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Part III

Publication 5384 — Statistics of Income Program Documentation: Data Items by Forms and Schedules, Program Year 2024 · 2026-10-03 edition · updated 2026-10-04 · United States

Line 2. Enter the sum of any carryover of foreign oil and gas tax to the current year. Attach a schedule showing the computation in detail. Corporations are encouraged to attach a schedule that is similar to Schedule K (Form 1118), which is used to report a running balance of the corporation’s section 904(c) carryovers. If this approach is taken, the amount to be entered on line 2 is the amount that corresponds to Schedule K (Form 1118), line 3, column (xiv). Please note that special rules apply to the carryback and carryover of foreign taxes paid or accrued on combined foreign oil and gas income and related taxes. For example, in applying foreign tax carryovers from prior tax years, in the case of any tax year that is an unused credit year (as defined in section 907(f)) under each of sections 907(f) and 904(c), the provisions of section 907(f) are to be applied before section 904(c). See section 907(f) and Regulations section 1.907(f)-1 for additional information.

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(vi) U.S. income ✔ ✔ ✔ ) ( ✔ ✔ ✔ ✔ ✔ ( )
(v)
Other income*
(identify a
)
✔ ( )
✔
( )
✔
( )
✔
( )
✔
✔
✔
✔ ✔ ( )
✔
✔ ( )
✔
✔ ✔ ✔ ✔ ✔ ( )
✔
✔
(iv)
General category income
✔ ( )
✔
( )

✔
( )
✔
✔ ( )

✔
✔
✔ ✔ ( )
✔
✔ ( )
✔
✔ ✔ ✔ ✔ ( )
✔
✔ ✔
(iii)
Passive category income
✔ ( )
✔
( )
✔
✔ ( )
✔
( )
✔
✔
✔ ✔ ( )
✔
✔ ( )
✔
✔ ✔ ✔ ( )
✔
✔ ✔ ✔
(ii)
Foreign branch income
✔ ( )
✔
✔ ( )
✔
( )
✔
( )

✔
✔
✔ ✔ ( )
✔
✔ ( )
✔
✔ ✔ ( )
✔
✔ ✔ ✔ ✔
(i)
Section 951A income
✔ ✔ ( )
✔
( )
✔
( )
✔
( )
✔
✔
✔ ✔ ( )
✔
✔ ( )
✔
✔ ( )
✔
✔ ✔ ✔ ✔ ✔
**1 **
Income or (loss) before adjustments
**1 **
Income or (loss) before adjustments
**2 **
Allocation of separate limitation losses:
**a **Section 951A income **b **Foreign branch income **c **Passive category income d
General category income
**e **

Other income* (identifya
)
**3 **
**Subtotal—**Combine lines 1 through 2e.
**4 **
Allocation of overall foreign losses
**5 **
Allocation of domestic losses
**6 **
**Subtotal—**Combine lines 3 through 5.
**7 **
Recapture of overall foreign losses
**8 **
**Subtotal—**Combine lines 6 and 7.
**9 **

Recharacterization of separate limitation
income:
**a **Section 951A income **b **Foreign branch income **c **Passive category income d
General category income
**e **

Other income* (identifya
)
10
Recapture of overall domestic losses
11



Numerator of Limitation Fraction—
Combine lines 8 through 10. Enter each
result here and on Schedule B, Part II,
line 7, of corresponding Form 1118.

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(vii) Subtotal (add columns (i) through (vi))

(vi)
5th Preceding
Tax Year
(v)
6th Preceding
Tax Year
(iv)
7th Preceding
Tax Year
(iii)
8th Preceding
Tax Year
(ii)
9th Preceding
Tax Year
(i)
10th Preceding
Tax Year
-0-
Foreign Tax Carryover
Reconciliation
**1 **


Foreign tax carryover from the prior tax
year (enter amounts from the
appropriate columns of line 8 of the
prior year Schedule K (see instructions))
**2 **
Adjustments to line 1 (enter description
—see instructions):
**a **
Carryback adjustment
(see instructions)
**b **
Adjustments for section 905(c)
redeterminations (see instructions)
c d e f g **3 **
Adjusted foreign tax carryover from
prior tax year (combine lines 1 and 2)
**4 **
Foreign tax carryover used in current
tax year (enter as a negative number)
**5 **

Foreign tax carryover expired unused
in current tax year (enter as a negative
number)
**6 **
Foreign tax carryover generated in
current tax year
**7 **

Actual or estimated amount of line 6 to
be carried back to prior tax year (enter
as a negative number)
**8 **
Foreign tax carryover to the following
tax year. Combine lines 3 through 7.

