Instructions For Schedule H (Form 1120-F) - 2017 Page 5

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deductions to ECI for purposes of
allocations to ECI or non-ECI are
sets of books must be eliminated in
line 11, 16, or 19, enter the worldwide
estimated and documented by
the combined reports.
assets used in that ratio. If a
questionnaires or home office
Line 30. Enter on line 30 the total of
worldwide asset ratio is not available
department interviews (e.g.,
the adjustments necessary to conform
from either Schedule I (Form 1120-F),
estimated percent of time spent by
the amounts on line 29 to the amounts
line 6b, or Schedule H, line 11, 16, or
employees of particular home office
that are deductible for U.S. tax
19, leave line 22b blank.
departments or sub-departments on
purposes. See the instructions for Part
U.S. trade or business activities).
Line 22c. If an amount is entered on
I, line 2, for a general description of
line 22b, divide line 22a by line 22b to
Lines 26 Through 28.
the types of temporary and permanent
determine the asset ratio and enter
differences that are reportable as
Identification of Financial
the percentage on line 22c. If line 22b
adjustments to the book expenses in
Records Used
is blank, leave line 22c blank.
determining current year tax
Check the “Yes” or “No” box to
deductions under U.S. tax principles.
Line 23a. Enter on line 23a the
indicate whether the types of financial
However, do not include on line 30
number of personnel who worked in
books and records indicated were
any adjustments that are otherwise
the corporation's U.S. trade or
used to complete Parts I and II of
reportable on lines 32a through 35.
business during the tax year. The
Schedule H.
Specifically, third-party interest
corporation may use any reasonable
expense and interbranch interest
Line 28. If the “Yes” box is checked,
method to determine the number of
expense included on line 29 is
attach a statement listing the other
personnel, including data that is
adjusted on lines 32a and 32b,
documentation used to complete
already prepared and used by the
instead of line 30. Bad debt expense
Parts I and II of Schedule H (e.g.,
corporation for a non-tax business
included on line 29 is adjusted on
home country regulatory reports or
purpose. For example, if the
line 33, instead of line 30. Other
functional analyses).
corporation maintains headcount data
third-party deductible expenses not
(such as weighted average headcount
Part IV – Allocation and
allocated or apportioned to ECI and
data) in its personnel records or for
non-ECI under Regulations section
Apportionment of
other purposes such as budgeting,
1.861-8 are adjusted on line 34,
Expenses on Books and
planning, and control, such numbers
instead of line 30. Interbranch
may be used in the numerator.
Records Used to Prepare
expenses (other than interest
Form 1120-F, Schedule L
Line 23b. If the corporation used a
expense) included on line 29
ratio based on number of personnel to
(including interbranch book charges
Use Part IV of Schedule H to report
apportion deductions on line 11, 16,
for home office services provided to
the allocation and apportionment of
or 19, enter the worldwide personnel
the U.S. trade or business) are
deductions recorded on the
count used in the denominator of such
adjusted on line 35, instead of line 30.
corporation's Schedule L books, other
ratio on line 23b. If the corporation
However, if the corporation is a
than interest and bad debt expense,
does not apportion deductions using a
foreign bank that charges its U.S.
to ECI and non-ECI under Regulations
number of personnel ratio, leave
branch office cost reimbursements for
sections 1.861-8 and 1.861-17 and
line 23b blank.
services and overhead which are
Temporary Regulations section
booked by the branch in the
1.861-8T.
Line 23c. If an amount is entered on
third-party category of expense
line 23b, divide line 23a by line 23b to
Line 29. Enter on line 29 the total
actually incurred rather than as a lump
determine the number of personnel
expenses recorded on the Schedule L
sum interbranch amount, the
ratio and enter the percentage on
books.
interbranch amounts charged and
line 23c. If line 23b is blank, leave
recorded by the U.S. branch
line 23c blank.
Note. The Schedule L books may be
Schedule L book should not be
maintained using GAAP, or other
Line 24. If the corporation used any
reported on line 35 as interbranch
applicable accounting standards,
other ratio-based method to allocate
expenses, but should be left in the
other than U.S. GAAP. The
and apportion deductions to ECI and
third-party categories to which they
Schedule L books may include more
non-ECI on line 8, 9, 10, 11, 16, or 19
are assigned on the U.S. books and
than one set of books, including the
of Schedule H, attach a statement
records. If any such amounts require
set(s) of books of disregarded
describing the ratio used on each line.
adjustment for U.S. tax principles
entities. See the Instructions for
Include the numerator and
(e.g., meals and entertainment at
Schedule M-3 (Form 1120-F), Part I,
denominator of the ratio used for each
50%), then such adjustment should
lines 4 and 5, for the Schedule L
applicable line.
be shown on line 30.
treatment of disregarded entities and
Line 25. If the corporation used a
Attach a statement detailing the
the combined reporting of multiple
non-ratio-based method to allocate
items adjusted and amounts of each
sets of books. These rules apply to
and apportion deductions to ECI and
adjustment.
both banks and non-banks for
non-ECI on line 8, 9, 10, 11, 16, or 19
purposes of determining the
Line 32a. Enter on line 32a the
of Schedule H, attach a statement
expenses reportable on Schedule H,
amount of third-party interest expense
describing each such method and the
line 29. Interbranch income and
(whether owed to unrelated or related
percentage used, if any, for each
expenses recorded between separate
parties) that is included in the amount
applicable line. These may include
reported on line 31. Interest expense
methods for which percentage
Instructions for Schedule H (Form 1120-F)
-5-

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