Instructions For Schedule I (Form 1120-F) - 2007 Page 8
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8section 1.882-5 applies in determining the
current year deduction of a prior year
treated as a reduction of the allocation in
attributable business profits. For such
deferral for each applicable provision. If
determining the deductible interest
treaties, the amount allocable to ECI
the amount of current year deferrals of
expense for the year.
reported on line 23 requires additional
the interest expense allocated and
Line 24d. Total deferrals and
allocation and apportionment between
reported on line 23 exceeds the current
disallowances. Combine lines 24a, 24b
taxable ECI and treaty-exempt ECI under
year amount of the deductible amount of
and 24c, and enter the result on line 24d.
Regulations section 1.882-5(a)(5).
prior year interest deferrals, enter the
The amount entered on line 24d is also
excess current year deferral as a negative
Note. Enter all amounts on line 24a as a
reported and reconciled for its temporary
number on line 24b. If the current year
negative amount. These line 24a amounts
and permanent differences on Schedule
deductible amount of prior year deferrals
are a reduction of the allocation in
M-3 (Form 1120-F), Part III, line 26c,
exceeds the current year deferrals, enter
determining the deductible interest
columns (b) and (c). See the instructions
the excess deductible amount over the
expense for the year.
for Schedule M-3 (Form 1120-F), Part III,
current year deferrals as a positive
line 26c.
Line 24b. Deferred interest expense.
number on line 24b.
Enter on line 24b the amount of allocable
Line 25. Amount of allocation
Line 24c. Capitalized interest
interest expense on line 23 that is subject
deductible on Form 1120-F, Part II, line
expense. Enter on line 24c the amount
to deferral under sections 163(e)(3),
18. Combine lines 23 and 24d and enter
of interest expense allocation reported on
163(j) or 267(a)(3) in the current tax year.
the result on line 25. The result is the
line 23 that is capitalizable under section
Also enter on line 24b the amount of
corporation’s deductible amount of
263A. Attach a schedule describing how
allocable interest expense deferred under
interest expense allocation for the tax
such allocation has been made.
any of these sections in a prior year that
year and is reportable on Form 1120-F,
Note. Enter all amounts on line 24a as a
is deductible in the current taxable year.
Part II, line 18.
negative amount. These amounts are
Attach a schedule indicating the amount
of current year deferral and the amount of
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