones has been working for you as a confidential informant because you have evidence against him for a February 6, 2005 third possession of cocaine after convictions in 1993 and 1994. He appears to have followed the terms of his deal with you to introduce our undercover agents to his dealer. We have promised not to prosecute for any drug offenses he may commit in the presence of our undercover agent while playing the role of our informant. His assistance has enabled us to get sufficient evidence on Smith and Thompson to obtain convictions. Based on Jones’ two prior convictions for possession of cocaine, we would normally want him to go to federal court, where the maximum sentences are available. However, because of his cooperation, we could file the case in the Sedgwick County, Kansas, and district court under state law. We could even change the charge to a drug paraphernalia offense and send his case to the city of Wichita.
How do you think we should proceed concerning Jones' February 6, 2005 cocaine possession? (30%)
He will probably plead guilty unless we send him to federal court. Where do you want to file the case? (20%)
Smith has sold cocaine to our undercover agents on two occasions: July 12, 2005 and August 3, 2005. We have found no prior record on this individual, bu.
You are a primary care physician in a large group practice that uses.docxShainaBoling829
You are a primary care physician in a large group practice that uses an electronic health record (EHR). At the beginning of each visit, you view a dashboard of preventive care measures - like flu vaccine, colon cancer screening, cholesterol tests - that are due for your patient, based on age, medical history (problem list), and medication list stored in the EHR
.
You are a police officer assigned to a task force that is investigat.docxShainaBoling829
You are a police officer assigned to a task force that is investigating major drug trafficking operations in your jurisdiction. As part of the investigative process, a judge has issued a wiretap order for a suspect’s phone. You are assigned the responsibility of monitoring phone conversations, and you overhear the suspect as well as other individuals who may or may not be involved in the drug ring. Before obtaining enough evidence to arrest and prosecute the suspect, you hear evidence related to other types of criminal activity.
Assignment Guidelines
Address the following in 900–1,200 words:
What constitutional issues are involved in the scenario that dictates what you can and cannot do related to the evidence of other criminal activity outside the scope of the original wiretap order? Explain.
If you arrest the other individuals for the crimes not associated with the reasons for the wiretap, what happens to any future evidence that might be obtained from the wiretap? Why?
If you fail to arrest the other individuals, are there any potential risks involved? Explain you answer.
Be sure to reference all sources using APA style.
.
You are a patient at seeing a Plastic Surgeon for a consultation. Du.docxShainaBoling829
You are a patient at seeing a Plastic Surgeon for a consultation. During your visit, the physician takes out his cell phone and takes several pictures of the areas for the surgery. During this process the physician explains that this will be a part of his before and after collection.
Is there a problem with him using his personal cell phone and not a camera dedicated to the medical practice? Did you sign some disclaimer saying photos could be taken for non-medical purposes? How do you feel about what the physician did? Are there any violation(s)? If so, explain. How would you handle this situation? Create a 2-3 page paper to answer the questions in this case study.
.
You are a new PR intern at Apple. Apple is donating 200 iPads to a l.docxShainaBoling829
you are a new PR intern at Apple. Apple is donating 200 Ipads to a local inner-city school to promote technology in education. As a PR intern, you need to get the word out about this event. In your discussion post, compose a tweet (a tweet is 140 characters or less) and a Facebook post (200-250 words) creating awareness for the event.
.
You are a leader of a European country. You want your country to get.docxShainaBoling829
You are a leader of a European country. You want your country to get involved in South America for resources, markets ad trade.write a letter to president monroe of the united states and respond to the monroe doctrine. What steps will you take to complete your intention of getting involved in South America?
.
You are a community health educator and you have been tasked with de.docxShainaBoling829
You are a community health educator and you have been tasked with developing a presentation to be given in a setting to educate an audience on one specific kind of diabetes.
Identify
your audience. Examples include the following:
Senior center
Middle school
A Workplace
Create
a 350- to 700-word resource as a way to share this information. Examples include the following:
A social media page
An information pamphlet
A presentation
Consider
the best method so it is crafted in an appropriate and understandable way for your identified audience.
Choose
from the two following options, which kind of diabetes you'll be reporting on:
Option A: Type I
How society views diabetes (what society thinks it is versus what it actually is, common beliefs and practices)
Signs and symptoms
Compliance with treatment regimens
Impact on health care resources
Option B: Type II
How society views diabetes (what society thinks it is versus what it actually is)
Preventive measures
Making the right decisions to live a healthy life
Compliance with common beliefs
Impact on health care resources
.
You and your team have completed your fieldwork and have a handful o.docxShainaBoling829
You and your team have completed your fieldwork and have a handful of other considerations before you compete the audit and issue your report. These activities are designed to ensure nothing significant has occurred between the completion of your fieldwork and the issuing of the audit report. You are assigned as a senior on the staff, in line to be promoted to manager, to instruct the other staff on the importance of considering contingent liabilities, letters from client lawyers, and subsequent events.
Create
a 10- to 12-slide presentation for the staff.
Explain
the importance of reviewing for contingent liabilities and subsequent events.
Describe
the requirements for reviewing for contingent liabilities and subsequent events.
The Company selected is "APPLE"
What I need to concentrate on is complete 5 slides DESCRIBING THE REQUIREMENTS FOR REVIEWING FOR CONTINGENT LIABILITIES AND SUBSEQUENT EVENTS.
AND THE CONCLUSION
USE SPEAKER NOTES AS WELL.
.
xxxx, great post. I agree that as technology has grown so has the .docxShainaBoling829
xxxx, great post. I agree that as technology has grown so has the influence of the media. It is now that we can see it as it is happening, but most time we have someone "telling us" what is happening. I agree that the public is given information passed on through society's filters. This can be dangerous depending on who is sending and releasing the information.
I also agree that our dress choices are influenced by the media, especially social media at this point. Some many other things are put out there and most time it’s a false image. It is sad that sometimes people build their lives upon social media and its "famous" people. It is sad that some people are not being themselves because they are following a lie on social media. As a people we must learn that it’s ok not to follow the masses and be ourselves, and not believe the lie that you are nothing if you don't have the life, the job, and the things that is portrayed in the media.
.
Yes Richard I agree with you. The American Red Cross has been workin.docxShainaBoling829
Yes Richard I agree with you. The American Red Cross has been working alongside families and communities in Haiti for more than 10 years. When a 7.0 earthquake struck the country in 2010, Americans’ generosity has made this critical work possible. Thanks to donations from across the United States, American Red Cross continue to help Haitians recover from these disasters. They still provide food, water, medical care, sanitation and emergency shelter to families in need. Over the past seven years, they have funded more than 50 hospitals and clinics in Haiti and so much more.They continue working alongside the Haitian Red Cross to ensure that recovery is long-lasting and that families are prepared for future disasters that may come their way
I NEED YOU TO COMMENT FROM THIS POST, NO MORE THAN 150 WORDS NEEDED AND A REFERNCE PLEASE
.
Yet society has in every possible way created the impression that on.docxShainaBoling829
Yet society has in every possible way created the impression that only some are in God’s favor and the others out. By our dress, color, nationality, wealth, age, gender, education, language, looks, and health, others can recognize instantly whether we are blessed or cursed, beloved or rejected. There are enormous benefits in going along with this selective grading of human beings, and severe penalties inflicted for its rejection. For these that God does not sit atop the pyramid of power accidents of genetics and class determine one’s social location and power, and anyone who tampers with them undermines the foundations of unequal privilege. To say legitimating the entire edifice, does not favor some and reject others, is to expose the entire structure as human contrivance established in defiance of God’s very nature. ––Walter Wink
300 words for forum.
How do Wink's ideas about privilege and power compare to Johnson's, Ehrenreich's, and Bader-Saye's ideas? [This question casts a wide net; please feel free to write about the ideas in which
you
are most interested.] How are they different? How might you integrate Bader-Saye's ideas about the risks of hospitality, generosity and peacemaking with Wink’s theology of social transformation [as represented in his quotation above]? How might you use the experiences/stories of the people we have read about/viewed/listened to this semester including all of the following:
the women in Ehrenreich's
Nickel and Dimed,
the characters from your
Multicultural Children's Picture Book
the characters from
Hotel Rwanda, Come See the Paradise
and
El Norte
the characters in
If These Walls Could Talk 2
The Girls Next Door
In your posting please use these stories to illustrate Wink’s view of the connection between social transformation and our
commitment to the general welfare--
regardless of our social location. Post three questions about how
Nickel and Dimed
and
Following Jesus in a Culture of Fear
deal with the focus of this forum and respond to
at least
four other questions posted by the other members of your cohort.
.
xxxxx comment 1xxxxx, I believe America only sees leftright, li.docxShainaBoling829
xxxxx comment 1
xxxxx, I believe America only sees left/right, liberal/conservative, one's race/others' race, one's religion/others' religion, etc. To be fair, there are important issues that we do face but the media has pulled both further from the center. This is done to keep us preoccupied in conflict so we ignore what is being done in front of our faces, which is politicians/media/wealthy elites are controlling the government/financial system/media to mold the public's views and what they buy. By them focusing on these secondary issues and differences, we are missing the root problem: money in politics. These legal bribes guarantee that we are not represented in legislation unless enough people oppose the current law.
Comment 2
Nicely said, it is amazing how money can be used to basically buy anything in the world, even our politicians. The Presidency, our Senators and Congressman, Governors, Mayor's and more. This allows for things like the rich getting richer and the poor or course getting poorer. It almost seems like there is no middle class anymore. Money plays a huge role in everyday life. Don't get me wrong, money and politicians has definitely been used in some cases for the good or doing the right thing. We cannot base everything evil or not perfect on money. We just have to be more responsible.
.
WWTC Active Directory DesignWWTC office at New York is largely a.docxShainaBoling829
WWTC Active Directory Design
WWTC office at New York is largely autonomous and few IT personnel to take care of day-to-day IT support activities such as password resets troubleshoot virus problems. You are concerned about sensitive data store in this location. You want to deploy a highly developed OU structure to implement security policies uniformly through GPO automatically at all domains, OU, and workstations.
At this location Windows Server 2012 R2 is required providing the following
10 AD features
:
1.
Use BitLocker encryption technology for devices (server and Work station) disc space and volume.
2.
Enables a BitLocker system on a wire
d network to automatically unlock the system volume during boot (on capable Windows Server 2012 R2 networks), reducing internal help desk call volumes for lost PINs.
3.
Create group policies settings to enforce that either Used Disk Space Only or Full Encryption is used when BitLocker is enabled on a drive.
4.
Enable BranchCache in Windows Server 2012 for substantial performance, manageability, scalability, and availability improvements
5.
Implement Cache Encryption to store encrypted data by default.
This allows you to ensure data security without using drive encryption technologies.
6.
Implement Failover cluster services
7.
Implement File classification infrastructure feature to provide automatic classification process.
8.
IP Address Management (IPAM) is an entirely new feature in Windows Server 2012 that provides highly customizable administrative and monitoring capabilities for the IP address infrastructure on a corporate network.
9.
Smart cards and their associated personal identification numbers (PINs) are an increasingly popular, reliable, and cost-effective form of two-factor authentication. With the right controls in place, a user must have the smart card and know the PIN to gain access to network resources.
10.
Implement Windows Deployment Services to enables you to remotely deploy Windows operating systems. You can use it to set up new computers by using a network-based installation.
Other AD Deliverables
:
Create Active directory infrastructure to include recommended features
Create OU level for users and devices in their respective OU
Create Global, Universal, Local group. Each global group will contain all users in the corresponding department. Membership in the universal group is restrictive and membership can be assigned on the basis of least privileged principle. (For design purpose, you can assume that WTC as a Single Forest with multiple domains).
Create appropriate GPO and GPO policies and determine where they will be applied
.
Wrongful Convictions and the Utilization of Eyewitness Accounts Wr.docxShainaBoling829
Wrongful Convictions and the Utilization of Eyewitness Accounts
Write a 2 to 3 page paper responding to the following: APA FORMAT
Identify the ethical issues within the field of criminal investigation as applied to wrongful conviction based upon tainted or faulty line-ups.
In recent years we have seen many criminal convictions overturned for various reasons. One such reason is the “Eyewitness Account.”
Address the ethical responsibilities of law enforcement in their requirements for fairness, and responsibility to ensure there are no wrongful convictions based upon false identification.
Identify the processes utilized by law enforcement in the identification of suspects.
Consider individuals making identifications, do so in error at times, others intentionally, or are led by law enforcement through improper actions i.e., prejudicial line-ups or photo arrays.
.
Written Report on Documentary Enron The Smartest Guys in the Roo.docxShainaBoling829
Written Report on Documentary:
Enron: The Smartest Guys in the Room
For this assignment view the video,
ENRON:
The Smartest Guys in the Room,
[1 hr. & 50 min].
Write a critique of the film in 4-5 page double-spaced paper.
Answer each of the following questions in your essay.
