Additional Information Requested — 2025 Inst 1120-F (PDF)

Complete items H through JJ.

Item K(1) If the foreign corporation was not engaged in a U.S. trade or business at any time during the tax year, or was engaged in a U.S. trade or business but did not derive any gross income effectively connected to such trade or business, answer “No” to item K(1).

If the foreign corporation had gross income effectively connected with or treated as effectively connected with the conduct of a trade or business in the United States, answer “Yes” to item K(1).

Item L Skip item L (leave blank) if the foreign corporation is a resident of a country that does not have an income tax treaty with the United States. If the foreign corporation is a resident of a country that has an income tax treaty with the United States:

Answer “Yes” if the corporation had a permanent establishment in the United States at any time during the tax year or in any prior tax year to which income was attributable, and enter the name of the country of residence of the foreign corporation; or
Answer “No” if the corporation does not have a permanent establishment in the United States.

If the answer to item L is “No” and the answer to item K(1) is “Yes,” complete item W(1) on page 2 of the form and attach a completed Form 8833 to the return, including a statement indicating the nature and amount (or reasonable estimate thereof) of gross receipts of the foreign corporation exempt by reason of not having a permanent establishment in the United States.

Item M See Form 5472 , earlier.

Item O—Personal Service Corporation A personal service corporation is a corporation whose principal activity for the testing period is the performance of personal services. The services must be substantially performed by employee-owners.

Testing period. The testing period for a tax year is generally the prior tax year unless the corporation has just been formed.

Performance of personal services. The term “performance of personal services” includes any activity involving the performance of personal services in the fields of health, law, engineering, architecture, accounting, actuarial science, performing arts, or consulting.

Accounting period. A personal service corporation must use a calendar tax year unless:

It elects to use a 52-53-week tax year that ends with reference to the calendar year or tax year elected under section 444;

Line 9d. Type of Account Check the appropriate box for the type of account. Don’t check more than one box. The corporation must check the correct box to ensure the deposit is accepted.

Instructions for Form 1120-F (2025) 15

It can establish a business purpose for a different tax year and obtains the approval of the IRS (see the Instructions for Form 1128 and Pub. 538); or
It elects under section 444 to have a tax year other than a calendar year. To make the election, use Form 8716, Election To Have a Tax Year Other Than a Required Tax Year.

If a corporation makes the section 444 election, its deduction for certain amounts paid to employee-owners may be limited. See Schedule H (Form 1120), Section 280H Limitations for a Personal Service Corporation (PSC), to figure the maximum deduction.

If a section 444 election is terminated and the termination results in a short tax year, type or print at the top of the first page of Form 1120-F for the short tax year “SECTION 444 ELECTION TERMINATED.”

Other rules. For other rules that apply to personal service corporations, see Passive activity limitations, later.

Item P Enter any tax-exempt interest received or accrued. Include any exempt-interest dividends received as a shareholder in a mutual fund or other RIC. Also, if required, include the same amount on Schedule M-1, line 7a, or Schedule M-3, Part II, line 4a.

Item R If the corporation has a net operating loss (NOL) for tax year 2025, it can elect to waive the entire carryback period for the NOL and instead carry the NOL forward to future tax years. To do so, check the box in item R and file Form 1120-F by its due date, including extensions. Do not attach the statement described in Temporary Regulations section 301.9100-12T. Generally, once made, the election is irrevocable.

If the corporation timely filed its return for the loss year without making the election, it can make the election on an amended return filed within 6 months of the due date of the loss year return (excluding extensions). Attach the election to the amended return and write “Filed pursuant to section 301.9100-2” on the election statement. See the Instructions for Form 1139.

Item S Enter the amount of the NOL carryover to the tax year from prior years, even if some of the loss is used to offset income on this return. The amount to enter is the total of all NOLs generated in prior years but not used to offset income (either as a carryback or carryover) to a tax year prior to 2025. Do not reduce the amount by any NOL deduction reported on Section II, line 30a.

Item T Check the “Yes” box for item T if the corporation is a subsidiary in a parent-subsidiary controlled group. This applies even if the corporation is a subsidiary member of one group and the parent corporation of another. For a definition of a parent-subsidiary controlled group, see the Instructions for Schedule O (Form 1120).

