Schedule E

Report taxes paid, accrued, and deemed paid by the domestic corporation under section 901 and 960(b) with respect to PTEP distributions. Foreign withholding taxes levied on a domestic corporation as a result of distributions of PTEP from a first-tier foreign corporation to such domestic corporation are reported on Schedule E, Part I, column 14. Such taxes are also reported on Schedule B, Part I, column 2(b)(1), as tax withheld on distributions of PTEP. Also, reported on this schedule are foreign income taxes levied on distributions of PTEP from a lower-tier foreign corporation to an upper-tier foreign corporation which are subsequently deemed paid under section 960(b)(1) by the domestic corporation upon distribution of such PTEP by the upper-tier foreign corporation to the domestic corporation.

Part I—Taxes Paid, Accrued, and Deemed Paid by Domestic Corporation

Column 1a. Enter the name of each first-tier foreign corporation that made PTEP distributions to a domestic corporation with respect to which foreign income taxes were paid, accrued, or deemed paid by the domestic corporation (and that were not previously deemed paid by a domestic corporation). For distributions of PTEP that originated in lower-tier foreign corporations, enter a unique alphabetic character before the name of the distributing foreign corporation to identify the source of the PTEP distribution. See the instructions for Part II, column 1a, for more information, including an example.

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 for the U.S. tax year of the first-tier foreign corporation in which the first-tier foreign corporation made the PTEP distribution to the domestic corporation. Use the format YYYYMM. If there is a PTEP distribution related to more than one PTEP group

within an annual PTEP account, complete a separate line for each PTEP group within an annual PTEP account. See Regulations section 1.960-3(c)(2).

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

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

Column 5. Enter the code which describes the PTEP group classification (as set forth in Regulations section

Column 6. Enter the inclusion year for the PTEP of the foreign corporation to which section 951(a) and section 951A inclusion amounts of U.S. shareholders are attributable. This is the annual PTEP account. See Regulations section 1.960-3(c)(1).

Column 7. Enter the total amount of the foreign corporation’s PTEP in the PTEP group within an annual PTEP account identified in columns 5 and 6. Enter the amount in the functional currency of the first-tier foreign corporation.

Column 8. Enter the total amount of the foreign corporations’ PTEP group taxes with respect to the PTEP group within the annual PTEP account identified in columns 5 and 6. Enter the amount in U.S. dollars.

Column 9. Enter the PTEP distribution from the PTEP group within the annual PTEP account identified in columns 5 and 6 in the functional currency of the first-tier foreign corporation. If there is a PTEP distribution related to more than one PTEP group within an annual PTEP account, complete a separate line for each PTEP group within an annual PTEP account.

Column 11. For each line, multiply the amount in column 8 by the amount in column 10. This is the U.S. dollar amount of the foreign income taxes properly attributable to the PTEP distribution reported in column 9 and not deemed to have been paid by the domestic corporation for the tax year or any prior tax year.

Note: With respect to distributions of PTEP resulting from inclusions under section 965, or section 951A, report the

Instructions for Form 1118 (Rev. 12-2025) 19

foreign income taxes properly attributable to such PTEP under section 960(b)(1) without reduction for the foreign tax credit disallowance under sections 965(g) and 960(d) (4), as applicable. The disallowance is taken into account in columns 12 and 13 and Schedule G. See the specific instructions for Schedule G, later.

Column 12. Report the amount disallowed under the section 965(g) applicable percentage with respect to the taxes deemed paid under section 960(b)(1) identified in column 11.

Column 13. Report the amount disallowed under section 960(d)(4) with respect to the taxes deemed paid under section 960(b)(1) identified in column 11.

Column 14. Report the foreign income taxes paid or accrued with respect to distributions of PTEP from a first-tier foreign corporation to a domestic corporation that are creditable under section 901. For each line in Schedule E, Part I, also include the column 14 amount in column 2(b)(1) of the line in Schedule B, Part I, that corresponds with the identifying number specified in column 1(a) of Schedule A and that also corresponds with the identifying number specified in column 1b of this Schedule E, Part I.

Note: With respect to distributions of PTEP resulting from inclusions under section 965 or section 951A, report the foreign income taxes paid or accrued with respect to such PTEP distributions (that are creditable under section 901) without reduction for the foreign tax credit disallowance under sections 965(g) and 960(d)(4), as applicable. The disallowance is taken into account in columns 15 and 16 and Schedule G. See the specific instructions for Schedule G, later.

Column 15. Report the amount disallowed under the section 965(g) applicable percentage with respect to the taxes paid or accrued under section 901 identified in column 14.

Column 16. Report the amount disallowed under section 960(d)(4) with respect to the taxes paid or accrued under section 901 identified in column 14.

