Other Forms, Schedules — 2025 Inst 1120-F (PDF)

Forms A foreign corporation may have to file some of the following forms and schedules. See the form or schedule for more information.

For a list of additional forms the corporation may need to file (most notably, forms pertaining to the reporting of various types of income, and any related withholding, to U.S. persons, foreign persons, and the IRS), see Pub. 542, Corporations.

Form 1094-C. Transmittal of Employer Health Coverage Statements and Form 1095-C, Employer-Provided Health Coverage Statement. Employers with 50 or more full-time employees (including full-time equivalent employees) use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C must be used to report to the IRS summary information for each employer and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee. In addition, Forms 1094-C and 1095-C are used in determining whether an employer owes payments under the employer-shared responsibility provisions under section 4980H. For more information, see the Instructions for Forms 1094-C and 1095-C. Also, for more information related to the Affordable Care Act, visit IRS.gov/ACA .

Form 5472. Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. This form is filed by or for a foreign corporation engaged in a U.S. trade or business that had reportable transactions with a related party. See the Instructions for Form 5472 for filing instructions and information for failure to file and maintain records.

Form 8275. Disclosure Statement and Form 8275-R, Regulation Disclosure Statement. Use these forms to disclose items or positions taken on a tax return that are not otherwise adequately disclosed on a tax return or that are contrary to Treasury regulations (to avoid parts of the accuracy-related penalty or certain preparer penalties).

Form 8300. Report of Cash Payments Over $10,000 Received in a Trade or Business. Use this form to report the receipt of

more than $10,000 in cash or foreign currency in one transaction or a series of related transactions.

Form 8832. Entity Classification Election. This form is filed by an eligible entity to elect how it will be classified for federal tax purposes. If the corporation filed Form 8832 to make an initial classification election to be a corporation or to change its classification to be a corporation effective during the current tax year, the corporation must attach a copy of the Form 8832 to its Form 1120-F . If the corporation owns a direct or indirect interest in an entity that is not required to file a return, but for which a Form 8832 was filed to make a change in the classification of the entity that is effective during the current tax year, the corporation must attach a copy of the Form 8832 with respect to that entity to its Form 1120-F for the current tax year. Examples of when the corporation must attach a copy of the Form 8832 for an entity in which it has an interest include the corporation’s ownership of:

An entity that elected to be a disregarded entity,
A foreign entity that elected to be a partnership but does not itself have a Form 1065 filing requirement, and
A foreign corporation that owns a foreign entity that elected to be a disregarded entity.

The corporation does not need to attach the Form 8832 for an entity in which it has an indirect interest if an entity in which it has an interest is already attaching a copy of the Form 8832 with its return. See Regulations section 301.7701-3(c)(1)(ii).

Form 8833. Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b). Use this form to make the treaty-based return position disclosure required by section 6114.

Form 8848. Consent To Extend the Time To Assess the Branch Profits Tax Under Regulations Sections 1.884-2(a) and (c). Use this form to execute a waiver of period of limitations in regard to a termination or incorporation of a U.S. trade or business or liquidation or reorganization of a foreign corporation or its domestic subsidiary. See the instructions for Section III, Part I, of Form 1120-F.

Form 8886. Reportable Transaction Disclosure Statement. Use this form to disclose information for each reportable transaction in which the corporation participated. Form 8886 must be filed for each tax year that the federal income tax liability of the corporation is affected by its participation in the transaction. The following are reportable transactions.

Any listed transaction, which is a transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction and identified by notice, regulation, or other published guidance as a listed transaction.
Any transaction offered under conditions of confidentiality for which the corporation (or a related party) paid an advisor a fee of at least $250,000.
Certain transactions for which the corporation (or a related party) has contractual protection against disallowance of the tax benefits.
Certain transactions resulting in a loss of at least $10 million in any single year or $20 million in any combination of years.
Any transaction identified by the IRS by notice, regulation, or other published guidance as a “transaction of interest.”

For more information, see Regulations section 1.6011-4. Also, see the Instructions for Form 8886.

Penalties. The corporation may have to pay a penalty if it is required to disclose a reportable transaction under section 6011 and fails to properly complete and file Form 8886. Penalties may also apply under section 6707A if the corporation fails to file Form 8886 with its corporate return, fails to provide a copy of

6 Instructions for Form 1120-F (2025)

Form 8886 to the Office of Tax Shelter Analysis (OTSA), or files a form that fails to include all the information required (or includes incorrect information). Other penalties, such as an accuracy-related penalty under section 6662A, may also apply. See the Instructions for Form 8886 for details on these and other penalties.

Reportable transactions by material advisors. Material advisors to any reportable transaction must disclose certain information about the reportable transaction by filing Form 8918 with the IRS. For details, see the Instructions for Form 8918.

Schedules

Schedule H, Deductions Allocated to Effectively Connected Income Under Regulations Section 1.861-8. This schedule is required to be attached to report certain deductions of the corporation that are allocable to ECI. If the corporation has any deductions reportable on Form 1120-F, Section II, lines 12 through 27, then Schedule H is required to be attached. See the separate Instructions for Schedule H for details.

Note: Line 20 of Schedule H is reportable on Form 1120-F, Section II, line 26.

Schedule I, Interest Expense Allocation Under Regulations Section 1.882-5. This schedule is required to be attached to report any interest expense allocable to ECI under Regulations section 1.882-5. The schedule must be attached whether or not such allocable interest is deductible against ECI in the current year. See the separate Instructions for Schedule I (Form 1120-F) for identification of elective allocation methods and computation of the allocable and deductible amounts of interest expense.

Note: Line 25 of Schedule I is reportable on Form 1120-F, Section II, line 18.

Schedule P, List of Foreign Partner Interests in Partner- ships. This schedule is required to be attached to report all ECI included in Schedules K-3 (Form 1065) the foreign corporation receives for each of its directly held partnership interests. Schedule P is also required to report the corporation’s adjusted outside basis in its directly held partnership interest and the amount of the outside basis of each such interest apportioned to ECI under Regulations section 1.884-1(d)(3). See the separate Instructions for Schedule P (Form 1120-F) for the reconciliation of ECI and distributive share of expenses reported on Schedules K-3 (Form 1065). Finally, Schedule P is required to report information regarding a foreign corporate partner’s transfer of an interest in a partnership and the calculation of gain or loss on the transfer when the partnership directly or indirectly either is engaged in the conduct of a trade or business within the United States or holds any U.S. real property interests. Do not file Schedule P if the corporation has no partnership interests that give rise to ECI that is included in the income reported to the corporation on Schedules K-3 (Form 1065) and there has not been a transfer of an interest in a partnership that directly or indirectly either is engaged in the conduct of a trade or business within the United States or holds any U.S. real property interests.

Note: If the corporation has received Form 8805, Foreign Partner’s Information Statement of Section 1446 Withholding Tax, it will have ECI includible in its Schedule K-3 (Form 1065) that is required to be reported on Schedule P.

Schedule S, Exclusion of Income From the International Operation of Ships or Aircraft Under Section 883. This schedule is required to be attached to claim a Code exemption under section 883. This schedule incorporates the information required under Regulations sections 1.883-1 through 1.883-4. See the separate Instructions for Schedule S (Form 1120-F) for details.

Schedule V, List of Vessels or Aircraft, Operators, and Own- ers. This schedule is required to be attached if the corporation is required to report gross transportation income in Section I, line 9, column (b). See the separate Instructions for Schedule V (Form 1120-F) for details.