Instructions For Schedule Ttp - Tax Treaty Positions

Income Exclusions

Each corporation filing Schedule TTP must report the amount of income excluded from its

return (from its Schedule U-M if the corporation is a member of a Massachusetts combined

group filing a combined report) by application of all the treaties identified on Schedule TTP.

Each corporation must report separately the amounts of interest, royalties, other FDAP

income and other non-FDAP income from all sources that were excluded from its income as

reported. Note that any corporation that excludes income from its Massachusetts income

computation must also, for consistency purposes, exclude any expenses that relate to such

income and also must adjust its apportionment formula to exclude any factor attributes that

relate to the excluded income. Do not reduce these amounts on lines 1 through 4 on account

of any deductions that would be allowable if the income were taxable on a net income basis.

The total of lines 1 through 4 is reported on line 5.

Combined Report Filers Only

For each Schedule TTP, identify the name of the combined group’s principal reporting

corporation and the Federal Identification number of the principal reporting corporation.

Each corporation filing Schedule TTP that receives but excludes from the combined report

any income that is derived, directly or indirectly, from intangible property or service-related

activities, the costs of which are generally deductible for federal income tax purposes against

the business income of other corporations of the Massachusetts combined group must also

identify the amounts received from each related party.

Enter the name of each member of the Massachusetts combined group paying such amounts

to the corporation filing Schedule TTP, the Federal Identification number of the other

corporation making the payments and the total amount of income excluded from the return

(without reduction on account of any deductions that would be allowable if the income were

included in the combined report). The total of the amounts on line 6 may be less than the

amount reported on line 5 if the corporation filing schedule TTP is excluding income from

sources other than the members of the Massachusetts combined group because of the treaty.

For each Schedule TTP, also check the first applicable box that corresponds to this

corporation (e.g. if the corporation is a non-U.S. corporation that, based on its own activities,

is taxable on its income in Massachusetts, that box will be checked regardless of whether or

not either of the subsequent tests is met).

Instructions For Schedule Ttp - Tax Treaty Positions - 2012 Page 2