Instructions For Schedule I (Form 1120-F) - 2008 (Page 8 of 8) in pdf

Line 24b. Deferred interest expense.

Line 24c. Capitalized interest

additional rules that may defer or disallow

Enter on line 24b the amount of allocable

expense. Enter on line 24c the amount

deductibility in whole or in part.

interest expense on line 23 that is subject

of interest expense allocation reported on

Line 24a. Tax-exempt allocations.

to deferral under sections 163(e)(3),

line 23 that is capitalizable under section

Enter on line 24a the amount of allocable

163(j) or 267(a)(3) in the current tax year.

263A. Attach a schedule describing how

interest expense on line 23 that is subject

Also enter on line 24b the amount of

such allocation has been made.

to further allocation and apportionment to

allocable interest expense deferred under

Note. Enter all amounts on line 24c as a

tax-exempt income under section 265 or

any of these sections in a prior year that

negative amount. These amounts are

under the provisions of an applicable

is deductible in the current taxable year. If

treated as a reduction of the allocation in

income tax treaty. Attach a schedule

the amount of current year deferrals of

determining the deductible interest

showing how such allocation between

the interest expense allocated and

expense for the year.

exempt and non-exempt ECI has been

reported on line 23 exceeds the current

made. See Regulations section

Line 24d. Total deferrals and

year amount of the deductible amount of

1.882-5(a)(5), examples (3) and (4).

disallowances. Combine lines 24a, 24b,

prior year interest deferrals, enter the

Treaty-exempt income may include

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

excess current year deferral as a negative

income that is ECI under the force of

The amount entered on line 24d is also

number on line 24b. If the current year

attraction principle of section 864(c)(3)

reported and reconciled for its temporary

deductible amount of prior year deferrals

but which is business profits not

and permanent differences on Schedule

exceeds the current year deferrals, enter

attributable to a U.S. permanent

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

the excess deductible amount over the

establishment of the corporation under an

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

current year deferrals as a positive

applicable treaty to which Regulations

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

number on line 24b.

section 1.882-5 applies in determining the

line 26c.

attributable business profits. For such

Attach a schedule indicating the

Line 25. Amount of allocation

treaties, the amount allocable to ECI

amount of current year deferral and the

deductible on Form 1120-F, Section II,

reported on line 23 requires additional

amount of current year deduction of a

line 18. Combine lines 23 and 24d and

allocation and apportionment between

prior year deferral for each applicable

enter the result on line 25. The result is

taxable ECI and treaty-exempt ECI under

provision. In the case of deferrals and

the corporation’s deductible amount of

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

deductions under section 163(j), attach

interest expense allocation for the tax

Form 8926, Disqualified Corporate

Note. Enter all amounts on line 24a as a

year and is reportable on Form 1120-F,

Interest Expense Disallowed Under

negative amount. These line 24a amounts

Section II, line 18.

Section 163(j) and Related Information, in

are a reduction of the allocation in

lieu of a schedule.

determining the deductible interest

expense for the year.

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Instructions For Schedule I (Form 1120-F) - 2008 Page 8

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