The written assessment of
Enron
is due according to Syllabus.
Submit a paper copy in class and also post it on BB website SafeAssign.
2.
Describe the dominant culture of ENRON and the subculture of Enron’s trading group.
3.
Do you believe that Enron’ failure is a result of the behavior of “a few bad men”, or a demonstration of the “dark shadow of the American dream”?
Explain.
4.
What did Skilling say is the only thing that motivates people?
Do you agree or disagree?
5.
Describe the PRC (performance review committee).
Why was it referred to as “rank and yank”?
What was its effect?
What is your opinion of the ethics of the practice?
6.
Describe Enron’s initiative on broadband technology.
7.
What was Arthur Andersen’s conflict of interest in regards to Enron?
What could have been done to prevent this conflict of interest?
8.
How did Skilling treat Fortune author Bethany McLean when she started asking questions about Enron’s financials?
Do you think this was a tactic, and if so, what did he hope to achieve by it?
9.
What are three important “takeaway” messages you learned from this documentary?
.
Written assignment,. please follow instruction..Legislative Prof.docxShainaBoling829
Written assignment,. please follow instruction..
Legislative Profiles
United States Senate
*You may put the answers to each questions directly into this document and submit.
Choose
one
of the two United States Senators for the State of Texas or the State in which you live.
1.
Name of the Senator
2.
Address of the senator’s official website
3.
The senator’s party affiliation (e.g. Republican, Democrat, Independent)
4.
Name of the State represented
5.
Senatorial Electoral history
a.
Last election the senator won
i.
Name of the senator’s opponent.
ii.
Results of the election. (E.g. Geisler def. Brownfield, 52%-48%)
6.
Committee assignments
a.
Name all the committees the senator currently serves on.
7.
Political beliefs (in addition to their political party affiliation note any important positions they have publically taken on various political issues).
This should be in your own words and at least one paragraph long.
Make sure you include the source of your information.
8.
At least one quote that shows their political views on some topic. Be sure to include the source of your quote)
9.
One-paragraph summary based on a video of the senator speaking either on the Senate floor or being interviewed on a news program.
a.
You will need to find a video online – should be at least 3 min. This can usually be found on the senator’s website or on YouTube.
b.
Include the web address of the video that I can watch—this is required.
c.
Summarize in a few sentences the main argument of the senator’s speech.
United States House of Representatives
10.
The nine-digit zip code of your home address. Check
http://zip4.usps.com/zip4/welcome.jsp
which is the zip code lookup on the United States Postal Service website.
11.
The United States Congressional district in which you live.
12.
Name of your Representative
13.
Address of your representative’s official website
14.
Your representative’s party affiliation (e.g. Republican, Democrat, Independent)
15.
Congressional Electoral history
a.
Last election the representative won
i.
Name of the representative’s opponent.
ii.
Results of the election. (E.g. Geisler def. Brownfield, 52%-48%)
16.
Committee assignments
a.
Name the committees the representative currently serves on.
17.
Political beliefs (in addition to their political party affiliation note any important positions they have publically taken on various political issues).
This should be in your own words. and at least one paragraph long.
Make sure you include the source of your information.
18.
At least one quote that shows their political views on some topic. Be sure to include the source of your quote.
19.
One-paragraph summary based on a video of the congressman speaking either on the Senate floor or being interviewed on a news program.
a.
You will need to find a video online – should be at least 3 min, no longer than 10 min. Something like this can usually be fo.
Written Assignment Choose a Part 121 air carrier(such as Am.docxShainaBoling829
Written Assignment:
Choose
a Part 121 air carrier
(such as American, Delta, Southwest, etc.) and provide data that shows how that enterprise has successfully employed competitive advantage obtained through the utilization of information technology to win and keep loyal customers or operate more efficiently in the reservations, maintenance, or operations departments. You may provide a historical example that would be found going back several decades. Learning from the past is a great way to succeed in the future.
.
WRITTEN ASSIGNMENT for Unit 11 is to write a eulogy, no longer than .docxShainaBoling829
WRITTEN ASSIGNMENT for Unit 11 is to write a eulogy, no longer than 2-3 minutes if actually presented, for a deceased person or about someone who is still alive (what you would you say). Write a possible “manuscript” that might have been transcribed from what you would have said. The same principles--creative intro, support, and conclusion, transitions—apply. Do not record the speech nor provide an outline. Here, simply upload and copy and paste the manuscript, written word-for-word.
.
The Indian economy is classified into different sectors to simplify the analysis and understanding of economic activities. For Class 10, it's essential to grasp the sectors of the Indian economy, understand their characteristics, and recognize their importance. This guide will provide detailed notes on the Sectors of the Indian Economy Class 10, using specific long-tail keywords to enhance comprehension.
For more information, visit-www.vavaclasses.com
The Roman Empire A Historical Colossus.pdfkaushalkr1407
The Roman Empire, a vast and enduring power, stands as one of history's most remarkable civilizations, leaving an indelible imprint on the world. It emerged from the Roman Republic, transitioning into an imperial powerhouse under the leadership of Augustus Caesar in 27 BCE. This transformation marked the beginning of an era defined by unprecedented territorial expansion, architectural marvels, and profound cultural influence.
The empire's roots lie in the city of Rome, founded, according to legend, by Romulus in 753 BCE. Over centuries, Rome evolved from a small settlement to a formidable republic, characterized by a complex political system with elected officials and checks on power. However, internal strife, class conflicts, and military ambitions paved the way for the end of the Republic. Julius Caesar’s dictatorship and subsequent assassination in 44 BCE created a power vacuum, leading to a civil war. Octavian, later Augustus, emerged victorious, heralding the Roman Empire’s birth.
Under Augustus, the empire experienced the Pax Romana, a 200-year period of relative peace and stability. Augustus reformed the military, established efficient administrative systems, and initiated grand construction projects. The empire's borders expanded, encompassing territories from Britain to Egypt and from Spain to the Euphrates. Roman legions, renowned for their discipline and engineering prowess, secured and maintained these vast territories, building roads, fortifications, and cities that facilitated control and integration.
The Roman Empire’s society was hierarchical, with a rigid class system. At the top were the patricians, wealthy elites who held significant political power. Below them were the plebeians, free citizens with limited political influence, and the vast numbers of slaves who formed the backbone of the economy. The family unit was central, governed by the paterfamilias, the male head who held absolute authority.
Culturally, the Romans were eclectic, absorbing and adapting elements from the civilizations they encountered, particularly the Greeks. Roman art, literature, and philosophy reflected this synthesis, creating a rich cultural tapestry. Latin, the Roman language, became the lingua franca of the Western world, influencing numerous modern languages.
Roman architecture and engineering achievements were monumental. They perfected the arch, vault, and dome, constructing enduring structures like the Colosseum, Pantheon, and aqueducts. These engineering marvels not only showcased Roman ingenuity but also served practical purposes, from public entertainment to water supply.
We all have good and bad thoughts from time to time and situation to situation. We are bombarded daily with spiraling thoughts(both negative and positive) creating all-consuming feel , making us difficult to manage with associated suffering. Good thoughts are like our Mob Signal (Positive thought) amidst noise(negative thought) in the atmosphere. Negative thoughts like noise outweigh positive thoughts. These thoughts often create unwanted confusion, trouble, stress and frustration in our mind as well as chaos in our physical world. Negative thoughts are also known as “distorted thinking”.
Read| The latest issue of The Challenger is here! We are thrilled to announce that our school paper has qualified for the NATIONAL SCHOOLS PRESS CONFERENCE (NSPC) 2024. Thank you for your unwavering support and trust. Dive into the stories that made us stand out!
How to Split Bills in the Odoo 17 POS ModuleCeline George
Bills have a main role in point of sale procedure. It will help to track sales, handling payments and giving receipts to customers. Bill splitting also has an important role in POS. For example, If some friends come together for dinner and if they want to divide the bill then it is possible by POS bill splitting. This slide will show how to split bills in odoo 17 POS.
2024.06.01 Introducing a competency framework for languag learning materials ...Sandy Millin
http://sandymillin.wordpress.com/iateflwebinar2024
Published classroom materials form the basis of syllabuses, drive teacher professional development, and have a potentially huge influence on learners, teachers and education systems. All teachers also create their own materials, whether a few sentences on a blackboard, a highly-structured fully-realised online course, or anything in between. Despite this, the knowledge and skills needed to create effective language learning materials are rarely part of teacher training, and are mostly learnt by trial and error.
Knowledge and skills frameworks, generally called competency frameworks, for ELT teachers, trainers and managers have existed for a few years now. However, until I created one for my MA dissertation, there wasn’t one drawing together what we need to know and do to be able to effectively produce language learning materials.
This webinar will introduce you to my framework, highlighting the key competencies I identified from my research. It will also show how anybody involved in language teaching (any language, not just English!), teacher training, managing schools or developing language learning materials can benefit from using the framework.
How to Create Map Views in the Odoo 17 ERPCeline George
The map views are useful for providing a geographical representation of data. They allow users to visualize and analyze the data in a more intuitive manner.
The Art Pastor's Guide to Sabbath | Steve ThomasonSteve Thomason
What is the purpose of the Sabbath Law in the Torah. It is interesting to compare how the context of the law shifts from Exodus to Deuteronomy. Who gets to rest, and why?
Welcome to TechSoup New Member Orientation and Q&A (May 2024).pdfTechSoup
In this webinar you will learn how your organization can access TechSoup's wide variety of product discount and donation programs. From hardware to software, we'll give you a tour of the tools available to help your nonprofit with productivity, collaboration, financial management, donor tracking, security, and more.
Form 1118 (Rev. December 2020)Department of the Treasury
1. Form 1118
(Rev. December 2020)
Department of the Treasury
Internal Revenue Service
Foreign Tax Credit—Corporations
▶ Attach to the corporation’s tax return.
▶ Go to www.irs.gov/Form1118 for instructions and the latest
information.
For calendar year 20 , or other tax year beginning , 20 , and
ending , 20
OMB No. 1545-0123
Attachment
Sequence No. 118
Name of corporation Employer identification number
Use a separate Form 1118 for each applicable category of
income (see instructions).
a Separate Category (Enter code—see instructions.) . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . ▶
b If code 901j is entered on line a, enter the country code for
the sanctioned country (see instructions) . . . . . . . . . . . . . . ▶
c If one of the RBT codes is entered on line a, enter the country
code for the treaty country (see instructions) . . . . . . . . . . . . ▶
Schedule A Income or (Loss) Before Adjustments (Report all
2. amounts in U.S. dollars. See Specific Instructions.)
1. EIN or Reference ID
Number
(see instructions)*
2. Foreign Country or
U.S. Possession
(enter two-letter code—use
a separate line for each)
(see instructions)
Gross Income or (Loss) From Sources Outside the United States
3. Inclusions Under Sections 951(a)(1) and 951A
(see instructions)
4. Dividends
(see instructions) 5. Interest
(a) Exclude Gross-Up (b) Gross-Up (section 78) (a)
Exclude Gross-Up (b) Gross-Up (section 78)
A
B
C
Totals (add lines A through C) . . . . . . . ▶
6. Gross Rents, Royalties,
and License Fees
7. Sales
3. 8. Gross Income From
Performance of Services
9. Section 986(c) Gain 10. Section 987 Gain 11. Section 988
Gain
12. Other
(attach schedule)
A
B
C
Totals
13. Total
(add columns 3(a)
through 12)
14. Allocable Deductions
(a) Dividends
Received Deduction
(see instructions)
(b) Deduction Allowed Under
Section 250(a)(1)(A)—Foreign
Derived Intangible Income
(c) Deduction Allowed Under
Section 250(a)(1)(B)—Global
Intangible Low-Taxed Income
4. Rental, Royalty, and Licensing Expenses
(d) Depreciation, Depletion,
and Amortization
(e) Other Allocable
Expenses
(f) Expenses Allocable
to Sales Income
A
B
C
Totals
14. Allocable Deductions (continued)
(g) Expenses Allocable
to Gross Income From
Performance of Services
(h) Other Allocable
Deductions (attach schedule)
(see instructions)
(i) Total Allocable Deductions
(add columns 14(a)
through 14(h))
5. 15. Apportioned
Share of Deductions
(enter amount from
applicable line of Schedule H,
Part II, column (d))
16. Net Operating
Loss Deduction
17. Total Deductions
(add columns 14(i)
through 16)
18. Total Income or (Loss)
Before Adjustments
(subtract column 17
from column 13)
A
B
C
Totals
* For section 863(b) income, NOLs, income from RICs, high-
taxed income, section 965, section 951A, and reattribution of
income by reason of disregarded payments, use a single line
(see instructions).
Also, for reporting branches that are QBUs, use a separate line
for each such branch.
For Paperwork Reduction Act Notice, see separate instructions.
6. Cat. No. 10900F Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 2
Schedule B Foreign Tax Credit (Report all foreign tax amounts
in U.S. dollars.)
