Schedule Abi - Exceptions To The Add Back Of Interest Expenses - 2013 Page 3

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Exception 3.

The taxpayer must prepare with its tax return and make available to the Commissioner upon request a supporting statement prepared in accordance with

Exception based on supporting statement.

the Department’s public written statements. All double tax exceptions must be claimed by answering the questions set forth in the preceding sections.

Check the basis for this claim:

Business purpose/economic substance

Section 31K foreign treaty exception

01 Amount of the deductible interest claimed by taxpayer. Enter result here and in Total Exceptions Claimed, line 3 . . . . . . . . . . . 1

02 Name of the related member to which the taxpayer paid, accrued or incurred the interest cost or expense

03 FID of the related member to which the taxpayer paid, accrued or incurred the interest cost or expense . . . . . . . . . . . . . . . . . . 3

04 Date when the underlying debt or liability was originally incurred (if the cost or expense was paid, accrued or incurred

pursuant to a note or similar obligation, date of the note or instrument) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

05 Dollar amount of the underlying debt or liability as originally incurred . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

06 Outstanding dollar amount of the debt or liability at the end of the tax year covered by this tax return . . . . . . . . . . . . . . . . . . . . 6

07 If the underlying debt or liability has a fixed term, enter the termination date . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

08 Interest rate on the underlying debt or liability (if a variable rate, enter the effective rate for the period covered by this

tax return) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

09 If the taxpayer is seeking the section 31K exception, enter the name of the foreign nation in which the related member

is resident . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

10 Was the interest cost or expense paid, accrued or incurred pursuant to a note or similar instrument?

Yes

11 If the answer to question 10 is yes, was the interest cost or expense paid, accrued or incurred in connection with a dividend note or similar instrument?

Yes

12 Did the taxpayer assert an add back exception in connection with the debt or liability on its Massachusetts tax return for a prior year?

Yes

13 Was the interest cost or expense actually paid (e.g., as opposed to accrued)?

Yes

14 If the answer to question 13 is yes, was the amount paid substantially returned to the taxpayer, either directly or indirectly, during the tax year (e.g.,

through the means of a dividend, loan, etc.)?

Yes

15 Was the underlying transaction entered into in whole or in part on the advice of a tax advisor?

Yes

16 Was reduction of tax a principal purpose for the underlying transaction?

Yes

17 Was the interest cost or expense the result of the taxpayer participating in a cash management, cash sweep or similar arrangement or system?

Yes

18 Is the amount of interest cost or expense the result of or supported by a written study or appraisal?

Yes

19 The taxpayer may use the space below to provide greater detail concerning its Exception 3 claim.