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2025›Notice 2023-80, 2023-52 I.R.B. 1583, available at›Specific Instructions

Part I—Taxable Income or Loss From Sources Outside the United States

2025 Inst 1116 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States

Caution: Part I must be completed by all filers unless specifically indicated otherwise in these instructions.

Line i—Foreign Country or U.S. Territory Generally, if you received income from, or paid taxes to, more than one foreign country or U.S. territory, report information on a country-by-country basis on Form 1116, Parts I and II. Use a separate column in Part I and a separate line in Part II for each country or territory. If you paid taxes to more than three countries or territories, attach additional sheets following the format of Parts I and II.

Foreign tax credit splitting event. If you had a foreign tax credit splitting event in a previous year and you are taking the related income into account in 2025, enter “909 income” on line i for that income instead of the country or territory name.

Section 863(b) gross income and deductions. You don’t need to report section 863(b) income (certain income from services or inventory that is partly from U.S. source and partly from foreign source) on a per-country basis. Total all section 863(b) foreign source income in the applicable category and

enter the total in a single column in Part I. Enter “863(b)” on line i. Total all section 863(b) deductions in the applicable category and in the same column enter the totals on lines 2 through 6. Total all foreign taxes imposed on section 863(b) income and enter the total on a single line in Part II for the applicable category.

Regulated investment company (RIC) pass-through amounts. You don’t need to report income passed through from a mutual fund or other RIC on a country-by-country basis. Total all income, in the applicable category, passed through from the mutual fund or other RIC and enter the total in a single column in Part I. Enter “RIC” on line i. Total all foreign taxes passed through and enter the total on a single line in Part II for the applicable category.

Inclusions under section 951A. Because computations for inclusions under section 951A are reported on separate Forms 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income, you don’t need to report those inclusions on a country-by-country basis. Enter the total inclusion in a single column in Part l and enter “951A” on line i.

High-taxed income. Passive income doesn’t include high-taxed income. High-taxed income is income if the foreign taxes you paid on the income (after allocation of expenses) exceed the highest U.S. tax that can be imposed on the income. See Regulations section 1.904-4(c) for more information. If you have passive income that is high-taxed income, use a separate column in Part I. Enter “HTKO” on line i of Forms 1116 for passive category income and the other category of income to which such passive category income is reclassified. On your Form 1116 for passive category income, passive income that is treated as another category of income because it is high taxed should be included on line 1a in the column for the country entered on line i. Also, enter the high-taxed income in the “HTKO” column on line 1a as a negative number. On your Form 1116 for the other category of income, the high-taxed income should be entered as a positive number on line 1a in the “HTKO” column. Don’t enter any amounts on lines 2 through 5 for your “HTKO” column. Add all deductions that are definitely related or apportioned to passive income that is treated as another category of income because it is high taxed and enter the total amount of those deductions on line 6 in the appropriate “HTKO” column. Enter the amount as a negative number in the “HTKO” column on your Form 1116 for passive category income. Enter the amount as a positive number in the “HTKO” column on your Form 1116 for the other category of income. See the instructions for line 13, later.

Lines 1a and 1b—Foreign Gross Income Include income in the category checked above Part I that is taxable by the United States and is from sources within the country entered on line i, even if isn’t taxable by that foreign country. Identify the type of income on the dotted line next to line 1a. Don’t include any earned income excluded on Form 2555, Foreign Earned Income.

Example. If you received dividends (passive category income) and wages (general category income) from foreign sources, you must complete two Forms 1116. On one Form 1116, check box c (passive category income), enter the dividends on line 1a, and enter “Dividends” on the dotted line. On the other Form 1116, check box d (general category income), enter on line 1a wages not excluded on Form 2555,

Instructions for Form 1116 (2025) 11

Worksheet A (See instructions.) Keep for Your Records

Category #1 Category #2

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