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8 Foreign tax carryover to the following tax year. Combine lines 3 through 7. 7 Actual or estimated amount of line 6 to be carried back to prior tax year (enter as a negative number) 6 Foreign tax carryover generated in current tax year 5 Foreign tax carryover expired unused in current tax year (enter as a negative number) 4 Foreign tax carryover used in current tax year (enter as a negative number) 3 Adjusted foreign tax carryover from prior tax year (combine lines 1 and 2). Include the column (xiv) total on the current year Form 1118, Schedule B, Part II, line 5. g f e d c b Adjustments for section 905(c) redeterminations (see instructions) a Carryback adjustment (see instructions) 2 Adjustments to line 1 (enter description—see instructions): 1 Foreign tax carryover from the prior tax year (enter amounts from the appropriate columns of line 8 of the prior year Schedule K (see instructions)) Foreign Tax Carryover (continued) Reconciliation
(viii)
Subtotal from page 1
(enter the amounts from
column (vii) on page 1)
(ix)
4th Preceding
Tax Year
(x)
3rd Preceding
Tax Year
(xi)
2nd Preceding
Tax Year
(xii)
1st Preceding
Tax Year
(xiii)
Current
Tax Year
(xiv)
Totals
(add columns (viii)
through (xiii))

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Number, street, and room or suite no. If a P.O. box, see instructions.

City or town, state, and ZIP code

Address of service center where your tax return is filed

Type of filer (check one):

Individual Partnership Corporation Trust Estate Other 1 Individuals— Enter adjusted gross income from your tax return (see instructions) 2 Partnerships and corporations: a Partnerships—Enter each partner’s name and identifying number.

b Corporations—Enter the name and employer identification number of each member of the controlled group (as defined in

section 993(a)(3)). Do not list members included in the consolidated return; instead, attach a copy of Form 851. List all other members of the controlled group not included in the consolidated return. If you list any corporations below or if you attach Form 851, you must designate a common tax year. Enter on line 4b the name and employer identification number of the corporation whose tax year is designated.

3 Partnerships— Each partnership filing Form 5713 must give the following information: a Partnership’s total assets (see instructions) . . . . . . . . . . . . . . . b Partnership’s ordinary income (see instructions) . . . . . . . . . . . . . 4 Corporations— Each corporation filing Form 5713 must give the following information: a Type of form filed (Form 1120, 1120-FSC, 1120-IC-DISC, 1120-L, 1120-PC, etc.) . . . b Common tax year election (see instructions)

(1) Name of corporation � (2) Employer identification number . . . . . . . . . . . . . . . . . (3) Common tax year beginning, 20 , and ending , 20 . c Corporations filing this form enter:

(1) Total assets (see instructions) . . . . . . . . . . . . . . . . . . (2) Taxable income before net operating loss and special deductions (see instructions) . .

5 Estates or trusts— Enter total income (Form 1041, page 1) . . . . . . . . . 6 Enter the total amount (before reduction for boycott participation or cooperation) of the following tax benefits (see instructions): a Foreign tax credit . . . . . . . . . . . . . . . . . . . . . . . b Deferral of earnings of controlled foreign corporations . . . . . . . . . . . c Deferral of IC-DISC income . . . . . . . . . . . . . . . . . . . . d FSC exempt foreign trade income . . . . . . . . . . . . . . . . . . e Foreign trade income qualifying for the extraterritorial income exclusion . . . . . Please Under penalties of perjury, I declare that I have examined this report, including accompanying schedules and statements, and to the best of my

knowledge and belief, it is true, correct, and complete.