Part I—Foreign Taxes Paid, Accrued, and Deemed Paid (see
instructions)
1. Credit Is Claimed for Taxes
(check one):
Paid Accrued
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used)
Tax Withheld at Source on:
(a) Dividends
(b) Distributions of
Previously Taxed Earnings
and Profits
(c) Branch Remittances (d) Interest
(e) Rents, Royalties,
and License Fees
(f) Other
Date Paid Date Accrued
A
7. B
C
Totals (add lines A through C) . ▶
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used)
Other Foreign Taxes Paid or Accrued on:
(g) Sales (h) Services Income (i) Other
(j) Total Foreign Taxes Paid or Accrued
(add columns 2(a) through 2(i))
3. Tax Deemed Paid
(see instructions)
A
B
C
Totals
Part II—Separate Foreign Tax Credit (Complete a separate Part
II for each applicable category of income.)
1a Total foreign taxes paid or accrued (total from Part I, column
2(j)) . . . . . . . . . . . . . . . . . . . . . . .
b
Foreign taxes paid or accrued by the corporation during prior
tax years that were suspended due to the rules of section 909
and for
which the related income is taken into account by the
8. corporation during the current tax year (see instructions) . . . . .
. . .
2 Total taxes deemed paid (total from Part I, column 3) . . . . . .
. . . . . . . . . . . . . . . . . . . . .
3 Reductions of taxes paid, accrued, or deemed paid (enter total
from Schedule G) . . . . . . . . . . . . . . . . . . ( )
4 Taxes reclassified under high-tax kickout . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . .
5
Enter the sum of any carryover of foreign taxes (from Schedule
K, line 3, column (xiv), and from Schedule I, Part III, line 3)
plus any
carrybacks to the current tax year . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .
6 Total foreign taxes (combine lines 1a through 5) . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . . . . .
7
Enter the amount from the applicable column of Schedule J,
Part I, line 11 (see instructions). If Schedule J is not required to
be completed, enter the
result from the “Totals” line of column 18 of the applicable
Schedule A . . . . . . . . . . . . . . . . . . . . . . . . . . .
8a Total taxable income from all sources (enter taxable income
from the corporation’s tax return) . . . . . . . . . . . . . .
b Adjustments to line 8a (see instructions) . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . .
c Subtract line 8b from line 8a . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . .
9. 9 Divide line 7 by line 8c. Enter the resulting fraction as a
decimal (see instructions). If line 7 is greater than line 8c, enter
1 . . . . . . . . . . .
10 Total U.S. income tax against which credit is allowed
(regular tax liability (see section 26(b)) minus any American
Samoa economic development credit)
11 Multiply line 9 by line 10 . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . .
12 Increase in limitation (section 960(c)) . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . . .
13 Credit limitation (add lines 11 and 12) (see instructions) . . .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14 Separate foreign tax credit (enter the smaller of line 6 or line
13). Enter here and on the appropriate line of Part III . . . . . . . .
. . . . ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 3
Schedule B Foreign Tax Credit (continued) (Report all foreign
tax amounts in U.S. dollars.)
Part III—Summary of Separate Credits (Enter amounts from
Part II, line 14 for each applicable category of income. Do not
include taxes paid to sanctioned countries.)
1 Credit for taxes on section 951A category income . . . . . . . . .
. . . . . . . . . . . . . . . . . . .
2 Credit for taxes on foreign branch category income . . . . . . . .
. . . . . . . . . . . . . . . . . . . .
3 Credit for taxes on passive category income . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . .
4 Credit for taxes on general category income . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . .
5 Credit for taxes on section 901(j) category income (combine
10. all such credits on this line) . . . . . . . . . . . . . . . .
6 Credit for taxes on income re-sourced by treaty (combine all
such credits on this line) . . . . . . . . . . . . . . . .
7 Total (add lines 1 through 6) . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . .
8 Reduction in credit for international boycott operations (see
instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . .
9 Total foreign tax credit (subtract line 8 from line 7). Enter
here and on the appropriate line of the corporation’s tax return .
. . . . . . . . ▶
Schedule C Tax Deemed Paid With Respect to Section 951(a)(1)
Inclusions by Domestic Corporation Filing Return (Section
960(a))
Use this schedule to report the tax deemed paid by the
corporation with respect to section 951(a)(1) inclusions of
earnings from foreign corporations under
section 960(a). For each line in Schedule C, include the column
10 amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying
number specified in column 1 of Schedule A and that also
corresponds with the identifying number entered in column 1b
of this Schedule C (see
instructions).
1a. Name of Foreign Corporation
1b. EIN or
Reference ID
Number of the
Foreign Corporation
(see instructions)
11. 1c. QBU Reference
ID (if applicable)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation (enter
country code—see
instructions)
4. Functional Currency
of Foreign Corporation
(enter code - see
instructions)
5. Subpart F Income Group
(a) Reg. sec. 1.960-1(d)
(2)(ii)(B)(2)(enter code)
(b) Reg. sec. 1.904-4(c)
(3)(i)-(iv) (enter code)
(c) Unit
6. Total Net Income in Subpart F
Income Group (in functional currency
of foreign corporation)
12. 7. Total Current Year Taxes in
Subpart F Income Group
(in U.S. Dollars)
8. Section 951(a)(1) Inclusion Attributable to Subpart F Income
Group
(a) Functional Currency (b) U.S. Dollars
9. Divide column 8(a) by column 6
10. Tax Deemed Paid (multiply
column 7 by column 9)
Total (add amounts in column 10) . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 4
Schedule D Tax Deemed Paid With Respect to Section 951A
Income by Domestic Corporation Filing the Return (Section
960(d))
Use this schedule to figure the tax deemed paid by the
corporation with respect to section 951A inclusions of earnings
from foreign corporations under
section 960(d).
Part I—Foreign Corporation’s Tested Income and Foreign Taxes
1a. Name of Foreign Corporation
13. 1b. EIN or
Reference ID
Number of the
Foreign Corporation
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation (enter
country code—
see instructions)
4. Functional
Currency of Foreign
Corporation
(enter code)
5. Pro rata share of
CFC’s tested
income from
applicable Form
8992 schedule
(see instructions)
6. CFC’s tested
14. income from
applicable Form
8992 schedule
(see instructions)
7. Divide column 5
by column 6
8. CFC’s tested
foreign income
taxes from
Schedule Q
(Form 5471)
(see instructions)
9. Pro rata share of
tested foreign
income taxes paid
or accrued by CFC
(Multiply amount in
column 7 by amount
in column 8)
Total (add amounts in column 5) . . . . . . . . . . . . . . . . . . . . ▶
Total (add amounts in column 9) . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . ▶
Part II—Foreign Income Tax Deemed Paid
1. Global Intangible Low-Taxed Income
(Section 951A Inclusion)
15. 2. Inclusion Percentage.
Divide Part II, Column 1, by
Part I, Column 5 Total
3. Multiply Part I, Column 9 Total, by
Part II, Column 2 Percentage
4. Tax Deemed Paid
(Multiply Part II, column 3, by 80%.
Enter the result here and include on the line of
Schedule B, Part I, column 3 that corresponds with the
line with “951A” in column 2 of Schedule A.)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 5
Schedule E Tax Deemed Paid With Respect to Previously Taxed
Earnings and Profits (PTEP) by Domestic Corporation Filing the
Return
(Section 960(b))
Part I—Tax Deemed Paid by Domestic Corporation
Use this part to report the tax deemed paid by the domestic
corporation with respect to distributions of PTEP from first-tier
foreign corporations under section 960(b). For each line in
Schedule E, Part I, include the column 11 amount in column 3
of the line in Schedule B, Part I that corresponds with the
identifying number specified in column 1 of Schedule A and
that also corresponds with the identifying number specified in
16. column 1b of this Schedule E, Part I (see instructions).
1a. Name of
Distributing Foreign
Corporation
1b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see
instructions)
2. Tax Year End
(Year/Month)
(see
instructions)
3. Country of
Incorporation
(enter country
code—
see
instructions)
4. Functional
Currency of the
17. Distributing
Foreign
Corporation
5. PTEP Group
(enter code)
6. Annual PTEP
account
(enter year)
7. Total amount of
PTEP in the
PTEP Group
8. Total amount of
the PTEP group
taxes with respect
to PTEP group
9. Distribution from
the PTEP Group
10. Divide column 9
by column 7
11. Foreign income
taxes properly
attributable to PTEP
and not previously
deemed paid
18. (multiply column 8
by column 10)
Total (add amounts in column 11) . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . . . . . ▶
Part II—Tax Deemed Paid by First- and Lower-Tier Foreign
Corporations
Use this part to report the tax deemed paid by a foreign
corporation with respect to distributions of PTEP from lower-
tier foreign corporations under section 960(b) that relate to
distributions reported in Part I (see instructions).
1a. Name of Distributing Foreign Corporation
1b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see
instructions)
2. Tax Year End
(Year/Month)
(see
instructions)
3. Country of
Incorporation
(enter country
19. code—see
instructions)
4a. Name of Recipient
Foreign Corporation
4b. EIN or
Reference ID
Number of the
Foreign
Corporation
(see
instructions)
5. Tax Year End
(Year/Month)
(see
instructions)
6. Country of
Incorporation
(enter country
code—see
instructions)
7. Functional Currency of the
Distributing Foreign
Corporation
8. PTEP Group (enter code)
20. 9. Annual PTEP account
(enter year)
10. Total Amount of
PTEP in the PTEP
Group
11. Total Amount of the
PTEP group taxes with
respect to PTEP group
12. PTEP Distributed
13. Divide column 12 by
column 10
14. Foreign income taxes
properly attributable to PTEP
and not previously deemed
paid (multiply column 11 by
column 13)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 6
Schedule F-1 Tax Deemed Paid by Domestic Corporation Filing
Return—Pre-2018 Tax Years of Foreign Corporations
Use this schedule to figure the tax deemed paid by the
corporation with respect to dividends from a first-tier foreign
corporation under section 902(a), and
21. deemed inclusions of earnings from a first- or lower-tier foreign
corporation under section 960(a). Report all amounts in U.S.
dollars unless otherwise
specified.
IMPORTANT: Applicable to dividends or inclusions from
tax years of foreign corporations beginning on or before
December 31, 2017.
If taxpayer does not have such a dividend or inclusion, do not
complete Schedule F-1 (see instructions).
Part I—Dividends and Deemed Inclusions From Post-1986
Undistributed Earnings
For each line in Schedule F-1, Part I, include the column 12
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying number specified in column 1
of Schedule A and that also corresponds with the identifying
number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)
of the
Foreign
Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
22. (see instructions)
3. Country of
Incorporation
(enter country
code—see
instructions)
4. Post-1986
Undistributed Earnings
(in functional currency)
(attach schedule)
5. Opening Balance
in Post-1986 Foreign
Income Taxes
6. Foreign Taxes Paid and Deemed
Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid
(see instructions)
7. Post-1986 Foreign
Income Taxes
(add columns 5, 6(a), and 6(b))
8. Dividends and Deemed Inclusions
23. (a) Functional
Currency (b) U.S. Dollars
9. Divide Column 8(a)
by Column 4
10. Multiply Column 7
by Column 9
11. Section 960(c) Limitation
12. Tax Deemed Paid
(subtract column 11
from column 10)
Total (add amounts in column 12) . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . . ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 7
Schedule F-1 Tax Deemed Paid by Domestic Corporation Filing
Return—Pre-2018 Tax Years of Foreign Corporations
(continued)
IMPORTANT: Applicable to dividends or inclusions from
tax years of foreign corporations beginning on or before
December 31, 2017.
If taxpayer does not have such a dividend or inclusion, do not
complete Schedule F-1 (see instructions).
Part II—Dividends Paid Out of Pre-1987 Accumulated Profits
For each line in Schedule F-1, Part II, include the column 8(b)
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying number specified in column
24. 1 of Schedule A and that also corresponds with the identifying
number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)
of the
Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of Incorporation
(enter country code—
see instructions)
4. Accumulated Profits
for Tax Year Indicated
(in functional currency computed
under section 902) (attach schedule)
5. Foreign Taxes Paid and Deemed
Paid on Earnings and Profits (E&P)
25. for Tax Year Indicated
(in functional currency)
(see instructions)
6. Dividends Paid
(a) Functional Currency (b) U.S. Dollars
7. Divide Column 6(a)
by Column 4
8. Tax Deemed Paid (see instructions)
(a) Functional Currency (b) U.S. Dollars
Total (add amounts in column 8b) . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . ▶
Part III—Deemed Inclusions From Pre-1987 Earnings and
Profits
For each line in Schedule F-1, Part III, include the column 8
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying number specified in column 1
of Schedule A and that also corresponds with the identifying
number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)
of the
Foreign Corporation
26. 1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of Incorporation
(enter country code—
see instructions)
4. E&P for Tax Year Indicated
(in functional currency
translated from U.S. dollars, computed under
section 964) (attach schedule)
5. Foreign Taxes Paid and
Deemed Paid for Tax Year Indicated
(see instructions)
6. Deemed Inclusions
(a) Functional Currency (b) U.S. Dollars
7. Divide Column 6(a)
by Column 4
8. Tax Deemed Paid
(multiply column 5 by column 7)
27. Total (add amounts in column 8) . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 8
Schedule F-2 Tax Deemed Paid by First- and Second-Tier
Foreign Corporations Under Section 902(b)—Pre-2018 Tax
Years of Foreign
Corporations
Use Part I to compute the tax deemed paid by a first-tier foreign
corporation with respect to dividends from a second-tier foreign
corporation. Use Part II to
compute the tax deemed paid by a second-tier foreign
corporation with respect to dividends from a third-tier foreign
corporation. Report all amounts in U.S.
dollars unless otherwise specified.