Note: The totals reported for columns 12 and 15 with respect to the section 965(g) disallowance are reported on Schedule G, line F. The totals reported for columns 13 and 16 with respect to the section 960(d)(4) disallowance are reported on Schedule G, line H.

Part II—Tax Deemed Paid by First- and Lower-Tier Foreign Corporations The purpose of Part II is to track the current-year and historical PTEP distributions between foreign corporations and taxes paid, accrued, or deemed paid by upper-tier foreign corporations on such PTEP distributions. These amounts are to be reported on this Part II only to the extent that there is a PTEP distribution to the domestic corporation entered in Part I. The amounts entered in Part II could relate to current-year or prior-year PTEP distributions between foreign corporations, so the applicable year should be noted in column 2 using the format YYYYMM.

If foreign income taxes paid, accrued, or deemed paid by a first-tier foreign corporation are properly attributable to a PTEP distribution from one or more lower-tier foreign corporations, report all such PTEP distributions by the lower-tier foreign corporations in Part II, even if the distributing lower-tier foreign corporations did not pay or accrue (and were not deemed to pay) any foreign income taxes with respect to the PTEP distributions. For each tier, report the amount of the PTEP distribution from the first-tier foreign corporation that is attributable to a PTEP distribution from the lower-tier foreign corporation and the amount of foreign income taxes paid, accrued, or deemed paid by that lower-tier foreign corporation with respect to that portion of the PTEP distribution. Because only eligible current-year tax paid or accrued by a CFC with respect to its receipt of a PTEP distribution from a lower-tier foreign corporation is eligible to be treated as deemed paid under section 960(b), no foreign income taxes of the lowest-tier foreign corporation to which the PTEP distribution is attributable are properly attributable to a PTEP distribution made to an upper-tier foreign corporation. See Regulations section 1.960-1(d)(3)(ii)(C).

Column 1a. Enter the name of each lower-tier foreign corporation that distributed PTEP to an upper-tier foreign corporation, in the current year or a prior year, that in turn was distributed in the current year to a domestic corporation. In column 1a, preceding the name of the distributing lower-tier foreign corporation, enter a unique alphabetic character that corresponds to a PTEP distribution reported in Part I. For example, in the case of a PTEP distribution from CFC3, third-tier foreign corporation, to CFC2, second-tier foreign corporation, to CFC1, first-tier foreign corporation, to USP, a domestic corporation, the domestic corporation correlates the distributions as follows.

Part I, column 1a. Enter “A CFC1” (to report distribution from CFC1 to domestic corporation sourced from PTEP distributions from CFC2 and CFC3).

Part II, column 1a. Enter “A CFC2” (to report distribution from CFC2 to CFC1), and enter “A CFC3” (to report distribution from CFC3 to CFC2).

Column 1b. Enter the EIN or reference ID number of the distributing 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 distributing 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 U.S. tax year of the distributing foreign corporation which includes the date when the foreign corporation distributed the PTEP to the upper-tier foreign corporation.

Note: If the PTEP distributed in Part I relates to PTEP distributions from lower-tier foreign corporations made in more than one tax year, figure and show the tax deemed paid on a separate line for each distribution.

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

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

Column 4b. Enter the EIN or reference ID number of the recipient 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 recipient 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 5. Enter the U.S. tax year of the recipient foreign corporation which includes the date the foreign corporation received the PTEP distribution.

Column 6. Enter the applicable two-letter code from the list at IRS.gov/CountryCodes .

Column 7. Enter the applicable three-character alphabetic code for the distributing foreign corporation’s functional currency using the ISO 4217 standard.

Column 8. Enter the applicable PTEP group code from the list provided in the specific instructions for Schedule E, Part I, column 5, earlier.

Column 9. Enter the annual PTEP account. See the instructions for Schedule E, Part I, column 6, earlier.

Column 10. Enter the total amount of the foreign corporation’s PTEP in the PTEP group within the annual PTEP account identified in column 8 and column 9. Enter such amount in the functional currency of the distributing foreign corporation.

Column 11. Enter the total amount of the foreign corporation’s PTEP group taxes with respect to the PTEP group within the annual PTEP account identified in column 8 and column 9. Enter this amount in U.S. dollars. To determine the appropriate translation rate, see section 986(a).

Column 12. Enter the PTEP distribution with respect to the PTEP group within the annual PTEP account identified in columns 8 and 9 in the functional currency of the distributing foreign corporation. If there is a PTEP distribution related to more than one PTEP group within an annual PTEP account, complete a separate line for each PTEP group within an annual PTEP account. Only report the amount of PTEP attributable to the PTEP that was ultimately distributed to the domestic corporation in the current year, even if the amount of PTEP distributed to the upper-tier foreign corporation was greater than that amount.

Column 14. Enter the U.S. dollar amount of the recipient foreign corporation’s income taxes paid, accrued, and deemed paid that are properly attributable to the PTEP distribution reported in column 12 and not deemed to have been paid by the domestic corporation for any prior tax year.

