Instructions For Form 1120-Fsc - 2006 Page 4

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any activities performed in connection with
Generally, file Form 7004 by the regular due
ends, see Pub. 947, Practice Before the IRS
foreign military sales except those activities
date of the Form 1120-FSC.
and Power of Attorney.
described in section 924(e). See
Where To File
Regulations section 1.924(d)-1(f) for details.
Other Forms and
File Form 1120-FSC with the:
Section 925(c) Rule
Statements That May Be
Internal Revenue Service Center
To use the administrative pricing rules to
P.O. Box 409101
Required
determine the FSC’s (or small FSC’s) profit
Ogden, UT 84409
on a transaction or group of transactions,
Forms
the FSC must perform (or contract with
Who Must Sign
another person to perform) all of the
The FSC may have to file some of the forms
The return must be signed and dated by:
economic process activities relating to the
listed below. See the form for more
The president, vice president, treasurer,
transaction or group of transactions. All of
information.
assistant treasurer, chief accounting officer;
the direct and indirect expenses relating to
or
the performance of those activities must be
For a list of additional forms the FSC
Any other corporate officer (such as tax
reflected on the books of the FSC and on
may need to file (most notably, forms
officer) authorized to sign.
Form 1120-FSC.
pertaining to the reporting of various types
of income, and any related withholding, to
If a return is filed on behalf of a FSC by a
Under Temporary Regulations section
U.S. persons, foreign persons, and the IRS),
receiver, trustee, or assignee, the fiduciary
1.925(a)-1T(b)(2)(ii), an election may be
see Pub. 542, Corporations.
must sign the return, instead of the
made to include on the FSC’s books all
Form 5471, Information Return of U.S.
corporate officer. Returns and forms signed
expenses, other than cost of goods sold,
by a receiver or trustee in bankruptcy on
Persons With Respect to Certain Foreign
that are necessary to figure combined
Corporations. This form may have to be filed
behalf of a FSC must be accompanied by a
taxable income for the transaction or group
copy of the order or instructions of the court
by certain U.S. officers, directors, or
of transactions. The expenses must be
shareholders of a FSC to report changes in
authorizing signing of the return or form.
identified on Schedule G on the applicable
ownership (see sections 6046 and the
line.
If an employee of the FSC completes
related regulations).
Form 1120-FSC, the paid preparer’s space
Who Must File
If a Form 1120-FSC is filed, Form 5471 is
should remain blank. Anyone who prepares
not required to be filed to satisfy the
Form 1120-FSC but does not charge the
File Form 1120-FSC if the corporation
requirements of section 6038 (see
FSC should not complete that section.
elected to be treated as a FSC or small
Temporary Regulations section
Generally, anyone who is paid to prepare
FSC, and the election is still in effect.
1.921-1T(b)(3)). However, certain U.S.
the return must sign it and fill in the “Paid
Note. A FSC that elects to be treated as a
shareholders may be required to file
Preparer’s Use Only” area.
domestic corporation under section
Form 5471 and the applicable schedules to
The paid preparer must complete the
943(e)(1) does not file Form 1120-FSC.
report subpart F income.
required preparer information and:
Instead, it files Form 1120 (or Form 1120-A).
See the instructions for Form 5471 for
Sign the return in the space provided for
more information.
the preparer’s signature.
When To File
Form 5472, Information Return of a 25%
Give a copy of the return to the taxpayer.
Foreign-Owned U.S. Corporation or a
Generally, a corporation must file Form
Note. A preparer may sign original or
Foreign Corporation Engaged in a U.S.
1120-FSC by the 15th day of the 3rd month
amended returns by rubber stamp,
Trade or Business. Generally, a FSC that is
after the end of its tax year. A FSC that has
mechanical device, or computer software
engaged in a trade or business in the United
dissolved must generally file by the 15th day
programs.
States that had a reportable transaction with
of the 3rd month after the date it dissolved.
a foreign or domestic related party during
Paid Preparer
If the due date falls on a Saturday,
the tax year must file Form 5472.
Sunday, or legal holiday, the FSC may file
Authorization
Form 5713, International Boycott Report.
on the next business day.
FSCs that had operations in, or related to,
If the FSC wants to allow the IRS to discuss
Private delivery services. FSCs may use
certain “boycotting” countries file
its 2006 tax return with the paid preparer
certain private delivery services designated
Form 5713.
who signed it, check the “Yes” box in the
by the IRS to meet the “timely mailing as
Form 8275, Disclosure Statement, and
signature area of the return. This
timely filing/paying” rule for tax returns and
Form 8275-R, Regulation Disclosure
authorization applies only to the individual
payments. These private delivery services
Statement. Disclose items or positions taken
whose signature appears in the “Paid
include only the following:
on a tax return that are not otherwise
Preparer’s Use Only” section of the return. It
adequately disclosed on a tax return or that
DHL Express (DHL): DHL Same Day
does not apply to the firm, if any, shown in
are contrary to Treasury regulations (to
Service, DHL Next Day 10:30 am, DHL Next
that section.
avoid parts of the accuracy-related penalty
Day 12:00 pm, DHL Next Day 3:00 pm, and
If the “Yes” box is checked, the FSC is
or certain preparer penalties).
DHL 2nd Day Service.
authorizing the IRS to call the paid preparer
Federal Express (FedEx): FedEx Priority
Form 8300, Report of Cash Payments
to answer any questions that may arise
Over $10,000 Received in a Trade or
Overnight, FedEx Standard Overnight,
during the processing of its return. The FSC
FedEx 2Day, FedEx International Priority,
Business. Use this form to report the receipt
is also authorizing the paid preparer to:
of more than $10,000 in cash or foreign
and FedEx International First.
Give the IRS any information that is
United Parcel Service (UPS): UPS Next
currency in one transaction or a series of
missing from the return,
related transactions.
Day Air, UPS Next Day Air Saver, UPS 2nd
Call the IRS for information about the
Day Air, UPS 2nd Day Air A.M., UPS
Form 8886, Reportable Transaction
processing of the return or the status of any
Worldwide Express Plus, and UPS
Disclosure Statement. Use this form to
related refund or payment(s), and
Worldwide Express.
disclose information for each reportable
Respond to certain IRS notices about
transaction in which the FSC participated.
The private delivery service can tell you
math errors, offsets, and return preparation.
Form 8886 must be filed for each tax year
how to get written proof of the mailing date.
The FSC is not authorizing the paid
that the Federal Income tax liability of the
Private delivery services cannot
preparer to receive any refund check, bind
FSC is affected by its participation in the
!
deliver items to P.O. boxes. You
the FSC to anything (including any
transaction. The FSC may have to pay a
must use the U.S. Postal Service to
additional tax liability), or otherwise
penalty if it is required to file Form 8886 and
CAUTION
mail any item to an IRS P.O. box address.
represent the FSC before the IRS.
does not do so. The following are reportable
transactions:
Extension of time to file. File Form 7004,
The authorization will automatically end
1. Any listed transaction which is a
Application for Automatic 6-Month Extension
no later than the due date (excluding
of Time To File Certain Business Income
extensions) for filing the FSC’s 2007 tax
transaction that is the same as or
substantially similar to tax avoidance
Tax, Information, and Other Returns, to
return. If the FSC wants to expand the paid
request a 6-month extension of time to file.
preparer’s authorization or revoke it before it
transactions identified by the IRS.
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