Note: If the corporation is an “excluded member” of a controlled group (see definition in the Instructions for Schedule O (Form 1120)), it is still considered a member of a controlled group for this purpose.

Item W(1) If a foreign corporation claims that a treaty overrules or modifies any provision of the Internal Revenue Code and thereby effects a reduction of any tax with respect to an item reported on this Form 1120-F, check the “Yes” box. Check the “Yes” box, for example, if a treaty benefit has been claimed based on the following.

The nondiscrimination provision of a treaty.
The business profits article of a treaty, if expenses are claimed in determining the business profits of the foreign corporation, notwithstanding an inconsistent provision of the Code.
The gains article, if a treaty benefit is claimed relating to gain or loss on the disposition of a U.S. real property interest.
The branch profits tax article (or portion of the dividends article relating to the branch profits tax) and tax on excess interest.
A waiver of insurance excise tax under section 4371 (if the foreign corporation has not entered into a closing agreement with the IRS and has not filed an annual Form 720).
The interest, dividends, or royalty article, if a refund of withholding tax is due.

Item W(2) Check the “Yes” box if the foreign corporation is claiming tax treaty benefits pursuant to a Competent Authority determination or Advance Pricing Agreement that it qualifies for the treaty benefits being claimed. You must attach a copy of the Competent Authority determination letter or Advance Pricing Agreement to the return.

Item Y(1) For more information regarding a corporation’s distributive share of income from a directly owned partnership interest that is ECI or treated as ECI by the partnership or the corporation (partner), see Who Must Complete Schedule P in the separate Instructions for Schedule P (Form 1120-F).

Item Y(2) In general, if a foreign corporation owns, directly or indirectly, an interest in a partnership that is engaged in a U.S. trade or business, gain or loss on the transfer of all (or any portion of) such interest is treated as effectively connected with the conduct of such trade or business to the extent effectively connected gain or loss would have flowed through the partnership to the foreign corporation had the partnership sold all of its assets at fair market value (FMV) as of the date of the sale or exchange. See section 864(c)(8) for more details. Also, see Regulations sections 1.864(c)(8)-1 and 1.864(c)(8)-2 for additional guidance concerning gain or loss of foreign persons from the transfer of certain partnership interests and the notification required to be provided to certain partnerships on the transfer.

Item Y(3) If the corporation owned at least a 10% interest, directly or indirectly, in any foreign partnership, attach a statement listing the following information for each foreign partnership. For this purpose, a foreign partnership includes an entity treated as a foreign partnership under Regulations section 301.7701-2 or 301.7701-3.

Name and EIN (if any) of the foreign partnership.
Identify which, if any, of the following forms the foreign partnership filed for its tax year ending with or within the corporation’s tax year: Form 1042, 1065, or 8804.
Name of partnership representative (if any).
Beginning and ending dates of the foreign partnership’s tax year.

In addition, report any ECI included on Schedule K-3 (Form 1065) reported by the foreign partnership to the corporation, and the ECI apportionment of the corporation’s outside basis in the foreign partnership, as required in Schedule P.

Item Z(2) If the answer to item Z(2) is “Yes,” attach a statement explaining whether the interbranch transactions are recognized under Proposed Regulations section 1.863-3(h) (Global Dealing Regulations) or some other proposed regulation. If interbranch

16 Instructions for Form 1120-F (2025)

transactions are recognized pursuant to a U.S. income tax treaty other than one that, in its text or accompanying documents (including an exchange of notes), allows for such recognition by explicitly incorporating an arm’s-length method applying the OECD Transfer Pricing Guidelines, then such treaty-based position should be disclosed on Form 8275-R, in addition to the treaty disclosure required on Form 8833.

Item AA A corporation filing Form 1120-F must file Schedule UTP (Form 1120), Uncertain Tax Position Statement, with its 2025 income tax return if:

For 2025, the corporation’s total assets equal or exceed $10 million. The assets of a corporation filing a Form 1120-F equal or exceed $10 million if the higher of the beginning or end of year total worldwide assets of the corporation reported on Form 1120-F, Schedule L, line 17, would be at least $10 million if the corporation were to prepare a Schedule L on a worldwide basis;
The corporation or a related party issued audited financial statements reporting all or a portion of the corporation’s operations for all or a portion of the corporation’s tax year; and
The corporation has one or more tax positions that must be reported on Schedule UTP.