Sign Here

Signature Date Title

For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 12030E Form 5713 (Rev. 12-2010)

Under penalties of perjury, I declare that I have examined this report, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete.

Signature Date

581 International Return Study

Form 5713 (Rev. 12-2010) Page 2

Form 5713 (Rev. 12-2010)

582 International Return Study

Form 5713 (Rev. 12-2010) Page 3 Yes No 9 Nonlisted countries boycotting Israel— Did you have operations in any nonlisted country which you know or have reason to know requires participation in or cooperation with an international boycott directed against Israel? If “Yes,” complete the following table. If more space is needed, attach additional sheets using the exact format and check

If “Yes,” complete the following table. If more space is needed, attach additional sheets using the exact format and check

If “Yes,” attach a copy (in English) of any and all boycott clauses agreed to, and attach a general statement of the agreement. If the agreement was in a form other than a written agreement, attach a separate sheet explaining the nature and form of any and all such agreements. (See instructions.) Note: If the answer to either question 11 or 12 is “Yes,” you must complete the rest of Form 5713. If you answered “Yes” to question 12, you must complete Schedules A and C or B and C (Form 5713).

Form 5713 (Rev. 12-2010)

✔

✔

583 International Return Study

Form 5713 (Rev. 12-2010) Page 4

b Requests and agreements— if the answer to any part of 13a is “Yes,” complete the following table. If more space is

584 International Return Study

Statement of Withholding on

Copy A

For Internal

Revenue Service Center

For Privacy Act and Paperwork Reduction Act Notice,

see the Instructions

for Form 8288.

WITHHOLDING AGENT’S name, street address, city or town, state or
province, country, ZIP or foreign postal code, and phone no.
1 Date of transfer
(mm/dd/yyyy)
/ /
OMB No. 1545-0902
8288-A
Form
(Rev. January 2023)
WITHHOLDING AGENT’S name, street address, city or town, state or
province, country, ZIP or foreign postal code, and phone no.
WITHHOLDING AGENT’S name, street address, city or town, state or
province, country, ZIP or foreign postal code, and phone no.
2 Gain recognized by
foreign corporation
$
2 Gain recognized by
foreign corporation
$
WITHHOLDING AGENT’S U.S. TIN U.S. TIN of FOREIGN PERSON subject
to withholding (see instructions)
3 Amount realized
$
4 Federal income tax
withheld
$
FOREIGN PERSON’S name subject to withholding FOREIGN PERSON’S name subject to withholding 5Withholding under
section:
a1445
b 1446(f)(1)
6FOREIGN PERSON
subject to withholding:
a Individual
b Corporation
c Partnership
d Other
(specify)
Foreign address (number, street, and apt. or suite no.)
City or town, state or province, country (not U.S.), and ZIP or foreign postal code City or town, state or province, country (not U.S.), and ZIP or foreign postal code 7 Country code of FOREIGN
PERSON subject to withholding
7 Country code of FOREIGN
PERSON subject to withholding
Mailing address of FOREIGN PERSON subject to withholding (if different) Mailing address of FOREIGN PERSON subject to withholding (if different) 8 Description of property transferred 8 Description of property transferred

Form 8288-A (Rev. 1-2023)

Cat. No. 62261L

Attach Copies A and B to Form 8288

Department of the Treasury - Internal Revenue Service

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586 International Return Study

1 Type of election (see instructions):

2 a Has the eligible entity previously filed an entity election that had an effective date within the last 60 months?

Yes. Go to line 2b. No. Skip line 2b and go to line 3.

2 b Was the eligible entity’s prior election an initial classification election by a newly formed entity that was effective on the date of formation?

Yes. Go to line 3. No. Stop here. You generally are not currently eligible to make the election (see instructions).

3 Does the eligible entity have more than one owner?

Yes. You can elect to be classified as a partnership or an association taxable as a corporation. Skip line 4 and go to line 5.

No. You can elect to be classified as an association taxable as a corporation or to be disregarded as a separate entity. Go to line 4.

