Form 1120-F - Instructions For Schedule P - List Of Foreign Partner Interests In Partnerships - 2013 Page 3

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(Form 1065-B), box 9 using code M-2
Schedule K-1 (and is not reportable on
subject to allocation under Regulations
(nondeductible expenses) and/or code U
line 2 of Schedule P).
section 1.882-5.
(other information).
Lines 7 and 8. Other gross income.
Line 15b. Direct interest expense allo-
Lines 1 Through 5. ECI and
Enter on line 7 all other gross income from
cation. On line 15b, enter the amount of
Schedule K-1 (Form 1065) that is not
interest expense included in line 15a that
Non-ECI Reconciliation of
included on lines 1 through 3 of the
is directly allocable to ECI under
Income and Non-Interest
Schedule K-1 (and is not reportable on
Regulations section 1.882-5(a)(1)(ii)(B)
Expenses
line 2 of Schedule P). On line 8, enter the
and the applicable requirements of
amount of gross income from line 7 that is
Temporary Regulations section
Line 1. Net income (loss). Enter on
allocated and apportioned to ECI.
1.861-10T(b) or (c). The amount entered
line 1 the combined total income (loss)
on line 15b is also included on Schedule I
Lines 9 and 10. Other non-interest ex-
from Schedule K-1 (Form 1065), Part III,
(Form 1120-F), line 22.
penses. Enter on line 9 all other
line 1, Ordinary business income (loss);
non-interest expense from Schedule K-1
Line 15c. U.S.-booked interest ex-
line 2, Net rental real estate income (loss);
and line 3, Other net rental income (loss).
(Form 1065) that is not included on lines 1
pense of the partnership. Subtract
through 3 of the Schedule K-1 (and is not
line 15b from line 15a and enter the
Enter the combined amount in the column
reportable on lines 4 and 5 of Schedule P).
amount on line 15c. The portion of this
in Part II which corresponds to the
On line 10, enter the amount of
expense amount that arises from U.S.
partnership listed in Part I. The amount
non-interest expense from line 9 that is
booked liabilities is required to be reported
entered on line 1 is grouped into its gross
income and gross expense components
allocated and apportioned to ECI. Include
on Schedule I (Form 1120-F), line 9,
on line 9 (and line 10 if applicable)
column (b). See Regulations section
for allocation and apportionment to ECI
guaranteed payments made by the
1.882-5(d)(4). A portion of the line 15c
and non-ECI under sections 864(c) and
partnership that are not included on lines 4
amount is also taken into account on Form
882(c). The gross income apportionments
and 5.
1120-F, Section III, Part II, line 8 in
are shown on line 3, and the allocation
and apportionments of non-interest
determining the corporation's branch
Lines 11 and 12. Summary of
interest under Regulations section
expenses shown on line 5 are determined
Gross Income
1.884-4(b).
under Regulations sections 1.861-8 and
1.861-17 and Temporary Regulations
Line 11. Total Gross Income. Enter on
Part III – Foreign Partner's
section 1.861-8T(c). See Regulations
line 11 the sum of the gross income
section 1.861-17 for the allocation and ECI
Average Outside Basis
amounts entered on line 2 and line 7. The
apportionment treatment of research and
amount on line 11 is the total gross
Under Regulations
experimentation expenditures that are
income from Schedule K-1 (Form 1065).
Sections 1.882-5(b) and
included in trade or business income on
Line 12. Total Gross Effectively Con-
line 1 or 3, Schedule K-1, and which are
1.884-1(d)(3)
nected Income. Enter on line 12 the sum
also reportable on Schedule P (Form
Report in Part III the corporation's outside
of the ECI amounts entered on lines 3 and
1120-F), lines 4 and 5.
basis for each partnership interest
8. The amount on line 12 is the total gross
Lines 2 and 3. Gross income. Enter on
identified in Part I of this Schedule P (Form
ECI from Schedule K-1 (Form 1065).
line 2 the total gross income included in
1120-F) for purposes of determining the
Lines 13 Through 15c. Interest
Schedule P (Form 1120-F), line 1. On
amount the corporation includes as a U.S.
line 3, enter the amount of ECI included in
Expense Reconciliation
asset in Step 1 of the interest expense
the gross income reported on line 2. If all
allocation under Regulations section
Enter on line 13 the amount of interest
of the gross income reported on line 2 is
1.882-5. The corporation's outside basis in
expense included in the net income (loss)
ECI, then report the same number on
its partnership interests reported on
on lines 1 through 3 of Schedule K-1
line 3.
Schedule P is determined and adjusted
(Form 1065) and in the net income (loss)
under the rules applicable to the
Lines 4 and 5. Non-interest expense.
reported on line 1 of Schedule P (Form
determination of the corporation's outside
Enter on line 4 the total amount of
1120-F). On line 14, enter the sum of the
basis in the partnership for branch profits
non-interest expense included on line 1.
other interest expense reported on
tax purposes under Regulations section
On line 5, enter the amount of non-interest
Schedule K-1 (Form 1065), lines 13 and
1.884-1(d)(3), except that the amounts
expense included on line 1 that is
18.
entered on lines 16 through 20 are the
allocated and apportioned to gross ECI.
average values rather than the
Include on line 4 (and line 5 if applicable),
Note. If interest expense is included on
determination dates used under the
guaranteed payments made by the
any line of Schedule K-1 (Form 1065)
section 884 regulations for branch profits
partnership that are included in the
other than lines 1, 2, 3, 13, or 18, attach a
tax purposes. If the corporation is not
combined net income (loss) reported on
statement indicating the line the interest is
exempt from the branch profits tax under
line 1. Interest expense included in line 1
included on and reclassify the interest
an applicable income tax treaty, attach a
is subject to allocation under Regulations
expense reported on such other line to
statement showing the determination of
section 1.882-5 and is reported in a
Schedule K-1 (Form 1065), line 13 or
the corporation's outside basis in
separate grouping of the corporation's
line 18, as appropriate, for purposes of
accordance with the requirements of lines
distributive share of all interest expense
reporting the reclassified amount on
16 through 20 for an averaging period that
on Schedule P (Form 1120-F), line 13.
line 14 of Schedule P. The reclassification
shows the apportioned outside basis for
will require an adjustment to such other
Lines 6 Through 10. Other
the beginning and ending determination
line to prevent double counting of total
Gross Income and Other
dates of the corporation's tax year.
expenses.
Non-Interest Expenses
Line 16. Section 705 Outside Basis.
Line 15a. Total interest expense. Add
Enter on line 16 the corporation's average
lines 13 and 14 and enter the result on
Line 6. Net income (loss). Enter on
value of the outside basis (otherwise
line 15a. This amount is the corporation's
line 6 the combined total income (loss)
determined under section 705) of the
total distributive share of interest expense
from Schedule K-1 (Form 1065) that is not
partnership in the column which
from Schedule K-1 (Form 1065) that is
included on lines 1 through 3 of the
Instructions for Schedule P (Form 1120-F) (2013)
-3-

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