Form 1120-F — U.S. Income Tax Return of a Foreign Corporation

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/f1120f.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

---

A Country of incorporation

B Foreign country under whose laws the income reported on this return is also subject to tax

C ^{Date incorporated}

D (1) Location of corporation’s primary books and records (city, province

or state, and country)

(2) Principal location of worldwide business

E If the corporation had an agent in the United States at any time during

the tax year, enter:

(1) Type of agent (2) Name (3) Address

F See the instructions and enter the corporation’s principal:

(1) Business activity code number

(2) Business activity

(3) Product or service

Form 1120-F (2025) Page 2 Additional Information (continued from page 1)

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

|H
Did the corporation’s method of accounting change from the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
I
Did the corporation’s method of determining income change from the preceding tax year? .
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement with an explanation.
J
Did the corporation file a U.S. income tax return for the preceding tax year?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
K
**(1)At any time during the tax year, was the corporation engaged in a trade or business in the United States?
.
.
.
.
.
.
(2)If the answer to question K(1) is “Yes,” is the corporation’s trade or business within the United States solely the result of a
section 897 (FIRPTA) sale or disposition?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(3)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(i) or section 864(b)(2)(B)(i)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(3) is “Yes,” enter the name of the resident broker, commission agent, custodian, or other independent agent
who effects transactions in stocks and securities in the United States on the corporations’s behalf:
(4)If the answer to question K(1) is “No,” was the corporation engaged in the trading of securities or commodities described in
section 864(b)(2)(A)(ii) or section 864(b)(2)(B)(ii)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If the answer to question K(4) is “Yes,” enter the name of any resident broker, commission agent, custodian, or other agent who
effects transactions in stocks and securities in the United States on the corporation’s behalf:
If the answer to question K(4) is “Yes,” enter the name of any partnership that effects transactions in the United States in securities or
commodities (either directly or through an employee, broker, commission agent, custodian, or other agent) in which the corporation is
a partner:
L
Did the corporation have a permanent establishment in the United States for purposes of any applicable tax treaty between the
United States and a foreign country? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the name of the foreign country:
M
Did the corporation have any transactions with related parties? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” Form 5472 may have to be filed (see instructions).
Enter number of Forms 5472 attached
N
Is the corporation a controlled foreign corporation? (See section 957(a) for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
O
Is the corporation a personal service corporation? (See instructions for definition.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P
Enter tax-exempt interest received or accrued during the tax year (see instructions) $
Q
At the end of the tax year, did the corporation own, directly or indirectly, 50% or more of the voting stock of a U.S. corporation?
(See section 267(c) for rules of attribution.) .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing (1) name and EIN of such U.S. corporation; (2) percentage owned; and (3) taxable income or
(loss) before NOL and special deductions of such U.S. corporation for the tax year ending with or within your tax year.
R
If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here (see instructions)
.
S
Enter the available NOL carryover from prior tax years. (Do not reduce it by any deduction on Section II, line 30a, page 5.) $
T
Is the corporation a subsidiary in a parent-subsidiary controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the parent corporation’s:
(1) EIN
(2) Name
U
(1)Is the corporation a dealer under section 475? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)**Did the corporation mark to market any securities or commodities other than in a dealer capacity?
.
.
.
.
.
.
.
.
V
At the end of the tax year, did any individual, partnership, corporation, estate, or trust own, directly or indirectly, 50% or more of
the corporation’s voting stock? (See section 267(c) for rules of attribution.)
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement showing the name and identifying number. (Do not include any information already entered in itemT.)
Enter percentage owned
**W
(1)**Is the corporation taking a position on this return that a U.S. tax treaty overrules or modifies an Internal Revenue law of the
United States, thereby causing a reduction of tax? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” the corporation is generally required to complete and attach Form 8833. See Form 8833 for exceptions.

Note:Failure to disclose a treaty-based return position may result in a $10,000 penalty (see section 6712).
**(2)**Is the corporation claiming treaty benefits pursuant to, or otherwise filing its return pursuant to, a Competent Authority
determination or an Advance Pricing Agreement? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to your return.
|||

Form 1120-F (2025) Page 3 Additional Information (continued from page 2)

