Form 1118 - Instructions For Schedule J Sheet

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Department of the Treasury
Internal Revenue Service
Instructions for Schedule J
(Form 1118)
(b) any current year adjustments, and (c)
category with positive income is as
Section references are to the Internal
the balances in the overall foreign loss
follows:
Revenue Code unless otherwise noted.
accounts at the end of the tax year.
(Separate limitation income /
Use Part IV to show: (a) the balances
Combined separate limitation income
What’s New for 2007
in the corporation’s overall domestic loss
from all categories with positive income) x
accounts at the beginning of the tax year,
Separate limitation loss being allocated
(b) any current year adjustments, and (c)
New separate categories and
3. If the combined separate limitation
the balances in the overall domestic loss
provisions for overall domestic losses.
losses for the tax year exceed the
accounts at the end of the tax year.
Section 402 of the American Jobs
combined separate limitation income for
Creation Act of 2004 reduced the number
Important. Complete Schedule J only
the tax year, the pro rata share of each
of separate limitation categories and
once. Include adjustments for each
separate limitation loss to allocate to each
added provisions for the setting up and
applicable separate category.
category with positive income is as
recapture of accounts for overall domestic
follows:
Computer-Generated Schedule
losses, effective for tax years beginning
(Separate limitation loss being
A computer-generated Schedule J can be
after December 31, 2006. See Temporary
allocated / Combined separate limitation
filed if it conforms to the IRS version of
Regulations sections 1.904(g)-1T through
losses from all categories with losses) x
the schedule. Expand Schedule J to
3T for rules implementing these changes
Separate limitation income in a given
properly complete Parts I, II, III, and IV of
and providing guidance to coordinate the
category
the schedule if the corporation has more
allocation and recapture of overall foreign
If separate limitation losses can be
than one separate category of “other
losses, separate limitation losses, and
allocated, enter the total amounts
income.” Income from each sanctioned
overall domestic losses. Though these
allocated in the bold-outlined boxes as
country to which section 901(j) applies
regulations are effective for tax years
positive numbers. Enter each separate
and each item of income resourced under
beginning after December 21, 2007,
amount allocated to a given category
a tax treaty are treated as a separate
taxpayers may choose to apply them to
across the same line under the
category of “other income.”
other tax years beginning after December
appropriate column heading to which it
31, 2006. Schedule J has been revised to
was allocated.
reflect the reduction in the number of
separate categories and to follow the
Specific Instructions
Note. The numbers entered across any
ordering rules contained in the new
given line should “zero out.”
regulations. A corporation that chooses to
Part I
If a separate limitation loss in one
follow the principles of Notice 89-3,
category offsets income in a second
1989-1 C.B. 623, rather than applying the
Note. See Temporary Regulations
category and the second category has a
regulations to its 2007 tax year should
section 1.904(g)-3T for more information
separate limitation loss account balance
make the following notation on the top of
on the ordering of adjustments in Part I.
that has not been recaptured with respect
Schedule J: “U.S. Loss Allocation Under
To complete this Part following the
to the first category, then the two
Notice 89-3.” See the specific instructions
principles of Notice 89-3, see the Notes
offsetting separate limitation loss account
for Part I for additional detail on how to
for line 5 and line 10 on pages 2 and 3.
balances are netted for purposes of
complete Schedule J under the
Line 1. Enter in each applicable column,
determining the amount of income in the
regulations or, in the alternative, applying
other than column (iv), the income or
second category that is subject to
the principles of Notice 89-3.
(loss) from column 13 of the
recharacterization on line 9, Part I, if any,
corresponding Schedule A for that
and for purposes of determining the
separate category. In column (iv), enter
year-end balances in both categories
General Instructions
an amount equal to the income or (loss)
reported in Part II.
from Schedule B, Part II, line 7c, minus
The combined separate limitation
the aggregate income or (loss) entered in
Purpose of Schedule
losses for the tax year that are more than
the other columns of this line 1.
the combined separate limitation income
Use Part I to show adjustments to
Line 2. This allocation grid must be
for the tax year reduce the U.S. source
separate limitation income or (losses) in
completed to show the pro rata share of
income (if any) for the tax year. If the
determining the numerator of the
each separate limitation loss to allocate
corporation has no U.S. source income
limitation fraction for each separate
among other applicable separate
for the tax year, or if the excess of its
category.
categories.
combined separate limitation losses for
Use Part II to show the year-end
To determine each pro rata share:
the tax year over combined separate
balances of future separate limitation
limitation income for the tax year exceeds
income that must be recharacterized as
1. Add all of the separate limitation
its U.S. source income for the tax year,
income in other separate categories (as
loss amounts entered across line 1. Then
the excess is treated as a net operating
the result of current year or prior year
add all of the separate limitation income
loss. This loss may be carried over or
separate limitation losses that were
amounts entered across line 1.
back to other tax years according to the
allocated to reduce income in those other
2. If the combined separate limitation
rules of section 172.
separate categories).
losses for the tax year do not exceed the
Use Part III to show: (a) the balances in
combined separate limitation income for
Example 1. Corporation X has a
the corporation’s overall foreign loss
the tax year, the pro rata share of each
separate limitation loss of $2,000 in its
accounts at the beginning of the tax year,
separate limitation loss to allocate to each
general category (line 1, column (i)) and
Cat. No. 50277F

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