Attach Schedule UTP to the corporation’s income tax return. Do not file it separately. A taxpayer that files a protective Form 1120-F must also file Schedule UTP if it satisfies the requirements set forth above.

For details, see the Instructions for Schedule UTP.

Item BB If the foreign corporation made any payment(s) in 2025 that would require the foreign corporation to file any Forms 1042 and 1042-S, check the “Yes” box. See the Instructions for Form 1042 and the Instructions for Form 1042-S for information regarding who is required to file Forms 1042 and 1042-S and what types of payments are subject to reporting on Forms 1042 and 1042-S.

Item CC If the corporation or any branch of the corporation was a QDD, check the “Yes” box, enter the QI-EIN, and attach a Schedule Q (Form 1120-F) for each QDD. You must complete and attach Schedule Q (Form 1120-F) even if the QDD has zero tax liability.

Item DD If the corporation had gross receipts of at least $500 million in any 1 of the 3 preceding tax years, complete and attach Form 8991. For this purpose, the corporation’s gross receipts include the gross receipts of all persons aggregated with the corporation, as specified in section 59A(e)(3). See the Instructions for Form 8991 to determine if the corporation is subject to the base erosion minimum tax.

Item EE Section 267A disallows a deduction for certain interest or royalty paid or accrued pursuant to a hybrid arrangement, to the extent that, under the foreign tax law, there is not a corresponding income inclusion (including long-term deferral). Report in item EE the total amount of interest and royalty paid or accrued by a U.S. taxable branch (which includes a U.S. permanent establishment) of the foreign corporation for which a deduction is disallowed under section 267A.

Payments to which section 267A applies. Interest or royalty considered paid or accrued by a U.S. taxable branch of the foreign corporation is subject to section 267A. See Regulations section 1.267A-5(b)(3) for rules regarding U.S. taxable branch payments, including interest or royalties considered paid or accrued by a U.S. taxable branch. Section 267A generally

applies to interest or royalties paid or accrued pursuant to a hybrid arrangement (such as, for example, a payment pursuant to a hybrid instrument or a payment to a reverse hybrid), provided that the payment or accrual is to a related party (or pursuant to a structured arrangement). In addition, pursuant to an imported mismatch rule, section 267A generally applies to interest or royalties paid or accrued pursuant to a non-hybrid arrangement where the income attributable to that payment or accrual is directly or indirectly offset by certain deductions involving hybridity incurred by a related party or pursuant to a structured arrangement. However, section 267A does not apply if a de minimis exception is satisfied. See Regulations section 1.267A-1(c). For purposes of section 267A, interest and royalties are defined broadly. For additional information about arrangements subject to section 267A, see Regulations sections 1.267A-2 and 1.267A-4. Also, see the anti-avoidance rule under Regulations section 1.267A-5(b)(6).

Extent to which deduction is disallowed. When section 267A applies to interest or royalties paid or accrued pursuant to a hybrid arrangement, it generally disallows a deduction for the amount to the extent that, under the foreign tax law, there is not a corresponding income inclusion (including long-term deferral). However, the deduction is not disallowed to the extent the amount is directly or indirectly included in income in the United States, such as if the amount is taken into account with respect to a U.S. shareholder under section 951(a) or section 951A. For additional information, see Regulations sections 1.267A-2 through 1.267A-4. For examples illustrating the application of section 267A, see Regulations section 1.267A-6.

Item FF The limitation on business interest expense applies to every taxpayer with a trade or business, unless the taxpayer meets certain specified exceptions. A taxpayer may elect out of the limitation for certain businesses otherwise subject to the business interest expense limitation. See Item GG . Also, see the Instructions for Form 8990.