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete
Schedule F-2 (see instructions).
Part I—Tax Deemed Paid by First-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed
Earnings (Include the column 10 results in Schedule F-1, Part I,
column 6(b).)
1a. Name of Second-Tier Foreign Corporation
and Its Related First-Tier Foreign Corporation
28. 1b. EIN (if any)
of the Second-Tier
Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Accumulated Profits
for Tax Year Indicated
(in functional currency—
see instructions)
5. Opening Balance
Post-1986 Foreign
Income Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid
29. (see instructions)
7. Post-1986 Foreign
Income Taxes
(add columns 5, 6(a), and 6(b))
8. Dividends Paid (in functional currency)
(a) of Second-Tier Corporation (b) of First-Tier Corporation
9. Divide Column 8(a)
by Column 4
10. Tax Deemed Paid
(multiply column 7
by column 9)
Section B—Dividends Paid Out of Pre-1987 Accumulated
Profits (Include the column 8(b) results in Schedule F-1, Part I,
column 6(b).)
1a. Name of Second-Tier Foreign Corporation
and Its Related First-Tier Foreign Corporation
1b. EIN (if any)
of the Second-Tier
Foreign Corporation
1c. Reference ID
Number
(see instructions)
30. 2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Accumulated Profits
for Tax Year Indicated
(in functional currency—
attach schedule)
5. Foreign Taxes Paid and
Deemed Paid for Tax Year Indicated
(in functional currency—
see instructions)
6. Dividends Paid
(in functional currency)
(a) of Second-Tier Corporation (b) of First-Tier Corporation
7. Divide Column 6(a)
by Column 4
8. Tax Deemed Paid
(see instructions)
(a) Functional Currency
31. of Second-Tier Corporation
(b) U.S. Dollars
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 9
Schedule F-2 Tax Deemed Paid by First- and Second-Tier
Foreign Corporations Under Section 902(b)—Pre-2018 Tax
Years of Foreign
Corporations (continued)
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete
Schedule F-2 (see instructions).
Part II—Dividends Deemed Paid by Second-Tier Foreign
Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed
Earnings (In general, include the column 10 results in Section
A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b), for an exception.)
1a. Name of Third-Tier Foreign Corporation
and Its Related Second-Tier Foreign Corporation
1b. EIN (if any)
of the Third-Tier
Foreign Corporation
32. 1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Post-1986
Undistributed Earnings
(in functional currency—
attach schedule)
5. Opening Balance in
Post-1986 Foreign
Income Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid (from
Schedule F-3, Part I, column 10)
7. Post-1986 Foreign
Income Taxes
33. (add columns 5, 6(a), and 6(b))
8. Dividends Paid
(in functional currency)
(a) of Third-Tier Corporation (b) of Second-Tier Corporation
9. Divide Column 8(a)
by Column 4
10. Tax Deemed Paid
(multiply column 7
by column 9)
Section B—Dividends Paid Out of Pre-1987 Accumulated
Profits (In general, include the column 8(b) results in Section
A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b) for an exception.)
1a. Name of Third-Tier Foreign Corporation
and Its Related Second-Tier Foreign Corporation
1b. EIN (if any)
of the Third-Tier
Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
34. (Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Accumulated Profits
for Tax Year Indicated
(in functional currency—
attach schedule)
5. Foreign Taxes Paid and
Deemed Paid for Tax Year Indicated
(in functional currency—
see instructions)
6. Dividends Paid
(in functional currency)
(a) of Third-Tier Corporation (b) of Second-Tier Corporation
7. Divide Column 6(a)
by Column 4
8. Tax Deemed Paid
(see instructions)
(a) Functional Currency
of Third-Tier Corporation
35. (b) U.S. Dollars
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 10
Schedule F-3 Tax Deemed Paid by Certain Third-, Fourth-, and
Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-
2018 Tax Years of
Foreign Corporations
Use this schedule to report taxes deemed paid with respect to
dividends from eligible post-1986 undistributed earnings of
fourth-, fifth-, and sixth-tier
controlled foreign corporations. Report all amounts in U.S.
dollars unless otherwise specified.
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete
Schedule F-3 (see instructions).
Part I—Tax Deemed Paid by Third-Tier Foreign Corporations
(In general, include the column 10 results in Schedule F-2, Part
II, Section A, column 6(b). However, see
instructions for Schedule F-1, Part I, column 6(b), for an
exception.)
1a. Name of Fourth-Tier Foreign Corporation
and Its Related Third-Tier Foreign Corporation
1b. EIN (if any)
of the Fourth-Tier
36. Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Post-1986
Undistributed Earnings
(in functional currency—
attach schedule)
5. Opening Balance in
Post-1986 Foreign
Income Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid
(from Part II, column 10)
37. 7. Post-1986 Foreign
Income Taxes
(add columns 5, 6(a), and 6(b))
8. Dividends Paid
(in functional currency)
(a) of Fourth-Tier CFC (b) of Third-Tier CFC
9. Divide Column 8(a)
by Column 4
10. Tax Deemed Paid
(multiply column 7
by column 9)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 11
Schedule F-3 Tax Deemed Paid by Certain Third-, Fourth-, and
Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-
2018 Tax Years of
Foreign Corporations (continued)
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31, 2017.
If taxpayer does not have such a dividend, do not complete
Schedule F-3 (see instructions).
Part II—Tax Deemed Paid by Fourth-Tier Foreign Corporations
38. (In general, include the column 10 results in column 6(b) of
Part I. However, see instructions for Schedule F-1,
Part I, column 6(b), for an exception.)
1a. Name of Fifth-Tier Foreign Corporation
and Its Related Fourth-Tier Foreign Corporation
1b. EIN (if any)
of the Fifth-Tier
Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Post-1986
Undistributed Earnings
(in functional currency—
attach schedule)
5. Opening Balance in
Post-1986 Foreign
39. Income Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid
(from Part III, column 10)
7. Post-1986 Foreign
Income Taxes
(add columns 5, 6(a), and 6(b))
8. Dividends Paid
(in functional currency)
(a) of Fifth-Tier CFC (b) of Fourth-Tier CFC
9. Divide Column 8(a)
by Column 4
10. Tax Deemed Paid
(multiply column 7
by column 9)
Part III—Tax Deemed Paid by Fifth-Tier Foreign Corporations
(In general, include the column 10 results in column 6(b) of
Part II, above. However, see instructions for Schedule
F-1, Part I, column 6(b), for an exception.)
1a. Name of Sixth-Tier Foreign Corporation
and Its Related Fifth-Tier Foreign Corporation
40. 1b. EIN (if any)
of the Sixth-Tier
Foreign Corporation
1c. Reference ID
Number
(see instructions)
2. Tax Year End
(Year/Month)
(see instructions)
3. Country of
Incorporation
(enter country code—
see instructions)
4. Post-1986
Undistributed Earnings
(in functional currency—
attach schedule)
5. Opening Balance in
Post-1986 Foreign
Income Taxes
6. Foreign Taxes Paid
for Tax Year Indicated
7. Post-1986 Foreign
41. Income Taxes
(add columns 5 and 6)
8. Dividends Paid
(in functional currency)
(a) of Sixth-Tier CFC (b) of Fifth-Tier CFC
9. Divide Column 8(a)
by Column 4
10. Tax Deemed Paid
(multiply column 7
by column 9)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 12
Schedule G Reductions of Taxes Paid, Accrued, or Deemed Paid
Part I—Reduction Amounts
A Reduction of Taxes Under Section 901(e)—Attach separate
schedule . . . . . . . . . . . . . . . . . . . . . . . . .
B Reduction of Foreign Oil and Gas Taxes—Enter amount from
Schedule I, Part II, line 4 . . . . . . . . . . . . . . . . . . .
C
42. Reduction of Taxes Due to International Boycott Provisions—
Enter appropriate portion from Schedule C (Form 5713) (see
instructions).
Important: Enter only “specifically attributable taxes” here . . . .
. . . . . . . . . . . . . . . . . . . . . . . . .
D Reduction of Taxes for Section 6038(c) Penalty—Attach
separate schedule . . . . . . . . . . . . . . . . . . . . . . .
E Taxes suspended under section 909 . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . . . . . .
F
Other Reductions of Taxes . . . . . . . . . . . . . . . . . . . . . . . . . . .
. . . . . . . . . . . .
1. Enter code—see instructions ▶
2. If more than one code is entered on line F1 or if code OTH is
entered on line F1, attach schedule (see instructions).
Total (add lines A through F). Enter here and on Schedule B,
Part II, line 3 . . . . . . . . . . . . . . . . . . . . . . . . . ▶
Part II—Other Information
G Check this box if, during the tax year, the corporation paid or
accrued any foreign tax that was disqualified for credit under
section 901(m) . . . . . . . . . ▶
H Check this box if, during the tax year, the corporation paid or
accrued any foreign tax that was disqualified for credit under
section 901(j), (k), or (l) . . . . . . . ▶
Form 1118 (Rev. 12-2020)
43. Form 1118 (Rev. 12-2020) Page 13
Schedule H Apportionment of Certain Deductions (Complete
only once for all categories of income.)
Part I—Research and Experimental Deductions
(a) Sales Method
Product Line #1 (SIC Code: )
(i) Gross Sales
(ii) R&E
Deductions
Product Line #2 (SIC Code: )
(iii) Gross Sales
(iv) R&E
Deductions
(b) Gross Income Method—Check method used: Option 1
Option 2
Product Line #1 (SIC Code: )
(v) Gross Income
(vi) R&E
Deductions
Product Line #2 (SIC Code: )
44. (vii) Gross Income
(viii) R&E
Deductions
(c) Total R&E
Deductions
(enter the sum of all
amounts entered in all
applicable “R&E
Deductions” columns)
1 Totals (see instructions)
2 Total to be apportioned
3
Apportionment among
statutory groupings
(see instructions):
a Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line a . . .
b Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line b . . .
c Enter Code
45. (1) Section 245A dividend
(2) Other . . . . .
(3) Total line c . . .
d Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line d . . .
e Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line e . . .
f Enter Code
(1) Section 245A dividend
(2) Other . . . . .
(3) Total line f . . .
4
Total foreign (add lines
3a(3), 3b(3), 3c(3), 3d(3),
3e(3), and 3f(3)) . . ▶
Important: See Computer-Generated Schedule H in instructions.
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020) Page 14
Schedule H Apportionment of Certain Deductions (Complete
only once for all categories of income.) (continued)
46. Part II—Interest Deductions, All Other Deductions, and Total
Deductions
(a) Average Value of Assets—
Check method used:
Tax book value
Alternative tax book value
(i) Nonfinancial
Corporations
(ii) Financial
Corporations
(b) Interest Deductions
(iii) Nonfinancial
Corporations
(iv) Financial
Corporations
(c) All Other
Deductions
(attach schedule)
(see instructions)
(d) Totals
(add the
corresponding
amounts from
column (c), Part I;
47. columns (b)(iii) and
(b)(iv), Part II; and
column (c), Part II)
Additional note:
Be sure to also enter
the totals from lines
3a(2), 3b(2), 3c(2),
3d(2), 3e(2), and 3f(2)
below in column 15
of the corresponding
Schedule A.
1a Totals (see instructions) . . . . . . . . . . . . .
b
Amounts specifically allocable under Temporary Regulations
section 1.861-10T(e) . . . . . . . . . . . . . .
c Other specific allocations under Temporary Regulations
section 1.861-10T
d Assets excluded from apportionment formula . . . . . .
2
Total to be apportioned (subtract the sum of lines 1b, 1c, and
1d from line 1a) . . . . . . . . . . . . . . . .
3 Apportionment among statutory groupings (see instructions):
a Enter Code
49. Expenses Allocated and Apportioned to Foreign Source Section
245A Dividend. Enter the sum of lines 3a(1), 3b(1), 3c(1),
3d(1), 3e(1), and 3f(1). Include the
column (d) result as a negative amount on Schedule B, Part II,
line 8b . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6 Enter expenses allocated and apportioned to U.S. source
section 245A dividend. Include the column (d) result as a
negative amount on Schedule B, Part II, line 8b
Important: See Computer-Generated Schedule H in instructions.