Note: See the Note in the instructions for Part I, column 11, for purposes of reporting foreign income taxes

properly attributable to PTEP distributions resulting from inclusions under section 965 or section 951A.

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

Example 1. USC, a domestic corporation, wholly owns CFC1, a Country Y corporation, which wholly owns Country X corporations CFC2 and CFC3. The U.S. tax year for USC, CFC1, CFC2, and CFC3 ends on December 31. During the U.S. tax year ending December 31, 2025, CFC2 and CFC3, both second-tier CFCs, each distribute 100u, comprising all of their respective section 965(a) PTEP within the annual PTEP account for the 2017 tax year (“2017 section 965(a) PTEP”) within the general category, to CFC1, a first-tier CFC. CFC1 pays 40u equal to $40 of eligible current-year taxes to Country X on the 200u PTEP distributions, reducing the 2017 section 965(a) PTEP to 160u. The applicable percentage under section 965(g) with respect to the $40 of taxes is 0.6. In that same year, CFC1 distributes all 160u of the 2017 section 965(a) PTEP to USC. USC pays no foreign tax on such distribution. CFC1 does not have any other PTEP balances. The reference ID numbers for CFC1, CFC2, and CFC3 are 10041, 10042, and 10043, respectively. The country codes for Country X and Country Y are OC and BC, respectively. The functional currency of CFC1, CFC2, and CFC3 is the “u.” The applicable three-character alphabetic code for the “u” using the ISO 4217 standard is “UUU.”

USC makes the following entries on a single line on its general category, Schedule E, Part I.

Column Entry

1a A CFC1

1b 10041

2 202512

3 BC

4 UUU

5 965a

6 2017

7 160u

8 40

9 160u

10 1.000

11 40

12 24

13 0

14 0

15 0

16 0

USC makes the following entries on the first of two lines on Schedule E, Part II.

Instructions for Form 1118 (Rev. 12-2025) 21

Column Entry

1a A CFC2

1b 10042

2 202512

3 OC

4a CFC1

4b 10041

5 202512

6 BC

7 UUU

8 965a

9 2017

10 100u

11 0

12 100u

13 1.000

14 0

USC makes the following entries on the second of two lines on Schedule E, Part II.

Column Entry

1a A CFC3

1b 10043

2 202512

3 OC

4a CFC1

4b 10041

5 202512

6 BC

7 UUU

8 965a

9 2017

10 100u

11 0

12 100u

13 1.000

14 0

Example 2. USC is a domestic corporation. CFC1 and CFC2 are Country X corporations, and CFC3 is a Country Y corporation. The U.S. tax year for USC, CFC1, CFC2, and CFC3 ends on December 31. During CFC3’s U.S. tax year ending December 31, 2018, CFC3 distributes 100u, comprising its entire section 965(a) PTEP within the annual PTEP account for the 2017 tax year (“2017 section 965(a) PTEP”) within the general category, to CFC2, a CFC that wholly owns CFC3. CFC2 pays eligible current-year tax of 20u to Country X equal to $20 on the 100u PTEP distribution, reducing the 2017 section 965(a)

PTEP to 80u. The applicable percentage under section 965(g) with respect to the $20 of taxes is 0.6. In CFC2’s U.S. tax year ending December 31, 2019, CFC2 distributes 40u of the 2017 section 965(a) PTEP to CFC1, a CFC that wholly owns CFC2. CFC1 pays no tax on such distribution, but is deemed to pay $10 of the eligible current-year tax that was paid by CFC2 in 2017. In CFC1’s U.S. tax year ending December 31, 2025, CFC1 distributes 40u to USC, who wholly owns CFC1. USC pays no foreign tax on such distribution, but is deemed to pay the $10 of eligible current-year tax that was paid by CFC2 in 2017 and deemed paid by CFC1 in 2019. The reference ID numbers for CFC1, CFC2, and CFC3 are 20041, 20042, and 20043, respectively. The country codes for Country X and Country Y are OC and BC, respectively. The functional currency of CFC1, CFC2, and CFC3 is the “u.” The applicable three-character alphabetic code for the “u” using the ISO 4217 standard is “UUU.”

Schedule E reporting is not necessary for USC’s tax years ending December 31, 2018 to December 31, 2024. For USC’s tax year ending December 31, 2025, USC makes the following entries on a single line on its general category Form 1118, Schedule E, Part I.

Column Entry

1a A CFC1

1b 20041

2 202512

3 OC

4 UUU

5 965a

6 2017

7 40u

8 10

9 40u

10 1.000

11 10

12 6

13 0

14 0

15 0

16 0

USC makes the following entries on the first of two lines on Schedule E, Part II.

