Instructions For Form 1120-Fsc -U.s. Income Tax Return Of A Foreign Sales Corporation - 2005 Page 9

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administrative pricing rules. See section
Instructions for Dividends
4. With respect to the commission
923(a)(2).
income reported on line 2 above,
and Dividends-Received
enter total gross receipts on the
Use lines 3a through 3d to figure the
Deduction Worksheet
sale, lease, or rental of property on
exemption percentage for foreign trade
For purposes of the 20% ownership test on
which the commission income
income that was determined by using the
arose (section 927(b)(2)) . . . . . . . 4.
lines 1 through 7, the percentage of stock
administrative pricing rules (see section
owned by the FSC is based on voting power
923(a)(3)). If a qualified cooperative is a
5. Add lines 3 and 4. Enter here and
and the value of the stock. Preferred stock
shareholder of the FSC, see section
on line 6f, Schedule B . . . . . . . . . 5.
described in section 1504(a)(4) is not taken
923(a)(4).
into account.
Line 6h. When making the line 6h
Schedule F
allocation, allocate only the commission
Line 1, Column (a)
income from the gross receipts on line 4
Enter dividends (except those received on
Net Income From Nonexempt
above. If the small FSC’s foreign trading
debt-financed stock acquired after July 18,
gross receipts for the tax year (line 6f,
Foreign Trade Income and
1984 — see section 246A) that:
Schedule B) exceed its allowable limitation
Taxable Nonforeign Trade
Are received from less-than-20%-owned
(line 6e, Schedule B), the small FSC may
domestic corporations subject to income tax
Income
select the gross receipts to which the
and
limitation is allocated. In such a case,
Qualify for the 70% deduction under
allocate the amount on line 6g between
Part I
section 243(a)(1).
columns (a) and (b) on line 6h based on
Enter net income from nonexempt foreign
whether the administrative pricing rules
Also include on line 1 dividends (except
trade income and related expenses in Part I.
were used for the gross receipts selected.
those received on debt-financed stock
Line 2. Enter FSC income that resulted
See Regulations section 1.921-2(b), Q&A-4.
acquired after July 18, 1984) from a
from the FSC’s cooperation with an
regulated investment company (RIC). The
Part II
international boycott. See section 927(e)(2)
amount of dividends eligible for the
and Form 5713 and related schedules and
dividends-received deduction under section
Line 19a. Net operating loss deduction.
instructions.
243 is limited by section 854(b). The FSC
A FSC may use the NOL incurred in one tax
should receive a notice from the RIC
Line 3. Enter the amount, if any, of illegal
year to reduce its taxable income in another
specifying the amount of dividends that
payments, bribes, or kickbacks that the FSC
tax year. Enter on line 19a the total NOL
qualify for the deduction.
paid, directly or indirectly, to government
carryovers from other tax years, but do not
officials, employees, or agents. See section
Report so-called dividends or earnings
enter more than the FSC’s taxable income
927(e)(2).
received from mutual savings banks, etc., as
(after the dividends-received deduction).
interest. Do not treat them as dividends.
Line 5. See the instructions for Schedule A
Attach a schedule showing the computation
before completing this line.
of the NOL deduction. Also complete line 7
Line 2, Column (a)
in Additional Information on page 2 of the
Part II
Enter dividends (except those received on
form.
debt-financed stock acquired after July 18,
Enter the taxable portion of gross income of
For details on the NOL deduction, see
1984) that are received from
the FSC that was not derived from foreign
Pub. 542, section 172, and Form 1139.
20%-or-more-owned domestic corporations
trading gross receipts. This type of income
subject to income tax and that are subject to
Line 19b. Dividends-received deduction.
includes:
the 80% deduction under section 243(c).
A FSC may be entitled to a deduction for
Small FSCs only. Amounts specifically
dividends it receives from other
excluded from foreign trade income because
Line 3, Column (a)
corporations. Complete the worksheet on
of the small FSC limitation (the amount by
Enter dividends that are:
page 10 using the instructions that begin
which line 6f of Schedule B exceeds line 6e
Received on debt-financed stock acquired
below. Attach the completed worksheet to
of Schedule B). (Enter the excess, if any, on
after July 18, 1984, from domestic and
Form 1120-FSC.
line 7 of Schedule F.)
foreign corporations subject to income tax
Investment type income. (Enter on lines 8
Line 20. Taxable income or (loss). If line
that would otherwise be subject to the
through 12 of Schedule F.)
20 is zero or less, the FSC may have an
dividends-received deduction under section
Income from property that is subsidized,
NOL that may be carried back or forward as
243(a)(1), 243(c), or 245(a). Generally,
deemed in short supply, or destined for use
a deduction to other tax years. Generally, a
debt-financed stock is stock that the FSC
in the United States. (Enter on lines 13 and
FSC first carries back an NOL 2 tax years.
acquired by incurring a debt (for example, it
14 of Schedule F.)
However, the FSC may elect to waive the
borrowed money to buy the stock).
Amounts from transactions that did not
carryback period and instead carry the NOL
Received from a RIC on debt-financed
meet the foreign economic process
forward to future tax years. To make the
stock. The amount of dividends eligible for
requirements. (Enter on line 15 of Schedule
election, see the instructions for Additional
the dividends-received deduction is limited
F.)
Information, line 6 on page 8.
by section 854(b). The FSC should receive
Other nonforeign trade income. (Enter on
a notice from the RIC specifying the amount
See Form 1139 for details, including
line 16 of Schedule F.)
of dividends that qualify for the deduction.
other elections that may be available, which
For more details, see sections 924(f)
must be made no later than 6 months after
Line 3, Columns (b) and (c)
and 927(a)(2) and (3).
the due date (excluding extensions) of the
Dividends received on debt-financed stock
Line 9. Complete the worksheet on page 10
FSC’s tax return.
acquired after July 18, 1984, are not entitled
to figure the total dividends to report on line
to the full 70% or 80% dividends-received
9. Attach the completed worksheet to Form
Schedule E
deduction. The 70% or 80% deduction is
1120-FSC.
reduced by a percentage that is related to
Exemption Percentages Used in
Line 18. Enter the deductions allocated or
the amount of debt incurred to acquire the
apportioned to line 17 income. Attach to
Figuring Exempt Foreign Trade
stock. See section 246A. Also, see section
Form 1120-FSC a schedule listing each type
Income
245(a) before making this computation for
of deduction. Show deductions related to
an additional limitation that applies to
For purposes of the Note at the top of
cost of goods sold separately. See the
dividends received from foreign
Schedule E, a C corporation is a corporation
instructions for Schedule A on page 7 before
corporations. Attach a schedule to Form
other than an S corporation. Shareholders,
completing this line.
1120-FSC showing how the amount on line
other than C corporations, are individuals,
Passive activity limitations. Section 469
3, column (c), was figured.
partnerships, S corporations, trusts, and
generally limits the deduction of passive
estates.
Line 4, Column (a)
activity losses for closely held FSCs and
Use lines 2a through 2d to figure the
FSCs that are personal service
Enter dividends received on the preferred
exemption percentage for foreign trade
corporations. See section 469 and the
stock of a less-than-20%-owned public utility
income determined by not using the
Instructions for Form 8810 for details.
that is subject to income tax and is allowed
-9-

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