Form 1118 (Rev. 12-2020)
Version A, Cycle 9
INTERNAL USE ONLY
DRAFT AS OF
November 4, 2020
Form 1118 (Rev. December 2020)
SE:W:CAR:MP
Foreign Tax Credit—Corporations
Form 1118
(Rev. December 2020)
Rev. December 2020. Cat. No. 10900F
Department of the Treasury
Internal Revenue Service
Foreign Tax Credit—Corporations
▶ Attach to the corporation’s tax return.▶ Go
to www.irs.gov/Form1118 for instructions and the latest
information.
OMB No. 1545-0123
Attachment
Sequence No. 118
Attachment Sequence No. 118. For Paperwork Reduction Act
Notice, see separate instructions.
50. Use a separate Form 1118 for each applicable category of
income (see instructions).
a
Separate Category (Enter code—see instructions.) ▶
b
If code 901j is entered on line a, enter the country code for the
sanctioned country (see instructions) ▶
c
If one of the RBT codes is entered on line a, enter the country
code for the treaty country (see instructions) ▶
Schedule A
Income or (Loss) Before Adjustments (Report all amounts in
U.S. dollars. See Specific Instructions.)
1. EIN or Reference IDNumber(see instructions)*
2. Foreign Country or
U.S. Possession(enter two-letter code—usea separate line for
each)(see instructions)
Gross Income or (Loss) From Sources Outside the United States
3. Inclusions Under Sections 951(a)(1) and 951A(see
instructions)
4. Dividends(see instructions)
5. Interest
1. E I N or Reference I D Number (see instructions)*. *For
section 863(b) income, N O L s, income from R I C s, high-
taxed income, section 965, and section 951A, use a single line
(see instructions).
2. Foreign Country or U.S. Possession (enter two-letter code—
use a separate line for each) (see instructions).
(a) Exclude Gross-Up
Gross Income or (Loss) From Sources Outside the United
States. 3. Inclusions Under Sections 951(a)(1) and 951A (see
instructions). (a) Exclude Gross-Up.
(b) Gross-Up (section 78)
Gross Income or (Loss) From Sources Outside the United
States. 3. Inclusions Under Sections 951(a)(1) and 951A (see
instructions). (b) Gross-Up (section 78).
51. (a) Exclude Gross-Up
Gross Income or (Loss) From Sources Outside the United
States. 4. Dividends (see instructions). (a) Exclude Gross-Up.
(b) Gross-Up (section 78)
Gross Income or (Loss) From Sources Outside the United
States. 4. Dividends (see instructions). (b) Gross-Up (section
78).
Gross Income or (Loss) From Sources Outside the United
States. 5. Interest.
A
B
C
Totals (add lines A through C) ▶
6. Gross Rents, Royalties,and License Fees
7. Sales
8. Gross Income From Performance of Services
9. Section 986(c) Gain
10. Section 987 Gain
11. Section 988 Gain
12. Other(attach schedule)
A
B
C
Totals
13. Total(add columns 3(a)through 12)
14. Allocable Deductions
(a) DividendsReceived Deduction(see instructions)
(b) Deduction Allowed Under Section 250(a)(1)(A)—Foreign
Derived Intangible Income
(c) Deduction Allowed Under Section 250(a)(1)(B)—Global
Intangible Low-Taxed Income
Rental, Royalty, and Licensing Expenses
(d) Depreciation, Depletion,and Amortization
(e) Other AllocableExpenses
(f) Expenses Allocableto Sales Income
13. Total (add columns 3(a) through 12).
52. 14. Allocable Deductions. (a) Dividends Received Deduction
(see instructions).
14. Allocable Deductions. (b) Deduction Allowed Under Section
250(a)(1)(A)—Foreign Derived Intangible Income.
14. Allocable Deductions. (c) Deduction Allowed Under Section
250(a)(1)(B)—Global Intangible Low-Taxed Income.
14. Allocable Deductions. Rental, Royalty, and Licensing
Expenses. (d) Depreciation, Depletion, and Amortization.
14. Allocable Deductions. Rental, Royalty, and Licensing
Expenses. (e) Other Allocable Expenses.
14. Allocable Deductions. (f) Expenses Allocable to Sales
Income.
A
B
C
Totals
14. Allocable Deductions (continued)
(g) Expenses Allocableto Gross Income From Performance of
Services
(h) Other AllocableDeductions (attach schedule) (see
instructions)
(i) Total Allocable Deductions(add columns 14(a)through 14(h))
15. ApportionedShare of Deductions(enter amount
fromapplicable line of Schedule H, Part II, column (d))
16. Net OperatingLoss Deduction
17. Total Deductions(add columns 14(i)through 16)
18. Total Income or (Loss)Before Adjustments(subtract column
17from column 13)
14. Allocable Deductions (continued). (g) Expenses Allocable
to Gross Income From Performance of Services.
14. Allocable Deductions (continued). (h) Other Allocable
Deductions.
14. Allocable Deductions (continued). (i) Total Allocable
Deductions (add columns 14(a) through 14(h)).
15. Apportioned Share of Deductions (enter amount from
applicable line of Schedule H, Part II, column (d)).
53. 16. Net Operating Loss Deduction.
17. Total Deductions (add columns 14(i) through 16).
18. Total Income or (Loss) Before Adjustments (subtract
column 17 from column 13).
A
B
C
Totals
* For section 863(b) income, NOLs, income from RICs, high-
taxed income, section 965, section 951A, and reattribution of
income by reason of disregarded payments, use a single line
(see instructions). Also, for reporting branches that are QBUs,
use a separate line for each such branch.
For Paperwork Reduction Act Notice, see separate instructions.
Cat. No. 10900F
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 2
Schedule B
Foreign Tax Credit (Report all foreign tax amounts in U.S.
dollars.)
Part I—Foreign Taxes Paid, Accrued, and Deemed Paid (see
instructions)
1. Credit Is Claimed for Taxes (check one):
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used)
(a) Dividends
(b) Distributions ofPreviously Taxed Earnings and Profits
(c) Branch Remittances
(d) Interest
(e) Rents, Royalties,and License Fees
(f) Other
Date Paid
1. Credit is Claimed for Taxes: Paid. Date Paid.
Date Accrued
1. Credit is Claimed for Taxes: Accrued. Date Accrued.
54. 2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (a) Dividends.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (b) Distributions of Previously Taxed
Income Earnings and Profits.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (c) Branch Remittances.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (d) Interest.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (e) Rents, Royalties, and License Fees.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Tax
Withheld at Source on: (f) Other.
A
B
C
Totals (add lines A through C) ▶
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used)
(g) Sales
(h) Services Income
(i) Other
(j) Total Foreign Taxes Paid or Accrued(add columns 2(a)
through 2(i))
3. Tax Deemed Paid(see instructions)
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Other
Foreign Taxes Paid or Accrued on: (g) Sales.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Other
55. Foreign Taxes Paid or Accrued on: (h) Services Income.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). Other
Foreign Taxes Paid or Accrued on: (i) Other.
2. Foreign Taxes Paid or Accrued (attach schedule showing
amounts in foreign currency and conversion rate(s) used). (j)
Total Foreign Taxes Paid or Accrued (add columns 2(a) through
2(i)).
3. Tax Deemed Paid (see instructions).
A
B
C
Totals
Part II—Separate Foreign Tax Credit (Complete a separate Part
II for each applicable category of income.)
1
a
Total foreign taxes paid or accrued (total from Part I, column
2(j))
b
Foreign taxes paid or accrued by the corporation during prior
tax years that were suspended due to the rules of section 909
and for which the related income is taken into account by the
corporation during the current tax year (see instructions)
2
Total taxes deemed paid (total from Part I, column 3)
3
Reductions of taxes paid, accrued, or deemed paid (enter total
from Schedule G)
( )
4
Taxes reclassified under high-tax kickout
5
Enter the sum of any carryover of foreign taxes (from Schedule
56. K, line 3, column (xiv), and from Schedule I, Part III, line 3)
plus any carrybacks to the current tax year
6
Total foreign taxes (combine lines 1a through 5)
7
Enter the amount from the applicable column of Schedule J,
Part I, line 11 (see instructions). If Schedule J is not required to
be completed, enter the result from the “Totals” line of column
18 of the applicable Schedule A
8
a
Total taxable income from all sources (enter taxable income
from the corporation’s tax return)
b
Adjustments to line 8a (see instructions)
c
Subtract line 8b from line 8a
9
Divide line 7 by line 8c. Enter the resulting fraction as a
decimal (see instructions). If line 7 is greater than line 8c, enter
1
10
Total U.S. income tax against which credit is allowed (regular
tax liability (see section 26(b)) minus any American Samoa
economic development credit)
11
Multiply line 9 by line 10
12
Increase in limitation (section 960(c))
13
Credit limitation (add lines 11 and 12) (see instructions)
14
Separate foreign tax credit (enter the smaller of line 6 or line
13). Enter here and on the appropriate line of Part III ▶
Form 1118 (Rev. 12-2020)
57. Form 1118 (Rev. 12-2020)
Page 3
Schedule B
Foreign Tax Credit (continued) (Report all foreign tax amounts
in U.S. dollars.)
Part III—Summary of Separate Credits (Enter amounts from
Part II, line 14 for each applicable category of income. Do not
include taxes paid to sanctioned countries.)
1
Credit for taxes on section 951A category income
2
Credit for taxes on foreign branch category income
3
Credit for taxes on passive category income
4
Credit for taxes on general category income
5
Credit for taxes on section 901(j) category income (combine all
such credits on this line)
6
Credit for taxes on income re-sourced by treaty (combine all
such credits on this line)
7
Total (add lines 1 through 6)
8
Reduction in credit for international boycott operations (see
instructions)
9
Total foreign tax credit (subtract line 8 from line 7). Enter here
and on the appropriate line of the corporation’s tax return
▶
Schedule C
Tax Deemed Paid With Respect to Section 951(a)(1) Inclusions
by Domestic Corporation Filing Return (Section 960(a))
Use this schedule to report the tax deemed paid by the
corporation with respect to section 951(a)(1) inclusions of
58. earnings from foreign corporations under section 960(a). For
each line in Schedule C, include the column 10 amount in
column 3 of the line in Schedule B, Part I that corresponds with
the identifying number specified in column 1 of Schedule A and
that also corresponds with the identifying number entered in
column 1b of this Schedule C (see instructions).
1a. Name of Foreign Corporation
1b. EIN or Reference ID Number of the Foreign Corporation(see
instructions)
1c. QBU Reference ID (if applicable)
2. Tax Year End (Year/Month) (see instructions)
3. Country of Incorporation (enter country code—
see instructions)
4. Functional Currency of Foreign Corporation (enter code -
see instructions)
5. Subpart F Income Group
(a) Reg. sec. 1.960-1(d)(2)(ii)(B)(2)(enter code)
(b) Reg. sec. 1.904-4(c)(3)(i)-(iv) (enter code)
(c) Unit
1a. Name of Foreign Corporation.
1b. E I N or Reference I D Number of the Foreign Corporation
(see instructions).
1c. Q B U Reference I D (if applicable).
2. Tax Year End (Year/Month) (see instructions).
3. Country of Incorporation (enter country code—see
instructions).
4. Functional Currency of Foreign Corporation (enter code - see
instructions).
5. Subpart F Income Group. (a) Reg. sec. 1.960-1(d)(2)(i
i)(B)(2)(enter code).
5. Subpart F Income Group. (b) Reg. sec. 1.904-4(c)(3)(i)-(i v)
(enter code).
5. Subpart F Income Group. (c) Unit.
6. Total Net Income in Subpart F Income Group (in functional
currency of foreign corporation)
7. Total Current Year Taxes in Subpart F Income
59. Group (in U.S. Dollars)
8. Section 951(a)(1) Inclusion Attributable to Subpart F Income
Group
(a) Functional Currency
(b) U.S. Dollars
9. Divide column 8(a) by column 6
10. Tax Deemed Paid (multiply column 7 by column 9)
6. Total Net Income in Subpart F Income Group (in functional
currency of foreign corporation).
7. Total Current Year Taxes in Subpart F Income Group (in U.S.
Dollars).
8. Section 951(a)(1) Inclusion Attributable to Subpart F Income
Group. (a) Functional Currency.
8. Section 951(a)(1) Inclusion Attributable to Subpart F Income
Group. (b) U.S. Dollars.
9. Divide column 8(a) by column 6.
10. Tax Deemed Paid (multiply column 7 by column 9).
Total (add amounts in column 10) ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 4
Schedule D
Tax Deemed Paid With Respect to Section 951A Income by
Domestic Corporation Filing the Return (Section 960(d))
Use this schedule to figure the tax deemed paid by the
corporation with respect to section 951A inclusions of earnings
from foreign corporations under section 960(d).