4 If the eligible entity has only one owner, provide the following information:

a Name of owner �

5 If the eligible entity is owned by one or more affiliated corporations that file a consolidated return, provide the name and employer identification number of the parent corporation:

a Name of parent corporation �

For Paperwork Reduction Act Notice, see instructions. Cat. No. 22598R Form 8832 (Rev. 12-2013)

587 International Return Study

Form 8832 (Rev. 12-2013) Page 2 Part I Election Information (Continued) 6 T ype of entity (see instructions):

a A domestic eligible entity electing to be classified as an association taxable as a corporation. b A domestic eligible entity electing to be classified as a partnership. c A domestic eligible entity with a single owner electing to be disregarded as a separate entity. d A foreign eligible entity electing to be classified as an association taxable as a corporation. e A foreign eligible entity electing to be classified as a partnership. f A foreign eligible entity with a single owner electing to be disregarded as a separate entity.

7 If the eligible entity is created or organized in a foreign jurisdiction, provide the foreign country of organization �

8 Election is to be effective beginning (month, day, year) (see instructions) . . . . . . . . . . . . �

9 Name and title of contact person whom the IRS may call for more information 10 Contact person’s telephone number

Consent Statement and Signature(s) (see instructions)

Under penalties of perjury, I (we) declare that I (we) consent to the election of the above-named entity to be classified as indicated above, and that I (we) have examined this election and consent statement, and to the best of my (our) knowledge and belief, this election and consent statement are true, correct, and complete. If I am an officer, manager, or member signing for the entity, I further declare under penalties of perjury that I am authorized to make the election on its behalf.

Signature(s) Date Title

Form 8832 (Rev. 12-2013)

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589 International Return Study

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591 International Return Study

Form 8991 (Rev. 12-2024) Page 2

6 Does the taxpayer elect to use financial statements per Regulations section 1.59A-3(b)(4)(i)(D) for purposes of calculating interest expense allocable to a foreign corporation’s effectively connected income? . . . Yes No 7 In the current year, did the taxpayer capitalize to inventory, or include in cost of goods sold (COGS), costs for any payment to a related foreign party that the taxpayer treated as a deduction in any prior tax year? . Yes No 8 If “Yes” for line 7, enter the following:

(i) (ii) (iii) (iv)

Amount Capitalized Line Item Reported Description of Item or Included in COGS on in Prior Year

Tax Year Form 3115 Was Filed

Form 8991 (Rev. 12-2024)

a b c

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(Check all applicable boxes in columns (c), (d), and (e) below) (e) Any Person Related Within the Meaning of Section 482 to the Taxpayer
(Check all applicable boxes in
columns (c), (d), and (e) below)
(d) Person Related
Under Section
267(b) or
707(b)(1) to the
Taxpayer or Any
25% Owner of
the Taxpayer
(Check all applicable boxes in
columns (c), (d), and (e) below)
(c) Any 25%
Owner of
the Taxpayer
(a-1)
(a-2)
(b-1)
(b-2)
(b-2) Taxpayer’s Base
Erosion Tax
Benefits
(a-1)
(a-2)
(b-1)
(b-2)
(b-1) Taxpayer’s Base
Erosion Payments
(a-1)
(a-2)
(b-1)
(b-2)
(a-2) Aggregate
Group’s Base
Erosion Tax
Benefits
(a-1)
(a-2)
(b-1)
(b-2)
(a-1) Aggregate
Group’s Base
Erosion Payments
(a-1)
(a-2)
(b-1)
(b-2)
(a-1) Type of Base Erosion Payments 1
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
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.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
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4
Rents, royalties, and license fees .
.
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.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
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1
Reserved for future use .
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2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
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.
.
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.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
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4
Rents, royalties, and license fees .
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.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
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.
1
Reserved for future use .
.
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.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
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.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
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.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
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.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
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.
1
Reserved for future use .
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.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
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.
.
.
.
.
4
Rents, royalties, and license fees .
.
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.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
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.
1
Reserved for future use .
.
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.
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.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
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.
.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
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.
.
.
.
.
.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
Reserved for future use .
.
.
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.
.
.
.
.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
.
.
.
.
.
.
.
.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
.
.
.
.
.
.
.
.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
.
.
.
.
.
.
.
.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
1
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
2
Cost sharing transaction payments as defined in Regulations
section 1.482-7(b)(1)(i) .
.
.
.
.
.
.
.
.
.
.
.
.
.
3 Purchase or creations of property rights for intangibles (patents,
trademarks, etc.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
4
Rents, royalties, and license fees .
.
.
.
.
.
.
.
.
.
.
5aCompensation/consideration paid for services
NOT
excepted by
Regulations section 1.59A-3(b)(3)(i) .
.
.
.
.
.
.
.
.
.
**b **Compensation/consideration paid for services excepted by
Regulations section 1.59A-3(b)(3)(i)
.
.
.
$
6
Interest expense
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
7
Payments for the purchase of tangible personal property .
.
.
**8 **

