Instructions For Form 1118 - 2007

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Department of the Treasury
Instructions for Form 1118
Internal Revenue Service
(Rev. December 2007)
Foreign Tax Credit—Corporations
Passive Category Income
Section references are to the Internal
Computer-Generated
Revenue Code unless otherwise noted.
Passive category income includes
Form 1118
passive income and specified passive
category income.
The corporation may submit a
What’s New for 2007
computer-generated Form 1118 and
Passive income. Generally, passive
schedules if they conform to the IRS
income is:
Several categories of income have
version. However, if a software program
Any income received or accrued that
been eliminated. Section 404 of the
is used, it must be approved by the IRS
would be foreign personal holding
American Jobs Creation Act of 2004
for use in filing substitute forms. This
company income (defined in section
eliminated the following categories of
ensures the proper placement of each
954(c)) if the corporation were a
income, effective for tax years beginning
item appearing on the IRS version. For
controlled foreign corporation (CFC)
after December 31, 2006.
more information, see Pub. 1167, General
(defined in section 957). This includes
Rules and Specifications for Substitute
High withholding tax interest.
any gain on the sale or exchange of stock
Forms and Schedules.
Financial services income.
that is more than the amount treated as a
Shipping income.
dividend under section 1248. However, in
How To Complete
determining if any income would be
Dividends from a domestic international
foreign personal holding company
sales corporation (DISC) or former DISC.
Form 1118
income, the rules of section 864(d)(6) will
Taxable income attributable to foreign
apply only for income of a CFC.
trade income
Important. Complete a separate
Any amount includible in gross income
Certain distributions from a foreign
Schedule A; Schedule B, Parts I & II;
under section 1293 (which relates to
sales corporation (FSC) or former FSC.
Schedules C through G; and Schedule I
certain passive foreign investment
for each applicable separate category of
companies).
Income that was previously reported in
income. See Categories of Income below.
these categories is now either passive
Passive income does not include:
Complete Schedule B, Part III; Schedule
category income or general category
Any financial services income that is
H; and Schedule J only once.
income. See Categories of Income below
general category income (see General
Use Schedule A to compute the
for definitions of passive category income
Category Income on page 2),
corporation’s income or loss before
and general category income.
Any export financing interest unless it is
adjustments for each applicable category
also related person factoring income (see
of income.
Schedule A, column 11. Schedule A,
section 904(d)(2)(G) and Temporary
Use Schedule B to determine the total
column 11 (net operating loss deduction)
Regulations section 1.904-4T(h)(3)),
foreign tax credit after certain limitations.
has been added to reflect the provisions
Any high-taxed income (see General
Use Schedule C to compute taxes
of Temporary Regulations section
Category Income on page 2 and the
deemed paid by the domestic corporation
1.904(g)-3T(b), providing guidance on the
instructions for Schedule A, on page 5),
filing the return.
allocation of net operating losses to
or
Use Schedules D and E to compute
separate limitation income in tax years
Any active rents or royalties received
taxes deemed paid by lower-tier foreign
beginning after December 21, 2007.
from an unrelated person and active rents
corporations.
or royalties received from a related
Use Schedule F to report gross
person that were paid or accrued after
General Instructions
income and definitely allocable
September 20, 2004. See Temporary
deductions from foreign branches.
Regulations section 1.904-4T(b)(2)(iii) for
Purpose of Form
Use Schedule G to report required
definitions and exceptions.
reductions of tax paid, accrued, or
Use Form 1118 to compute a
Note. Certain income received from a
deemed paid.
corporation’s foreign tax credit for certain
CFC and certain dividends from a 10/50
Use Schedule H to apportion
taxes paid or accrued to foreign countries
corporation that would otherwise be
deductions that cannot be definitely
or U.S. possessions. See Taxes Eligible
passive income may be assigned to
allocated to some item or class of income.
for a Credit on page 3.
another separate category under the
Use Schedule I (a separate schedule)
look-through rules. See Look-Through
to compute reductions of taxes paid,
Who Must File
Rules on page 2.
accrued, or deemed paid on foreign oil
Any corporation that elects the benefits of
Specified passive category income.
and gas extraction income.
the foreign tax credit under section 901
This term includes:
Use Schedule J (a separate schedule)
must complete and attach Form 1118 to
Dividends from a DISC or former DISC
to compute adjustments to separate
its income tax return.
(as defined in section 992(a) to the extent
limitation income or losses in determining
such dividends are treated as foreign
the numerators of limitation fractions,
source income, and
year-end recharacterization balances,
When to Make the Election
Distributions from a former FSC out of
and overall foreign and domestic loss
The election to claim the foreign tax credit
earnings and profits attributable to foreign
account balances.
(or a deduction in lieu of a credit) for any
trade income or interest or carrying
tax year may be made or changed at any
charges (as defined in section 927(d)(1),
Categories of Income
time before the end of a special 10-year
before its repeal) derived from a
period described in section 6511(d)(3) (or
Compute a separate foreign tax credit for
transaction which results in foreign trade
section 6511(c) if the period is extended
each applicable separate category
income (as defined in section 932(b),
by agreement).
described below.
before its repeal).
Cat. No. 10905I

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