Part I—Foreign Corporation’s Tested Income and Foreign Taxes
1a. Name of Foreign Corporation
1b. EIN or Reference IDNumber of theForeign Corporation(see
instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country of Incorporation (enter country code—
see instructions)
4. Functional Currency of Foreign Corporation (enter code)
5. Pro rata share of CFC’s tested income from applicable Form
60. 8992 schedule (see instructions)
6. CFC’s tested income from applicable Form 8992 schedule
(see instructions)
7. Divide column 5 by column 6
8. CFC’s tested foreign income taxes from Schedule Q
(Form 5471) (see instructions)
9. Pro rata share of tested foreign income taxes paid or accrued
by CFC (Multiply amount in column 7 by amount in column 8)
Total (add amounts in column 5) ▶
Entry 5. 5.
Entry 5. 5.
Entry 5. 5.
Entry 5. 5.
Total (add amounts in column 9) ▶
Part II—Foreign Income Tax Deemed Paid
1. Global Intangible Low-Taxed Income(Section 951A
Inclusion)
2. Inclusion Percentage.Divide Part II, Column 1, byPart I,
Column 5 Total
3. Multiply Part I, Column 9 Total, byPart II, Column 2
Percentage
4. Tax Deemed Paid(Multiply Part II, column 3, by 80%.Enter
the result here and include on the line of Schedule B, Part I,
column 3 that corresponds with the line with “951A” in column
2 of Schedule A.)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 5
Schedule E
Tax Deemed Paid With Respect to Previously Taxed Earnings
and Profits (PTEP) by Domestic Corporation Filing the Return
(Section 960(b))
Part I—Tax Deemed Paid by Domestic Corporation
Use this part to report the tax deemed paid by the domestic
corporation with respect to distributions of PTEP from first-tier
foreign corporations under section 960(b). For each line in
61. Schedule E, Part I, include the column 11 amount in column 3
of the line in Schedule B, Part I that corresponds with the
identifying number specified in column 1 of Schedule A and
that also corresponds with the identifying number specified in
column 1b of this Schedule E, Part I (see instructions).
1a. Name of Distributing Foreign Corporation
1b. EIN or Reference IDNumber of theForeign Corporation(see
instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country of Incorporation (enter country code—
see instructions)
4. Functional Currency of the Distributing Foreign Corporation
5. PTEP Group (enter code)
6. Annual PTEP account (enter year)
7. Total amount of PTEP in the PTEP Group
8. Total amount of the PTEP group taxes with respect to PTEP
group
9. Distribution from the PTEP Group
10. Divide column 9 by column 7
11. Foreign income taxes properly attributable to PTEP and not
previously deemed paid (multiply column 8 by column 10)
Total (add amounts in column 11) ▶
Part II—Tax Deemed Paid by First- and Lower-Tier Foreign
Corporations
Use this part to report the tax deemed paid by a foreign
corporation with respect to distributions of PTEP from lower -
tier foreign corporations under section 960(b) that relate to
distributions reported in Part I (see instructions).
1a. Name of Distributing Foreign Corporation
1b. EIN or Reference ID Number of the ForeignCorporation(see
instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country of Incorporation (enter country code—
see instructions)
4a. Name of RecipientForeign Corporation
4b. EIN or Reference ID Number of the ForeignCorporation(see
62. instructions)
5. Tax Year End(Year/Month)(see instructions)
6. Country of Incorporation (enter country code—see
instructions)
7. Functional Currency of the Distributing Foreign Corporation
8. PTEP Group (enter code)
9. Annual PTEP account (enter year)
10. Total Amount of PTEP in the PTEP Group
11. Total Amount of the PTEP group taxes with respect to
PTEP group
12. PTEP Distributed
13. Divide column 12 by column 10
14. Foreign income taxes properly attributable to PTEP and not
previously deemed paid (multiply column 11 by column 13)
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 6
Schedule F-1
Tax Deemed Paid by Domestic Corporation Filing Return—Pre-
2018 Tax Years of Foreign Corporations
Use this schedule to figure the tax deemed paid by the
corporation with respect to dividends from a first-tier foreign
corporation under section 902(a), and deemed inclusions of
earnings from a first- or lower-tier foreign corporation under
section 960(a). Report all amounts in U.S. dollars unless
otherwise specified.
IMPORTANT: Applicable to dividends or inclusions from
tax years of foreign corporations beginning on or before
December 31, 2017.If taxpayer does not have such a dividend or
inclusion, do not complete Schedule F-1 (see instructions).
Part I—Dividends and Deemed Inclusions From Post-1986
Undistributed Earnings
For each line in Schedule F-1, Part I, include the column 12
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying number specified in column 1
of Schedule A and that also corresponds with the identifying
63. number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)of theForeignCorporation
1c. Reference ID Number(see instructions)
2. Tax Year End (Year/Month)(see instructions)
3. Country of Incorporation(enter countrycode—
see instructions)
4. Post-1986 Undistributed Earnings (in functional
currency)(attach schedule)
5. Opening Balancein Post-1986 Foreign Income Taxes
6. Foreign Taxes Paid and DeemedPaid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid (see instructions)
1a. Name of Foreign Corporation (identify D I S C's and former
D I S C's).
1b. E I N (if any) of the Foreign Corporation.
1c. Reference I D Number (see instructions).
2. Tax Year End (Year/Month) (see instructions).
3. Country of Incorporation (enter country code—see
instructions).
4. Post-1986 Undistributed Earnings (in functional currency)
(attach schedule).
5. Opening Balance in Post-1986 Foreign Income Taxes.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(a) Taxes Paid.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(b) Taxes Deemed Paid (see instructions).
7. Post-1986 ForeignIncome Taxes(add columns 5, 6(a), and
6(b))
8. Dividends and Deemed Inclusions
(a) FunctionalCurrency
(b) U.S. Dollars
9. Divide Column 8(a)by Column 4
10. Multiply Column 7by Column 9
64. 11. Section 960(c) Limitation
12. Tax Deemed Paid(subtract column 11from column 10)
7. Post-1986 Foreign Income Taxes (add columns 5, 6(a), and
6(b)).
8. Dividends and Deemed Inclusions. (a) Functional Currency.
8. Dividends and Deemed Inclusions. (b) U.S. Dollars.
9. Divide Column 8(a) by Column 4.
10. Multiply Column 7 by Column 9.
11. Section 960(c) Limitation.
12. Tax Deemed Paid (subtract column 11 from column 10).
Total (add amounts in column 12) ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 7
Schedule F-1
Tax Deemed Paid by Domestic Corporation Filing Return—Pre-
2018 Tax Years of Foreign Corporations (continued)
IMPORTANT: Applicable to dividends or inclusions from
tax years of foreign corporations beginning on or before
December 31, 2017.If taxpayer does not have such a dividend or
inclusion, do not complete Schedule F-1 (see instructions).
Part II—Dividends Paid Out of Pre-1987 Accumulated Profits
For each line in Schedule F-1, Part II, include the column 8(b)
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifying number specified in column 1
of Schedule A and that also corresponds with the identifying
number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)of theForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country of Incorporation(enter country code—
see instructions)
4. Accumulated Profitsfor Tax Year Indicated(in functional
65. currency computed under section 902) (attach schedule)
5. Foreign Taxes Paid and Deemed Paid on Earnings and Profits
(E&P)for Tax Year Indicated(in functional currency)(see
instructions)
6. Dividends Paid
(a) Functional Currency
(b) U.S. Dollars
7. Divide Column 6(a)by Column 4
8. Tax Deemed Paid (see instructions)
(a) Functional Currency
(b) U.S. Dollars
5. Foreign Taxes Paid and Deemed Paid on Earnings and Profits
(E&P) for Tax Year Indicated (in functional currency) (see
instructions).
6. Dividends Paid. (a) Functional Currency.
6. Dividends Paid. (b) U.S. Dollars.
7. Divide Column 6(a) by Column 4.
8. Tax Deemed Paid (see instructions). (a) Functional Currency.
8. Tax Deemed Paid (see instructions). (b) U.S. Dollars.
Total (add amounts in column 8b) ▶
Part III—Deemed Inclusions From Pre-1987 Earnings and
Profits
For each line in Schedule F-1, Part III, include the column 8
amount in column 3 of the line in Schedule B, Part I that
corresponds with the identifyi ng number specified in column 1
of Schedule A and that also corresponds with the identifying
number specified in either column 1b or 1c of this Schedule F-
1, Part I (see instructions).
1a. Name of Foreign Corporation
(identify DISCs and former DISCs)
1b. EIN (if any)of theForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country of Incorporation(enter country code—
see instructions)
4. E&P for Tax Year Indicated(in functional currencytranslated
66. from U.S. dollars, computed under section 964) (attach
schedule)
5. Foreign Taxes Paid andDeemed Paid for Tax Year
Indicated(see instructions)
6. Deemed Inclusions
(a) Functional Currency
(b) U.S. Dollars
7. Divide Column 6(a)by Column 4
8. Tax Deemed Paid(multiply column 5 by column 7)
5. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(see instructions).
6. Deemed Inclusions. (a) Functional Currency.
6. Deemed Inclusions. (b) U.S. Dollars.
7. Divide Column 6(a) by Column 4.
8. Tax Deemed Paid (multiply column 5 by column 7).
Total (add amounts in column 8) ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 8
Schedule F-2
Tax Deemed Paid by First- and Second-Tier Foreign
Corporations Under Section 902(b)—Pre-2018 Tax Years of
Foreign Corporations
Use Part I to compute the tax deemed paid by a first-tier foreign
corporation with respect to dividends from a second-tier foreign
corporation. Use Part II to compute the tax deemed paid by a
second-tier foreign corporation with respect to dividends from a
third-tier foreign corporation. Report all amounts in U.S.
dollars unless otherwise specified.
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31,
2017.If taxpayer does not have such a dividend, do not complete
Schedule F-2 (see instructions).
Part I—Tax Deemed Paid by First-Tier Foreign Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed
Earnings (Include the column 10 results in Schedule F-1, Part I,
67. column 6(b).)
1a. Name of Second-Tier Foreign Corporationand Its Related
First-Tier Foreign Corporation
1b. EIN (if any)of the Second-TierForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Accumulated Profitsfor Tax Year Indicated(in functional
currency—see instructions)
5. Opening BalancePost-1986 ForeignIncome Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid(see instructions)
7. Post-1986 ForeignIncome Taxes(add columns 5, 6(a), and
6(b))
8. Dividends Paid (in functional currency)
(a) of Second-Tier Corporation
(b) of First-Tier Corporation
9. Divide Column 8(a)by Column 4
10. Tax Deemed Paid(multiply column 7by column 9)
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(a) Taxes Paid.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(b) Taxes Deemed Paid (see instructions).
7. Post-1986 Foreign Income Taxes (add columns 5, 6(a), and
6(b)).
8. Dividends Paid (in functional currency). (a) of Second-Tier
Corporation.
8. Dividends Paid (in functional currency). (b) of First-Tier
Corporation.
9. Divide Column 8(a) by Column 4.
10. Tax Deemed Paid (multiply column 7 by column 9).
Section B—Dividends Paid Out of Pre-1987 Accumulated
Profits (Include the column 8(b) results in Schedule F-1, Part I,
column 6(b).)
68. 1a. Name of Second-Tier Foreign Corporationand Its Related
First-Tier Foreign Corporation
1b. EIN (if any)of the Second-TierForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Accumulated Profitsfor Tax Year Indicated(in functional
currency— attach schedule)
5. Foreign Taxes Paid andDeemed Paid for Tax Year Indicated
(in functional currency—see instructions)
6. Dividends Paid(in functional currency)
(a) of Second-Tier Corporation
(b) of First-Tier Corporation
7. Divide Column 6(a)by Column 4
8. Tax Deemed Paid(see instructions)
(a) Functional Currencyof Second-Tier Corporation
(b) U.S. Dollars
5. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(in functional currency—see instructions).
6. Dividends Paid (in functional currency). (a) of Second-Tier
Corporation.
6. Dividends Paid (in functional currency). (b) of First-Tier
Corporation.
7. Divide Column 6(a) by Column 4.
8. Tax Deemed Paid (see instructions). (a) Functional Currency
of Second-Tier Corporation.
8. Tax Deemed Paid (see instructions). (b) U.S. Dollars.
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 9
Schedule F-2
Tax Deemed Paid by First- and Second-Tier Foreign
Corporations Under Section 902(b)—Pre-2018 Tax Years of
Foreign Corporations (continued)
IMPORTANT: Applicable to dividends from tax years of
69. foreign corporations beginning on or before December 31,
2017.If taxpayer does not have such a dividend, do not complete
Schedule F-2 (see instructions).
Part II—Dividends Deemed Paid by Second-Tier Foreign
Corporations
Section A—Dividends Paid Out of Post-1986 Undistributed
Earnings (In general, include the column 10 results in Section
A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b), for an exception.)
