Claim for Refund or Credit

If the corporation is filing Form 1120-F only as a claim for refund or credit of tax paid or withheld at source, the simplified procedure described below may be used. This simplified procedure may not be used by a corporation that was a QDD or had a branch that was a QDD.

Note: You cannot claim a refund based on a reduced rate of, or exemption from, U.S tax withheld from a substitute dividend payment made in connection with a securities lending or similar transaction if the tax was withheld by a withholding agent other than the withholding agent from which you received the payment (amounts are reported in box 8 of Form 1042-S). See Notice 2010-46, 2010-24 I.R.B. 757, available at IRS.gov/irb/ 2010-24_IRB#NOT-2010-46, for further information on limitations on refunds and credits permitted in such cases.

Simplified Procedure for Claiming a Refund of U.S. Tax Withheld at Source To make a claim for a refund, complete Form 1120-F as follows.

Page 1. Enter the complete name, address, and employer identification number (EIN) of the corporation. Check the applicable box to indicate the type of filing. Provide all the information required in items A through G.

Refund amount. Enter on page 1, lines 1 and 4a, the amount from page 4, line 11. Enter on lines 5i and 5z the amount from page 4, line 12. Enter the excess of line 5z over line 4a on lines 8a and 9b. This is the amount to be refunded to you. Signature. An authorized officer of the corporation must sign and date the return.

Pages 2 and 3. Additional information. Complete all items on pages 2 and 3 of Form 1120-F that apply to the corporation.

Page 4. Section I. Enter in column (b) the gross amount of each type of income received that is required to be reported in Section I (see Section I , later, for details). Include income from foreign sources that was subject to backup withholding. Do not include income from which no U.S. tax was withheld. If the corporation is subject to backup withholding on gross proceeds from sales of securities or transactions in regulated futures contracts, enter the gross proceeds on line 10.

Enter in columns (c) and (d), respectively, the correct rate and amount of U.S. income tax liability for each type of income reported in column (b). If the corporation is claiming a refund of U.S. tax withheld in excess of the rate provided in a tax treaty with the United States, enter the applicable treaty rate in column (c) and figure the correct U.S. income tax liability on the gross income reported in column (b).

Enter in column (e) the U.S. tax actually withheld at source (and not refunded by the payer or the withholding agent) from each type of income reported. This should be the amount reported to you in box 10, Total withholding credit, of Form(s) 1042-S, which includes the total amount of federal tax withheld at source less any amount that was repaid to you by the

withholding agent. If multiple rates of tax are applicable to a type of income, attach a statement showing the gross amounts of income, applicable rate, and amount of liability and withholding imposed for the respective amounts at each tax rate (for example, if a corporation receives subsidiary dividends subject to tax at 5% and portfolio dividends subject to tax at 15%, a statement must be attached for Section I, line 2a, to show the amount of dividend and tax liability for each respective rate).

Enter on line 11 the total U.S. tax liability for the reported income.

Enter on line 12 the total U.S. tax actually withheld from such income.

Check the appropriate box on line 13. A fiscally transparent entity is one that is not itself generally subject to income tax but one whose tax attributes flow through to its owners.

Additional Documentation Required

The corporation must attach to Form 1120-F the following.

1. Proof of the withholding (for example, Form 1042-S).

2. A statement that describes the basis for the claim for refund.

3. Any required tax certifications (for example, Form W-8BEN-E).

4. Any additional documentation to support the claim.

Refund of backup withholding tax. If the corporation is claiming a refund of backup withholding tax based on its status as a non-U.S. resident, it must:

• Provide a copy of the Form 1099 that shows the amount of reportable payment and backup withholding, and

• Attach a statement signed under penalties of perjury that the corporation is exempt from backup withholding because it is not a U.S. corporation or other U.S. resident (for example, Form W-8BEN-E).

Refunds of U.S. withholding. If any of the following apply, attach the information requested in addition to the additional documentation described earlier.

• If you are claiming a refund of U.S. tax withheld under chapter 4, you must provide a statement explaining the basis for the claim and must provide the other information requested in this section to establish a reduced rate, or exemption from, tax under section 881. See Regulations section 1.1474-5 for the requirements for claiming a credit or refund of tax withheld under chapter 4.

• If claiming a refund of U.S. tax withheld from portfolio interest, include a description of the relevant debt obligation, including the name of the issuer, CUSIP number (if any), interest rate, scheduled maturity date, and the date the debt was issued. Also, include a statement, signed under penalties of perjury, that the corporation is the beneficial owner of the interest income and not a U.S. corporation or other U.S. resident (for example, Form W-8BEN-E).

• If claiming a reduced rate of, or exemption from, tax based on a tax treaty, provide a certificate of entitlement to treaty benefits (for example, Form W-8BEN-E). A separate statement should be provided that contains any additional representations necessary to explain the basis for the claim. The corporation may complete item W(1) on page 2 of the form (which includes completing and attaching Form 8833, if required) in lieu of attaching a statement.

Note: To claim a reduced rate of, or exemption from, tax based on a tax treaty, the corporation must generally be a resident of the particular treaty country within the meaning of the treaty and satisfy the limitation on benefits article, if any, in the treaty with that country.

4 Instructions for Form 1120-F (2025)

• If claiming a refund for overwithholding on a distribution from a U.S. corporation with respect to its stock because the corporation has insufficient earnings and profits to support ordinary dividend treatment, provide a statement that identifies the distributing corporation and provides the basis for the claim.

• If claiming a refund for overwithholding on a distribution from a mutual fund or a real estate investment trust (REIT) with respect to its stock because the distribution was designated as long-term capital gain or a return of capital, provide a statement that identifies the mutual fund or REIT and provide the basis for the claim.

• If claiming a refund for overwithholding on a distribution from a U.S. corporation with respect to its stock because, in the foreign corporation’s particular circumstances, the transaction qualifies as a redemption of stock under section 302, provide a statement that describes the transaction and presents the facts necessary to establish that the payment was (a) a complete redemption, (b) a disproportionate redemption, or (c) not essentially equivalent to a dividend.