Premiums and/or other considerations paid or accrued for
insurance and reinsurance as covered by Regulations section
1.59A-3(b)(1)(iii)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

593 International Return Study

9a Nonqualified derivative payments . . . . . . . . . . b Qualified derivative payments excepted by Regulations section 1.59A-6(b) . . . . . . . . . . . $ 10 Payments reducing gross receipts made to surrogate foreign corporation . . . . . . . . . . . . . . . . . . 11 Other payments—specify . . . . . . . . . . . . . 12 Combine lines 2 through 11 . . . . . . . . . . . . 13 Base erosion tax benefits related to payments reported on lines 2 through 11, on which tax is imposed by section 871, 881, or 884(f), with respect to which tax has been withheld under section 1441 or 1442 at 30% statutory withholding tax rate or subject to tax under Regulations section 1.884-4(a)(2)(ii) at a 30% statutory rate (see instructions) . . . . . . . . . 14 Portion of base erosion tax benefits reported on lines 2 through 11, on which tax is imposed by section 871 or 881, with respect to which tax has been withheld under section 1441 or 1442 at reduced withholding rate pursuant to income tax treaty or subject to a reduced rate of tax under Regulations section 1.884-4(a)(2)(ii). Multiply the amount of the base erosion tax benefit by a fraction equal to the rate of tax imposed under the treaty over the 30% (0.30) statutory rate. See instructions. . . 15 Total base erosion tax benefits. Subtract the sum of line 13 and line 14 from line 12. Enter the amount from column (a-2) on Part I, line 2a. Enter the amount from column (b-2) on Part II, line 3b Type of Base Erosion Payments (a-1) (a-2) (b-1) (b-2)
Aggregate
Group’s Base
Erosion Payments
(a-1) (a-1)
Aggregate
Group’s Base
Erosion Tax
Benefits
(a-2) (a-2)
Taxpayer’s Base
Erosion Payments
(b-1) (b-1)
Taxpayer’s Base
Erosion Tax
Benefits
(b-2) (b-2)
Any 25%
Owner of
the Taxpayer
(c) (Check all applicable boxes in
columns (c), (d), and (e) below)
Person Related
Under Section
267(b) or
707(b)(1) to the
Taxpayer or Any
25% Owner of
the Taxpayer
(d) (d)


Any Person
Related Within
the Meaning of
Section 482
to the Taxpayer
(e) (e)

594 International Return Study

(i) Amount of deduction being waived for the tax year with respect to the item or property


(h)
Amount of
deduction claimed
for the tax year
with respect to the
item or property

(g)
Country of
organization of
the foreign
related party

(f)
Taxpayer
identification
number of foreign
related party


(e)
Name of foreign
related party that
is or will be the
recipient of the
payment that
generates the
deduction

(d)
Line number on
the controlled
group member tax
return where the
deduction is
reported

(c)
Provision of Code
and regulations,
as applicable, that
allows the
deduction for
which this
election relates

(b)
Date on which, or
period in which,
the waived
deduction was
paid or accrued
(a)
Description of item or property to which the
deduction relates
(a)
Description of item or property to which the
deduction relates
1 2 3 4 5 6 7 8 9 10 11 12 13 13 13

595 International Return Study

Form 8991 (Rev. 12-2024) Page 6

Form 8991 (Rev. 12-2024)

596 International Return Study

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▸Contents — Publication 5384 — Statistics of Income Program Documentation: Data Items by Forms and Schedules, Program Year 2024

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