Schedule D

Report taxes deemed paid under section 960(d) with respect to inclusions under section 951A. This schedule should only be completed with respect to the Form 1118 filed for the section 951A category, and, in rare cases, the passive category.

Schedule D is generally completed by a domestic corporation that owns, within the meaning of section 958(a), stock in one or more CFCs that claims taxes deemed paid with respect to inclusions under section 951A.

Schedule D is also generally completed by an individual (or an estate or trust) that has made an election under section 962 (“section 962 elector”).

If more than one line is needed in Part II:

• In Part II, column 2, the same denominator will be used (the Part I, column 5 total) in the inclusion percentage calculation for each line; and

• In Part II, column 3, the same multiplication factor will be used (the Part I, column 9 total) for each line.

If more than one line is completed in Part II, the column 4 amounts should be summed and included on a single line on Form 1118, Schedule B, Part I, column 3 (that is, the line on Schedule B, Part I, column 3, that corresponds with the line in Schedule A with “951A” in column 2 of Schedule A).

Part I—Foreign Corporation’s Tested Income and Foreign Taxes

Column 1a. Enter the name of each CFC that has tested income, as defined in section 951A(c)(2)(A). Do not report information of CFCs with tested losses, as defined in section 951A(c)(2)(B).

Column 1b. Enter the EIN or reference ID number of the foreign corporation. See Reference ID numbers, earlier.

Note: Taxpayers no longer have the option of entering “FOREIGNUS” or “APPLIED FOR” in this column. Instead, if the foreign corporation does not have an EIN, the taxpayer must use a reference ID number that uniquely identifies such foreign corporation, using the rules set forth in Reference ID numbers , in the Requirements section, earlier.

Column 2. Enter the year and month in which the CFC’s U.S. tax year ended using the format YYYYMM.

Column 3. Enter the applicable two-letter code from the list at IRS.gov/CountryCodes .

Column 4. Enter the applicable three-character alphabet code for the foreign corporation’s functional currency using the ISO 4217 standard.

Column 5. Enter the U.S. shareholder’s pro rata share of the CFC’s tested income from the applicable Form 8992 schedule. If the U.S. shareholder is not a member of a U.S. consolidated group, enter the amount reported in Schedule A (Form 8992), column (e), for the CFC. If the U.S. shareholder is a member of a U.S. consolidated group, enter the amount reported with respect to that U.S. shareholder in Schedule B (Form 8992), Part I, column (g), for the CFC.

If the domestic corporation is a partner in a partnership, enter the domestic corporate partner’s pro rata share of CFC tested income from Schedule K-3, Part VIII, line 3.

Column 6. Enter the CFC’s tested income from the applicable Form 8992 schedule. If the U.S. shareholder is not a member of a U.S. consolidated group, enter the amount reported in Schedule A (Form 8992), column (c), for the CFC. If the U.S. shareholder is a member of a U.S. consolidated group, enter the amount reported with respect to that U.S. shareholder in Schedule B (Form 8992), Part I, column (e), for the CFC.

Column 8. Enter the CFC’s tested foreign income taxes from Schedule Q (Form 5471), line 3, column (xii).

Column 9. Enter the pro rata share of tested foreign income taxes paid or accrued by the CFC. To determine this amount, multiply the amount in column 7 by the amount in column 8.

Note: See the instructions for Schedule G, later, for information on reduction of foreign taxes for failure to furnish information required under section 6038.

Part II—Foreign Income Tax Deemed Paid Note: While multiple line entries may be necessary for Schedule D, Part I, because such lines are completed for each CFC, in general, only one line will be completed in Schedule D, Part II, because the domestic corporation filing Form 1118 only has one section 951A inclusion. However, there is an exception if Form 1118 is completed by an individual (or by an estate or trust) that has made an election under section 962 (“section 962 elector”) and the section 962 elector is a shareholder of an S corporation that has made an election to treat the S corporation as an entity (rather than as an aggregate of its owners), as provided in Notice 2020-69 , 2020-39 I.R.B. 604, on a timely (including extensions) filed original Form 1120-S with respect to the first tax year ending on or after

18 Instructions for Form 1118 (Rev. 12-2025)

September 1, 2020. In this case, the section 962 elector may have more than one section 951A inclusion that will be reported on separate lines on Schedule D, Part II. There might be multiple lines as a result of (1) the section 962 elector’s section 951A inclusion, and (2) the section 962 elector’s share of the section 951A inclusion of the S corporation. There could also be multiple lines if the section 962 elector has an interest in more than one S corporation.

Column 1. Enter the GILTI (that is, the section 951A inclusion) from Form 8992, Part II, line 5.

Column 3. This amount as determined on this line is the section 78 gross-up with respect to an inclusion under section 951A which is reported on Form 1118, Schedule A, column 3(b).