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

|X
During the tax year, did the corporation own any entity that was disregarded as an entity separate from its owner under
Regulations sections 301.7701-2 and 301.7701-3?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach a statement listing the name, country under whose laws the entity was organized, and EIN (if any) of each such
entity.
Y
(1) Did a partnership allocate to the corporation a distributive share of income from a directly owned partnership interest, any of
which is ECI or treated as ECI by the partnership or the partner?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(2) During the tax year, did the corporation dispose of an interest in a partnership that directly or indirectly engaged in a trade or
business in the United States?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule P (Form 1120-F). See instructions.
(3) During the tax year, did the corporation own, directly or indirectly, at least a 10% interest, in any foreign partnership? .
.
.
Z
(1)Has the corporation engaged in any transactions the results of which are subject to the arm’s-length standard under section
482 and its regulations?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
(2)Has the corporation recognized any interbranch amounts? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach statement (see instructions).
AA
Is the corporation required to file Schedule UTP (Form 1120), Uncertain Tax Position Statement (see instructions)? .
.
.
.
.
If “Yes,” complete and attach Schedule UTP.
BB
During the corporation’s tax year, did the corporation make any payments that would require it to file Forms 1042 and 1042-S
under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474) of the Code?
.
.
.
.
.
.
.
.
CC
Is the corporation (including the home office or any branch) a qualified derivatives dealer (QDD)? .
.
.
.
.
.
.
.
.
.

(1)If “Yes,” attach Schedule Q (Form 1120-F) (see instructions).
(2) If “Yes,” enter the QI-EIN
DD
Does the corporation have gross receipts of at least $500 million in any of the 3 preceding tax years (see sections 59A(e)(2) and
(3))?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8991.
EE
During the tax year, did the corporation pay or accrue any interest or royalty for which a deduction is not allowed under section
267A (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” enter the total amount of the disallowed deductions .
.
.
.
.
.
. $
FF
Did the corporation have an election under section 163(j) for any real property trade or business or any farming business in effect
during the tax year (see instructions)?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
GG
Does the corporation satisfyone or moreof the following (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
**(1)The corporation owns a pass-through entity with current, or prior year carryover, excess business interest expense.
(2)The corporation’s aggregate average annual gross receipts (determined under section 448(c)) for the 3 tax years preceding the
current tax year are more than $31 million and the corporation has business interest expense.
(3)The corporation is a tax shelter and the corporation has business interest expense.
If “Yes,” to any, complete and attach Form 8990.
HH
Does the corporation intend to self-certify as a Qualified Opportunity Fund?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 8996. Enter the amount (if any) from Form 8996, line 15 $
II
Is the corporation a member of a controlled group?
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” attach Schedule O (Form 1120). See instructions.
JJ
Corporate Alternative Minimum Tax:
(1)Was the corporation an applicable corporation under section 59(k)(1) in any prior tax year? .
.
.
.
.
.
.
.
.
.
.
If “Yes,” go to question JJ(2).
If “No,” skip to question JJ(3).
(2)Is the corporation an applicable corporation under section 59(k)(1) in the current tax year because the corporation was an
applicable corporation in the prior tax year? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
If “Yes,” complete and attach Form 4626.
If “No,” continue to question JJ(3).
(3)**Does the corporation meet the requirements of the safe harbor method as provided under section 59(k)(3)(A) for the current tax
year (see instructions)? .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

If “Yes,” the corporation is not required to file Form 4626.
If “No,” complete and attach Form 4626.
KK
Reserved for future use .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
|||

Form 1120-F (2025) Page 4 SECTION I—Income From U.S. Sources Not Effectively Connected With the Conduct of a Trade or Business in the United States— Do not report items properly withheld and reported on Form 1042-S. See instructions. Report all gross transportation income subject to 4% tax on line 9. Report other column (a) income items only if not properly withheld and reported on Form 1042-S. The rate of tax on these gross income items is 30% or such lower rate specified by tax treaty. No deductions are allowed against these types of income. Enter treaty rates where applicable. If the corporation is claiming a lower treaty rate, also complete item W on page 2. If multiple treaty rates apply to a type of income (for example, subsidiary and portfolio dividends or dividends received by disregarded entities), attach a statement showing the amounts, tax rates, and withholding for each. For any amounts reported in this Section I, you must attach Form(s) 1042-S to substantiate any withholding claimed on line 5i, page 1, related to these amounts.

13 Is the corporation fiscally transparent under the laws of the foreign jurisdiction with respect to any item of income listed above? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

If “Yes,” attach a statement that provides the information requested above with respect to each such item of income.

Form 1120-F (2025)

Form 1120-F (2025) Page 5 SECTION II—Income Effectively Connected With the Conduct of a Trade or Business in the United States (see instructions)

Form 1120-F (2025) Page 6

Form 1120-F (2025) Page 7 SECTION III—Branch Profits Tax and Tax on Excess Interest Part I—Branch Profits Tax (see instructions)

Form 1120-F (2025) Page 8 Note: Check if completing on U.S. basis or Worldwide basis Schedule L Balance Sheets per Books

Form 1120-F (2025) Page 9