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

Column Entry

1a A CFC2

1b 20042

2 201912

3 OC

4a CFC1

4b 20041

5 201912

6 OC

7 UUU

8 965a

9 2017

10 80u

11 20

12 40u

13 0.500

14 10

USC makes the following entries on the second of two lines on Schedule E, Part II.

Column Entry

1a A CFC3

1b 20043

2 201812

3 BC

4a CFC2

4b 20042

5 201812

6 OC

7 UUU

8 965a

9 2017

10 100u

11 0

12 50u

13 0.500

14 0

Example 3. USC is a domestic corporation. CFC1 is a Country X corporation, CFC2 is a Country Y corporation, and CFC3 is a Country Z corporation. The U.S. tax year of USC, CFC1, CFC2, and CFC3 ends on December 31. During CFC3’s U.S. tax year ending December 31, 2018, CFC3 distributes 1,000u, comprising all of its subpart F PTEP within the annual PTEP account for the 2016 tax year (“2016 section 951(a)(1)(A) PTEP”) within the general category, to CFC2, a CFC that wholly owns CFC3. CFC2 pays eligible current-year tax of 100u to Country Y equal to $100 on the 1,000u PTEP distribution, reducing

the 2016 section 951(a)(1)(A) PTEP to 900u. In CFC2’s tax year ending December 31, 2019, CFC2 distributes 250u, comprising all of its section 951A PTEP within the annual PTEP account for the 2018 tax year (“2018 section 951A PTEP”) within the section 951A category, to CFC1, a CFC that wholly owns CFC2. CFC1 pays eligible current-year tax of 25u to Country X equal to $25 on the 250u PTEP distribution, reducing the 2018 section 951A PTEP to 225u. During CFC2’s tax year ending December 31, 2025, CFC2 distributes 450u out of its 2016 section 951(a)(1)(A) PTEP balance of 900u to CFC1. CFC1 pays eligible current-year tax of 45u to Country X equal to $45 on the 450u PTEP distribution, reducing the 2016 section 951(a)(1)(A) PTEP to 405u. CFC1 is also deemed to pay $50 of the eligible current-year tax paid by CFC2 on its receipt of the 2018 distribution of the PTEP from CFC3. In the same year, CFC1 distributes 630u to USC, which wholly owns CFC1. Such distribution includes all of CFC1’s 2016 section 951(a)(1)(A) PTEP of 405u and 2018 section 951A PTEP of 225u. USC pays no foreign tax on such distribution, but is deemed to pay $50 of the eligible current-year tax deemed paid by CFC1 and $70 on the eligible current-year tax paid by CFC1 on the 2019 and 2025 distributions of the PTEP from CFC2.

The reference ID numbers for CFC1, CFC2, and CFC3 are 10041, 10042, and 10043, respectively. The country codes for Country X, Country Y, and Country Z are OC, CC, and BC, respectively. The functional currency of CFC1, CFC2, and CFC3 is the “u.” The applicable three-character alphabetic code for the “u” using the ISO 4217 standard is “UUU.”

Schedule E reporting is not necessary for USC’s tax years ending December 31, 2018 to December 31, 2024. For USC’s tax year ending December 31, 2025, USC completes Form 1118, Schedule E, as follows:

USC makes the following entries on Schedule E, Part I, with respect to general category income.

Instructions for Form 1118 (Rev. 12-2025) 23

Column Entry

1a A CFC1

1b 10041

2 202512

3 OC

4 UUU

5 951a1A

6 2016

7 405u

8 95

9 405u

10 1.000

11 95

12 0

13 0

14 0

15 0

16 0

USC makes the following entries on the first of two lines on Schedule E, Part II, with respect to general category income.

Column Entry

1a A CFC2

1b 10042

2 202512

3 CC

4a CFC1

4b 10041

5 202512

6 OC

7 UUU

8 951a1A

9 2016

10 900u

11 100

12 450u

13 0.500

14 50

USC makes the following entries on the second of two lines on Schedule E, Part II, with respect to general category income.

Column Entry

1a A CFC3

1b 10043

2 201812

3 BC

4a CFC2

4b 10042

5 201812

6 CC

7 UUU

8 951a1A

9 2016

10 1000u

11 0

12 500u

13 0.500

14 0

USC makes the following entries on a line on Schedule E, Part I, of its Form 1118, with respect to section 951A category income.

Column Entry

1a B CFC1

1b 10041

2 202512

3 OC

4 UUU

5 951A

6 2018

7 225u

8 25

9 225u

10 1.000

11 25

12 0

13 0

14 0

15 0

16 0

USC makes the following entries on a line on Schedule E, Part II, of its Form 1118, with respect to section 951A category income.

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

Column Entry

1a B CFC2

1b 10042

2 201912

3 CC

4a CFC1

4b 10041

5 201912

6 OC

7 UUU

8 951A

9 2018

10 250u

11 0

12 250u

13 1.000

14 0