1a. Name of Third-Tier Foreign Corporationand Its Related
Second-Tier Foreign Corporation
1b. EIN (if any)of the Third-TierForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Post-1986Undistributed Earnings(in functional currency—
attach schedule)
5. Opening Balance inPost-1986 ForeignIncome Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid (from Schedule F-3, Part I, column 10)
7. Post-1986 ForeignIncome Taxes(add columns 5, 6(a), and
6(b))
8. Dividends Paid(in functional currency)
(a) of Third-Tier Corporation
(b) of Second-Tier Corporation
9. Divide Column 8(a)by Column 4
10. Tax Deemed Paid(multiply column 7by column 9)
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(a) Taxes Paid.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(b) Taxes Deemed Paid (from Schedule F-3, Part I, column 10).
7. Post-1986 Foreign Income Taxes (add columns 5, 6(a), and
6(b)).
8. Dividends Paid (in functional currency). (a) of Third-Tier
70. Corporation.
8. Dividends Paid (in functional currency). (b) of Second-Tier
Corporation.
9. Divide Column 8(a) by Column 4.
10. Tax Deemed Paid (multiply column 7 by column 9).
Section B—Dividends Paid Out of Pre-1987 Accumulated
Profits (In general, include the column 8(b) results in Section
A, column 6(b), of Part I. However, see instructions for
Schedule F-1, Part I, column 6(b) for an exception.)
1a. Name of Third-Tier Foreign Corporationand Its Related
Second-Tier Foreign Corporation
1b. EIN (if any)of the Third-TierForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Accumulated Profitsfor Tax Year Indicated(in functional
currency—attach schedule)
5. Foreign Taxes Paid andDeemed Paid for Tax Year Indicated
(in functional currency—see instructions)
6. Dividends Paid(in functional currency)
(a) of Third-Tier Corporation
(b) of Second-Tier Corporation
7. Divide Column 6(a)by Column 4
8. Tax Deemed Paid(see instructions)
(a) Functional Currencyof Third-Tier Corporation
(b) U.S. Dollars
5. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(in functional currency—see instructions).
6. Dividends Paid (in functional currency). (a) of Third-Tier
Corporation.
6. Dividends Paid (in functional currency). (b) of Second-Tier
Corporation.
7. Divide Column 6(a) by Column 4.
8. Tax Deemed Paid (see instructions). (a) Functional Currency
of Third-Tier Corporation.
71. 8. Tax Deemed Paid (see instructions). (b) U.S. Dollars.
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 10
Schedule F-3
Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier
Foreign Corporations Under Section 902(b)—Pre-2018 Tax
Years of Foreign Corporations
Use this schedule to report taxes deemed paid with respect to
dividends from eligible post-1986 undistributed earnings of
fourth-, fifth-, and sixth-tier controlled foreign
corporations. Report all amounts in U.S. dollars unless
otherwise specified.
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31,
2017.If taxpayer does not have such a dividend, do not complete
Schedule F-3 (see instructions).
Part I—Tax Deemed Paid by Third-Tier Foreign Corporations
(In general, include the column 10 results in Schedule F-2, Part
II, Section A, column 6(b). However, see instructions for
Schedule F-1, Part I, column 6(b), for an exception.)
1a. Name of Fourth-Tier Foreign Corporationand Its Related
Third-Tier Foreign Corporation
1b. EIN (if any)of the Fourth-TierForeign Corporation
1c. Reference IDNumber(see instructions)
2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Post-1986Undistributed Earnings(in functional currency—
attach schedule)
5. Opening Balance inPost-1986 ForeignIncome Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid(from Part II, column 10)
7. Post-1986 ForeignIncome Taxes(add columns 5, 6(a), and
6(b))
72. 8. Dividends Paid(in functional currency)
(a) of Fourth-Tier CFC
(b) of Third-Tier CFC
9. Divide Column 8(a)by Column 4
10. Tax Deemed Paid(multiply column 7by column 9)
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(a) Taxes Paid.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(b) Taxes Deemed Paid (from Part II, column 10).
7. Post-1986 Foreign Income Taxes (add columns 5, 6(a), and
6(b)).
8. Dividends Paid (in functional currency). (a) of Fourth-Tier C
F C.
8. Dividends Paid (in functional currency). (b) of Third-Tier C
F C.
9. Divide Column 8(a) by Column 4.
10. Tax Deemed Paid (multiply column 7 by column 9).
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 11
Schedule F-3
Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier
Foreign Corporations Under Section 902(b)—Pre-2018 Tax
Years of Foreign Corporations (continued)
IMPORTANT: Applicable to dividends from tax years of
foreign corporations beginning on or before December 31,
2017.If taxpayer does not have such a dividend, do not complete
Schedule F-3 (see instructions).
Part II—Tax Deemed Paid by Fourth-Tier Foreign Corporations
(In general, include the column 10 results in column 6(b) of
Part I. However, see instructions for Schedule F-1, Part I,
column 6(b), for an exception.)
1a. Name of Fifth-Tier Foreign Corporationand Its Related
Fourth-Tier Foreign Corporation
1b. EIN (if any)of the Fifth-TierForeign Corporation
1c. Reference IDNumber(see instructions)
73. 2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Post-1986Undistributed Earnings(in functional currency—
attach schedule)
5. Opening Balance inPost-1986 ForeignIncome Taxes
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated
(a) Taxes Paid
(b) Taxes Deemed Paid(from Part III, column 10)
7. Post-1986 ForeignIncome Taxes(add columns 5, 6(a), and
6(b))
8. Dividends Paid(in functional currency)
(a) of Fifth-Tier CFC
(b) of Fourth-Tier CFC
9. Divide Column 8(a)by Column 4
10. Tax Deemed Paid(multiply column 7by column 9)
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(a) Taxes Paid.
6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated.
(b) Taxes Deemed Paid (from Part III, column 10).
7. Post-1986 Foreign Income Taxes (add columns 5, 6(a), and
6(b)).
8. Dividends Paid (in functional currency). (a) of Fifth-Tier C F
C.
8. Dividends Paid (in functional currency). (b) of Fourth-Tier C
F C.
9. Divide Column 8(a) by Column 4.
10. Tax Deemed Paid (multiply column 7 by column 9).
Part III—Tax Deemed Paid by Fifth-Tier Foreign Corporations
(In general, include the column 10 results in column 6(b) of
Part II, above. However, see instructions for Schedule F-1, Part
I, column 6(b), for an exception.)
1a. Name of Sixth-Tier Foreign Corporationand Its Related
Fifth-Tier Foreign Corporation
1b. EIN (if any)of the Sixth-TierForeign Corporation
1c. Reference IDNumber(see instructions)
74. 2. Tax Year End(Year/Month)(see instructions)
3. Country ofIncorporation(enter country code—
see instructions)
4. Post-1986Undistributed Earnings(in functional currency—
attach schedule)
5. Opening Balance inPost-1986 ForeignIncome Taxes
6. Foreign Taxes Paidfor Tax Year Indicated
7. Post-1986 ForeignIncome Taxes(add columns 5 and 6)
8. Dividends Paid(in functional currency)
(a) of Sixth-Tier CFC
(b) of Fifth-Tier CFC
9. Divide Column 8(a)by Column 4
10. Tax Deemed Paid(multiply column 7by column 9)
6. Foreign Taxes Paid for Tax Year Indicated.
7. Post-1986 Foreign Income Taxes (add columns 5 and 6).
8. Dividends Paid (in functional currency). (a) of Sixth-Tier C F
C.
8. Dividends Paid (in functional currency). (b) of Fifth-Tier C F
C.
9. Divide Column 8(a) by Column 4.
10. Tax Deemed Paid (multiply column 7 by column 9).
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 12
Schedule G
Reductions of Taxes Paid, Accrued, or Deemed Paid
Part I—Reduction Amounts
A
Reduction of Taxes Under Section 901(e)—Attach separate
schedule
B
Reduction of Foreign Oil and Gas Taxes—Enter amount from
Schedule I, Part II, line 4
C
Reduction of Taxes Due to Internatio nal Boycott Provisions—
75. Enter appropriate portion from Schedule C (Form 5713) (see
instructions).Important: Enter only “specifically attributable
taxes” here
D
Reduction of Taxes for Section 6038(c) Penalty—Attach
separate schedule
E
Taxes suspended under section 909
F
Other Reductions of Taxes
2. If more than one code is entered on line F1 or if code OTH is
entered on line F1, attach schedule (see instructions).
Total (add lines A through F). Enter here and on Schedule B,
Part II, line 3 ▶
Part II—Other Information
G
Check this box if, during the tax year, the corporation paid or
accrued any foreign tax that was disqualified for credit under
section 901(m) ▶
H
Check this box if, during the tax year, the corporation paid or
accrued any foreign tax that was disqualified for credit under
section 901(j), (k), or (l) ▶
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 13
Schedule H
Apportionment of Certain Deductions (Complete only once for
all categories of income.)
Part I—Research and Experimental Deductions
(a) Sales Method
)
(i) Gross Sales
(ii) R&EDeductions
76. )
(iii) Gross Sales
(iv) R&E
Deductions
(b) Gross Income Method—Check method used:
)
(v) Gross Income
(vi) R&EDeductions
)
(vii) Gross Income
(viii) R&EDeductions
(c) Total R&E Deductions(enter the sum of all amounts entered
in all applicable “R&E Deductions” columns)
(a) Sales Method. Product Line #1. (i) Gross Sales.
(a) Sales Method. Product Line #1. (ii) R&E Deductions.
(a) Sales Method. Product Line #2. (iii) Gross Sales.
(a) Sales Method. Product Line #2. (iv) R&E Deductions.
(b) Gross Income Method. Product Line #1. (v) Gross Income.
(b) Gross Income Method. Product Line #1. (vi) R&E
Deductions.
(b) Gross Income Method. Product Line #2. (vii) Gross Income.
(b) Gross Income Method. Product Line #2. (viii) R&E
Deductions.
(c) Total R&E Deductions (enter the sum of all amounts entered
in all applicable “R&E Deductions” columns).
1
Totals (see instructions)
2
Total to be apportioned
3
Apportionment among statutory groupings (see instructions):
a
(1) Section 245A dividend
(2) Other
77. (3) Total line a
b
(1) Section 245A dividend
(2) Other
(3) Total line b
c
(1) Section 245A dividend
(2) Other
(3) Total line c
d
(1) Section 245A dividend
(2) Other
(3) Total line d
e
(1) Section 245A dividend
(2) Other
(3) Total line e
f
(1) Section 245A dividend
(2) Other
(3) Total line f
4
Total foreign (add lines 3a(3), 3b(3), 3c(3), 3d(3), 3e(3), and
3f(3)) ▶
Important: See Computer-Generated Schedule H in instructions.
Form 1118 (Rev. 12-2020)
Form 1118 (Rev. 12-2020)
Page 14
Schedule H
Apportionment of Certain Deductions (Complete only once for
all categories of income.) (continued)
Part II—Interest Deductions, All Other Deductions, and Total
Deductions
(a) Average Value of Assets—Check method used:
78. (i) Nonfinancial
Corporations
(ii) Financial Corporations
(b) Interest Deductions
(iii) Nonfinancial Corporations
(iv) Financial Corporations
(c) All Other Deductions (attach schedule)(see
instructions)
(d) Totals(add the corresponding amounts from
column (c), Part I; columns (b)(iii) and
(b)(iv), Part II; and column (c), Part II)
Additional note:Be sure to also enter the totals from lines3a(2),
3b(2), 3c(2),3d(2), 3e(2), and 3f(2) below in column 15of the
corresponding Schedule A.
(a) Average Value of Assets. (i) Nonfinancial Corporations.
(a) Average Value of Assets. (ii) Financial Corporations.
(b) Interest Deductions. (iii) Nonfinancial Corporations.
(b) Interest Deductions. (iv) Financial Corporations.
(c) All Other Deductions (see instructions).
(d) Totals (add the corresponding amounts from column (c),
Part I; columns (b)(iii) and (b)(iv), Part II; and column (c), Part
II). Additional note: Be sure to also enter the totals from lines
3a(2), 3b(2), 3c(2), 3d(2), 3e(2), and 3f(2) below in column 15
of the corresponding Schedule A.
