Instructions For Schedule I (Form 1120-F) -2010 (Page 8 of 8) in pdf

Note. If the corporation made an

applicable treaty to which Regulations

Section 163(j) and Related Information, in

section 1.882-5 applies in determining the

election under section 108(i) to defer

lieu of, or in addition to, a schedule.

attributable business profits. For such

income from cancellation of debt in

Line 24c. Capitalized interest

treaties, the amount allocable to ECI

connection with an applicable debt

expense. Enter on line 24c the amount

reported on line 23 requires additional

instrument reacquired after December 31,

of interest expense allocation reported on

allocation and apportionment between

2008, and before January 1, 2011, and,

line 23 that is capitalizable under section

taxable ECI and treaty-exempt ECI under

as part of the reacquisition, issues a debt

263A. Attach a schedule describing how

Regulations section 1.882-5(a)(5).

instrument with OID that is subject to

such allocation has been made.

section 108(i)(2), the interest deduction

Note. Enter all amounts on line 24a as a

Note. Enter all amounts on line 24c as a

for this OID is deferred. Include as a

negative amount. These line 24a amounts

negative amount. These amounts are

negative number on line 24b the amount

are a reduction of the allocation in

treated as a reduction of the allocation in

of allocable interest expense on line 23

determining the deductible interest

that is subject to such deferral in the

expense for the year.

current tax year. The accrued OID is

Line 24b. Deferred interest expense.

Line 24d. Total deferrals and

allowed as a deduction ratably over the

Enter on line 24b the amount of allocable

disallowances. Combine lines 24a, 24b,

5-year period that the income from

interest expense on line 23 that is subject

and 24c and enter the result on line 24d.

cancellation of debt is includible in

to deferral (for example, under sections

The amount entered on line 24d is also

income. The deduction is limited to the

163(e)(3), 163(j) or 267(a)(3)) in the

reported and reconciled for its temporary

income from the canceled debt with

current tax year. Also enter on line 24b

and permanent differences on Schedule

respect to the debt instrument reacquired.

the amount of allocable interest expense

M-3 (Form 1120-F), Part III, line 26c,

Include as a positive number on line 24b

deferred under any of these sections in a

columns (b) and (c). See the Instructions

any such deduction which pertains to

prior year that is deductible in the current

for Schedule M-3 (Form 1120-F), Part III,

amounts deferred in a prior tax year that

taxable year. If the amount of current year

line 26c.

is deductible in the current tax year.

deferrals of the interest expense allocated

Line 25. Amount of allocation

Attach a schedule indicating the

and reported on line 23 exceeds the

deductible on Form 1120-F, Section II,

amount of current year deferral and the

current year amount of the deductible

line 18. Combine lines 23 and 24d and

amount of current year deduction of a

amount of prior year interest deferrals,

enter the result on line 25. The result is

prior year deferral for each applicable

enter the excess current year deferral as

the corporation’s deductible amount of

provision. In the case of deferrals and

a negative number on line 24b. If the

interest expense allocation for the tax

deductions under section 163(j), attach

current year deductible amount of prior

year and is reportable on Form 1120-F,

Form 8926, Disqualified Corporate

year deferrals exceeds the current year

Section II, line 18.

Interest Expense Disallowed Under

deferrals, enter the excess deductible

amount over the current year deferrals as

a positive number on line 24b.

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Instructions For Schedule I (Form 1120-F) -2010 Page 8

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