Instructions For Form 1120-Fsc - 2006 Page 10

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the deduction provided in section 247 for
ex-dividend date. When counting the
4. Enter the smaller of line 2 or 3. If
dividends paid.
number of days the FSC held the stock, you
line 3 is greater than line 2, stop
may not count certain days during which the
here; enter the amount from line 4
Line 5, Column (a)
FSC’s risk of loss was diminished. See
on line 8, column (c), and do not
Enter dividends received on preferred stock
section 246(c)(4) and Regulations section
complete lines 5-10 below . . . . .
4.
of a 20%-or-more-owned public utility that is
1.246-5 for more details.
5. Enter the total amount of dividends
subject to income tax and is allowed the
b. Dividends attributable to periods
from 20%-or-more-owned
deduction provided in section 247 for
totaling more than 366 days that the
corporations that are included on
dividends paid.
corporation received on any share of
lines 2, 3, 5, and 7, column (a) . .
5.
preferred stock held for less than 91 days
Line 6, Column (a)
6. Subtract line 5 from line 1 . . . . . .
6.
during the 181-day period that began 90
Enter the U.S.-source portion of dividends
days before the ex-dividend date. When
7. Multiply line 6 by 70% . . . . . . . .
7.
that:
counting the number of days the FSC held
8. Subtract line 3 above from line 8,
Are received from less-than-20%-owned
the stock, you may not count certain days
column (c) . . . . . . . . . . . . . . .
8.
foreign corporations and
during which the FSC’s risk of loss was
Qualify for the 70% deduction under
diminished. See section 246(c)(4) and
9. Enter the smaller of line 7 or
section 245(a). To qualify for the 70%
Regulations section 1.246-5 for more
line 8 . . . . . . . . . . . . . . . . . . .
9.
deduction, the FSC must own at least 10%
details. Preferred dividends attributable to
10. Dividends-received deduction
of the stock of the foreign corporation by
periods totaling less than 367 days are
after limitation (sec. 246(b)). Add
vote and value.
subject to the 46-day holding period rule
lines 4 and 9. Enter the result here
above.
and on line 8, column (c) . . . . . . 10.
Line 7, Column (a)
c. Dividends on any share of stock to
Enter the U.S.-source portion of dividends
the extent the FSC is under an obligation
Line 10, Column (a)
that are received from 20%-or-more-owned
(including a short sale) to make related
If the FSC claims the foreign tax credit,
foreign corporations and that qualify for the
payments with respect to positions in
enter the tax that is deemed paid under
80% deduction under section 245(a).
substantially similar or related property.
sections 902 and 960. See sections 78 and
5. Any other taxable dividend income
Line 8, Column (c)
906(b)(4).
not properly reported elsewhere on the
Limitation on dividends-received
worksheet.
Line 11, Column (a)
deduction. Generally, line 8, column (c),
If patronage dividends or per-unit retain
Include the following:
may not exceed the amount on line 10 of the
allocations are included on line 11, identify
worksheet below. However, in a year in
1. Dividends (other than capital gain
the total of these amounts in a schedule
which an NOL occurs, this limitation does
distributions reported on Schedule D (Form
attached to Form 1120-FSC.
not apply even if the loss is created by the
1120) and exempt-interest dividends) that
dividends-received deduction. See sections
are received from RICs and that are not
172(d) and 246(b).
subject to the 70% deduction.
Schedule G
2. Dividends from tax-exempt
1. Refigure line 18, Part II, Schedule
Deductions Allocated or
organizations.
B (page 3 of Form 1120-FSC)
3. Dividends (other than capital gain
Apportioned to Foreign Trade
without any adjustment under
distributions) received from a real estate
Income Other Than Foreign
section 1059 and without any
investment trust that, for the tax year of the
capital loss carryback to the tax
trust in which the dividends are paid,
Trade Income Reported on
year under section 1212(a)(1) . . .
1.
qualifies under sections 856 through 860.
Schedule F
4. Dividends not eligible for a
2. Multiply line 1 by 80% . . . . . . . .
2.
dividends-received deduction, which include
3. Add lines 2, 5, and 7, column (c),
Limitations on Deductions
the following:
and the part of the deduction on
a. Dividends received on any share of
Section 263A uniform capitalization
line 3, column (c), that is
stock held for less than 46 days during the
rules. The uniform capitalization rules of
attributable to dividends from
91-day period beginning 45 days before the
section 263A generally require FSCs to
20%-or-more-owned corporations
3.
Dividends and Dividends-Received Deduction Worksheet
(a) Dividends
(c) Dividends-received
(See instructions that begin on page 9)
received
(b) %
deduction: (a) x (b)
1 Dividends from less-than-20%-owned domestic corporations that are subject to the
70% deduction (other than debt-financed stock) . . . . . . . . . . . . . . . . . . . . . . .
70
2 Dividends from 20%-or-more-owned domestic corporations that are subject to the
80% deduction (other than debt-financed stock) . . . . . . . . . . . . . . . . . . . . . . .
80
3 Dividends on debt-financed stock of domestic and foreign corporations (section
246A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
See Inst.
4 Dividends on certain preferred stock of less-than-20%-owned public utilities . . . . .
42
5 Dividends on certain preferred stock of 20%-or-more-owned public utilities . . . . . .
48
6 Dividends from less-than-20%-owned foreign corporations that are subject to the
70% deduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
70
7 Dividends from 20%-or-more-owned foreign corporations that are subject to the
80% deduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
80
8 Total dividends-received deduction. Add lines 1 through 7. See instructions for
limitation. Enter here and on line 19b, Schedule B. . . . . . . . . . . . . . . . . . . . . .
9 Other dividends from foreign corporations not included on lines 3, 6, or 7 . . . . . . .
10 Foreign dividend gross up (section 78) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11 Other dividends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12 Total dividends. Add lines 1 through 11. Enter here and on line 9, Schedule F . . .
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