1a
Totals (see instructions)
b
Amounts specifically allocable under Temporary Regulations
section 1.861-10T(e)
c
Other specific allocations under Temporary Regulations section
1.861-10T
d
Assets excluded from apportionment formula
79. 2
Total to be apportioned (subtract the sum of lines 1b, 1c, and 1d
from line 1a)
3
Apportionment among statutory groupings (see instructions):
a
(1) Section 245A dividend
(2) Other
(3) Total line a
b
(1) Section 245A dividend
(2) Other
(3) Total line b
c
(1) Section 245A dividend
(2) Other
(3) Total line c
d
(1) Section 245A dividend
(2) Other
(3) Total line d
e
(1) Section 245A dividend
(2) Other
(3) Total line e
f
(1) Section 245A dividend
(2) Other
(3) Total line f
4
Total foreign (add lines 3a(3), 3b(3), 3c(3), 3d(3), 3e(3), and
3f(3)) ▶
Section 904(b)(4) Adjustments
5
80. Expenses Allocated and Apportioned to Foreign Source Section
245A Dividend. Enter the sum of lines 3a(1), 3b(1), 3c(1),
3d(1), 3e(1), and 3f(1). Include the column (d) result as a
negative amount on Schedule B, Part II, line 8b
6
Enter expenses allocated and apportioned to U.S. source section
245A dividend. Include the column (d) result as a negative
amount on Schedule B, Part II, line 8b
Important: See Computer-Generated Schedule H in instructions.
Form 1118 (Rev. 12-2020)
f1_1: f1_2: f1_3: f1_4: f1_5: f1_6: f1_7: f1_8: f1_9: f1_10:
f1_11: f1_12: f1_13: f1_14: f1_15: f1_16: f1_17: f1_18: f1_19:
f1_20: f1_21: f1_22: f1_23: f1_24: f1_25: f1_26: f1_27: f1_28:
f1_29: f1_30: f1_31: f1_32: f1_33: f1_34: f1_35: f1_36: f1_37:
f1_38: f1_39: f1_40: f1_41: f1_42: f1_43: f1_44: f1_45: f1_46:
f1_47: f1_48: f1_49: f1_50: f1_51: f1_52: f1_53: f1_54: f1_55:
f1_56: f1_57: f1_58: f1_59: f1_60: f1_61: f1_62: f1_63: f1_64:
f1_65: f1_66: f1_67: f1_68: f1_69: f1_70: f1_71: f1_72: f1_73:
f1_74: f1_75: f1_76: f1_77: f1_78: f1_79: f1_80: f1_81: f1_82:
f1_83: f1_84: f1_85: f1_86: f1_87: f1_88: f1_89: f1_90: f1_91:
f1_92: f1_93: f1_94: f1_95: f1_96: f1_97: f1_98: f1_99:
f1_100: f1_101: f1_102: f1_103: f1_104: f1_105: f1_106:
f1_107: f1_108: f1_109: f1_110: f1_111: f1_112: f1_113:
f1_114: f1_115: f1_116: f1_117: f1_118: f1_119: f1_120: c2_1:
0f2_1: f2_2: f2_3: f2_4: f2_5: f2_6: f2_7: f2_8: f2_9: f2_10:
f2_11: f2_12: f2_13: f2_14: f2_15: f2_16: f2_17: f2_18: f2_19:
f2_20: f2_21: f2_22: f2_23: f2_24: f2_25: f2_26: f2_27: f2_28:
f2_29: f2_30: f2_31: f2_32: f2_33: f2_34: f2_35: f2_36: f2_37:
f2_38: f2_39: f2_40: f2_41: f2_42: f2_43: f2_44: f2_45: f2_46:
f2_47: f2_48: f2_49: f2_50: f2_51: f2_52: f2_53: f2_54: f2_55:
f2_56: f2_57: f2_58: f2_59: f2_60: f2_61: f2_62: f2_63: f2_64:
f2_65: f2_66: f2_67: f2_68: f2_69: f3_1: f3_2: f3_3: f3_4:
f3_5: f3_6: f3_7: f3_8: f3_9: f3_10: f3_11: f3_12: f3_13:
f3_14: f3_15: f3_16: f3_17: f3_18: f3_19: f3_20: f3_21: f3_22:
f3_23: f3_24: f3_25: f3_26: f3_27: f3_28: f3_29: f3_30: f3_31:
f3_32: f3_33: f3_34: f3_35: f3_36: f3_37: f3_38: f3_39: f3_40:
87. in The Peoples Republic of Shangri-La. These entities have not
generated subpart
F income up to now because their principal production and sales
operations are
located in Shangri-La and they are incorporated in Shangri-La.
We’ll assume that
these CFCs have on November 5, 2017, and December 31, 2017,
$10,000,000
of earnings and profits (“E&P”) that has not been taxed under
subpart F and are
not “effectively connected” to a U.S. trade or business.
So, how is XYZ affected by the provisions of the TCJA? The
basic concept
underlying the new law is the establishment of a territorial tax
system. The key
notion is that, in the future, earnings of our Shangri-La
subsidiaries would be
taxed only in Shangri-La, and when earnings are “repatriated”
through dividends,
those dividends will not be taxed in the United States.1 To
achieve this, the TCJA
created Code Sec. 245A. It establishes a 100% deduction for
dividends received
by a “specified shareholder” from the foreign source E&P of a
foreign corporation
(called the “participation deduction”). A “specified
shareholder” is a domestic C
corporation that owns 10% or more of a foreign corporation
other than a “passive
foreign investment corporation”—an exception I’ll ignore in
this column. Code
Sec. 246(c)(5) creates a holding period rule (366 days of a 731 -
day period hav-
ing the ex-dividend date in the middle) that wouldn’t be a
problem for us. But,
88. unfortunately, this deduction is not available to S corporations
or their shareholders.
To help pay for this new approach, under new Code Sec. 965,
each 10%
shareholder of a “specified foreign corporation” (generally, a
CFC or a foreign
corporation having a domestic corporation as a shareholder)
having “deferred
JOSEPH E. TIERNEY III is a
Shareholder of Meissner
Tierney Fisher & Nichols S.C. in
Milwaukee, Wisconsin.
ENTITY CHOICE CORNER
foreign income” (essentially, post-86 E&Ps that weren’t
taxed under subpart F or “effectively connected” to a U.S.
trade or business) must include in the shareholder’s 2017
return an amount equal to the shareholder’s pro rata share
of “accumulated deferred post 1986 foreign income” of
such corporations. These corporations are called “deferred
foreign income corporations” (“DFICs”) in the statute.
The required inclusion is through the mechanics of subpart
F. In effect, the amount that is to be taxed under Code Sec.
965 becomes subpart F income included under Code Sec.
951. This inclusion is required of all types of shareholders
of DFICs, including C corporations and S corporations,
as well as individuals, partnerships and trusts. So, XYZ’s
shareholders must pick up $10,000,000 as taxable income
for 2017 through subpart F (specifically Code Sec. 951).
There are two ironies for my S corporation clients in
89. this. First, all the good work done to make sure that their
foreign subsidiaries did not generate subpart F income
seems wasted because the shareholders of these corpora-
tions must include all the deferred income accumulated
over the course of the years in their respective 2017 tax
returns—a feature shared with all other types of sharehold-
ers of DFICs. Second, they won’t have the benefit of the
participation dividend deduction going forward because
the dividends that would otherwise constitute participa-
tion dividends are taxable to S corporations—which is not
the case for C corporation shareholders.
There are, however, three important relief provisions at
work in Code Sec. 965, and one significant benefit from
its application. Let’s start with the relief provisions. First,
reduced tax rates are applicable. The rates are scaled down
to 15.5% for the “cash position” of the foreign subsidiary
corporations and 8% for other assets (the balance), and
the foreign tax credit (to the extent available) is similarly
scaled down. But this scale down is measured against the
maximum corporate rate for 2017 (35%), and so, for S
corporation shareholders, this translates to reduced rates of
roughly 17.5% for cash assets and roughly 9.1% for non-
cash assets.2 There are extensive provisions dealing with
the distinction between a foreign corporation’s cash posi -
tion and its non-cash assets. And notice that the “blocked
currency” rules under Code Sec. 964(b) could operate to
convert what are “cash assets” into “non-cash assets.”
Second, under Code Sec. 965(h), each taxpayer may elect
an eight-year deferred payout of the tax attributable to the
Code Sec. 965 inclusion (8% for each of the first five years,
then 15% in the sixth year, 20% in the 7th year and 25% in
the 8th year). See new Proposed Reg. §1.965-7(b) for details,
including provisions for a “consent agreement,” a description
of “acceleration events” that will terminate deferral, and an
90. exception that will forestall acceleration for certain events
if there is a “section 965(h) eligible transferee” who signs a
“transfer agreement.” Heads up estate planners; death is an
acceleration event and the exception does not seem available.
Third, under Code Sec. 965(i), shareholders of S cor-
porations may elect permanent deferral until a “triggering
event.” The statute imposes joint liability for the deferred
tax on the S corporation and requires annual reporting.
The triggering events include (i) loss of S status (though
reinstatement where the termination is inadvertent will
apparently forestall the triggering event), (ii) sale of “sub-
stantially all the assets” (presumably 70% of gross assets
and 90% of net assets), liquidation of the S corporation
or cessation of business, or ceasing to exist, or (iii) disposi -
tion of stock, including by gift or death (inclusion is pro
rata). Code Sec. 965(i)(4) goes on to say that upon any
triggering event, the eight-year deferral under Code Sec.
965(h) can be elected, provided that, for a triggering event
is described in (ii) above, the consent of the Commissioner
will be needed. But Code Sec. 965(i)(2)(C) also provides
an event described in number (iii) above, a disposition of
stock, won’t be a triggering event if the transferee assumes
the remaining net tax liability of the transferor.
Proposed Reg. §1.965-7(c) provides rules for the Code
Sec. 965(i) permanent deferral election for S corporation
shareholders. It provides the structure for the rules relat-
ing to electing the eight-year deferral after a triggering
event, requiring the filing of a “consent agreement” and
specifies that, in the case of a triggering event descri bed in
(ii) above, filing this agreement automatically gives rise to
the necessary IRS consent to use the eight-year deferral.
Proposed Reg. §1.965-7(c) also specifies rules under
91. which a disposition of stock will not constitute a triggering
event. What is required is an “eligible transferee” (someone
other than a “domestic passthrough entity” such as a trust),
and that transferor and eligible transferee file a “transfer
agreement” with the Service. It specifies a form of “transfer
agreement” to affect the assumption of the net tax liability,
and makes clear that the transferor remains jointly and
severally liable also. Again heads up estate planners: these new
regulations give you just a 30-day window after the death of
an S corporation shareholder to file the transfer agreement
to preserve the permanent deferral election. But how the
transfer agreement works in a death setting seems unclear.3
Notice also that the permanent deferral with respect to a
particular DFIC will be available only if the S corporation
has sufficient ownership of the DFIC that qualifies under
Code Sec. 958(a); and if it does, then all of the DFIC’s
income passing through to the S corporation (even income
from domestic partnerships) will be protected by the elec-
tion under Code Sec. 965(i). However, if the S corpora-
tion is not a “U.S. shareholder” under Code Sec. 951(b),
JOURNAL OF PASSTHROUGH ENTITIES SEPTEMBER–
OCTOBER 20188
the permanent deferral election will not be available. For
example, if the S corporation’s ownership of shares in the
DFIC is entirely through a domestic passthrough entity
(e.g., a domestic partnership) that is a U.S. shareholder
of the DFIC, but its percentage interest in the domestic
partnership pulls up less than 10% of the interest in the
DFIC so that the S corporation itself will not be a “U.S.
shareholder” of the DFIC, the domestic partnership’s K-1
will pass through income under Code Sec. 965(a) and
92. deduction under Code Sec. 965(c) to the S corporation,
but the 965(i) election will not be available to the S cor-
poration’s shareholders with respect to that DFIC to defer
the related tax. See Notice 2018-26, section 3.05(b) and
the VIII. D. of the Preamble to the proposed regulations.4
Section 3.04(b) of Notice 2018-26 promised us regula-
tions providing that any change in a non-corporate entity’s
status under Reg. §301.7701-3 after November 2, 2017,
will be disregarded in the application of Code Sec. 965
if it reduces the tax otherwise due under Code Sec. 965.
Proposed Reg. §1.965-4(c)(2) fulfills this promise. This
will be true even if the election would properly relate back
to a date before November 5, 2017. However, suppose
our S corporation acquires 100% of a C corporation on
October 1, 2017 and which makes a QSub election on
November 30, 2017 to be effective on October 1, 2017.
This election shouldn’t be vitiated by this regulation
because this election is not made under Reg. §301.7701-3,
but rather under Reg. §1.1361-3.
As noted above, there is a significant benefit to the
shareholders of our S corporation from the application of
Code Sec. 965, which has otherwise caused them to endure
inclusion of substantial accumulated deferred income (in
our hypothetical, $10,000,000). These amounts (in effect all
of the remaining foreign source E&P of these corporations)
immediately become previously taxed E&P under Code
Sec. 959.5 Thus, when XYZ does repatriate these earnings
as distributions, they will not be included in gross income,
not even as dividends.6 So, while our S corporation share-
holders won’t have available the participation deduction
under Code Sec. 245A, they will have protection for these
distributions to our S corporation hereafter up to the total
amount of the earnings brought into taxation by Code Sec.
965. This is true even though our S corporation shareholders