Certain real property trades or businesses and farming businesses qualify to make an election not to limit business interest expense. This is an irrevocable election. If you make this election, you are required to use the alternative depreciation system to depreciate any nonresidential real property, residential rental property, and qualified improvement property for an electing real property trade or business, and any property with a recovery period of 10 years or more for an electing farming business. See section 168(g)(1). Also, you are not entitled to the special depreciation allowance for that property. For a taxpayer with more than one qualifying business, the election is made with respect to each business.

Check “Yes” if the corporation has an election in effect to exclude a real property trade or business or a farming business from section 163(j). For more information, see section 163(j) and the Instructions for Form 8990. Also, see the Instructions for Schedule I (Form 1120-F).

Item GG Generally, a taxpayer with a trade or business must file Form 8990 to claim a deduction for business interest. In addition, Form 8990 must be filed by any taxpayer that owns an interest in a partnership with current-year, or prior-year carryover, excess business interest expense allocated from the partnership.

Exclusions from filing. A taxpayer is not required to file Form 8990 if the taxpayer is a “small business taxpayer” (defined below) and does not have excess business interest expense from a partnership. A taxpayer is also not required to file Form 8990 if the taxpayer only has business interest expense from these excepted trades or businesses.

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An electing real property trade or business.
An electing farming business.
Certain utility businesses.

Small business taxpayer. A small business taxpayer is not subject to the business interest expense limitation and is not required to file Form 8990. A small business taxpayer is a taxpayer that (a) is not a tax shelter (as defined in section 448(d) (3), and (b) meets the gross receipts test of section 448(c) discussed next.

Gross receipts test. For 2025, a taxpayer meets the gross receipts test if the taxpayer has average annual gross receipts of $31 million or less for the 3 prior tax years. A taxpayer’s average annual gross receipts for the 3 prior tax years is determined by adding the gross receipts for the 3 prior tax years and dividing the total by 3. Gross receipts include the aggregate gross receipts from all persons treated as a single employer, such as a controlled group of corporations; commonly controlled partnerships, or proprietorships; and affiliated service groups. See section 448(c) and the Instructions for Form 8990 for additional information.

Note: A foreign corporation is required to complete Schedule I (Form 1120-F) to compute its interest expense deduction under Regulations section 1.882-5. If the foreign corporation is required to complete and file Form 8990, attach Form 8990 to Schedule I (Form 1120-F), which is attached to Form 1120-F.

Item HH If a foreign corporation is organized in a U.S. territory, it may be a Qualified Opportunity Fund (QOF) only if it is organized for the purpose of investing in qualified opportunity zone property that relates to a trade or business operated in the U.S. territory in which the corporation is organized. To certify as a QOF, the corporation must file Form 1120-F and attach Form 8996, even if the corporation had no income or expenses to report. If the corporation is attaching Form 8996, check the “Yes” box for item HH. On the line following the dollar sign, enter the amount from Form 8996, line 15.

The penalty reported on this line from Form 8996, line 15, is not due with the filing of this form. The IRS will send you a notice regarding the penalty reported on line 15. This notice will include instructions on the penalty, the reasonable cause relief process, and payment instructions.

Item II If the corporation is a member of a controlled group, check the “Yes” box. Complete and attach Schedule O (Form 1120), Consent Plan and Apportionment Schedule for a Controlled Group. Component members of a controlled group must use Schedule O to report the apportionment of certain tax benefits between the members of the group. See Schedule O and the Instructions for Schedule O for more information.

Item JJ Check the appropriate boxes to indicate if the corporation is required to file Form 4626. If the corporation does not meet the requirements of a safe harbor method, as provided under Proposed Regulations section 1.59-2(g)(2) or Notice 2025-27, Form 4626 must be completed and attached to the corporation’s return. See the Instructions for Form 4626.

Corporations that qualify for a corporate alternative minimum tax (CAMT) safe harbor should indicate “Yes” to question JJ(3) and are not required to file Form 4626. Corporations generally qualify for the CAMT safe harbor if the corporation’s average annual adjusted financial statement income (AFSI) for the 3 preceding tax years is less than $800 million. Special rules apply to members of a controlled group treated as a single employer

Such income (except as indicated below) will generally be subject to tax at a 30% rate. See section 881(a).

Amounts fixed or determinable, annual or periodic include the following.

Interest (other than original issue discount (OID) as defined in section 1273), dividends, rents, royalties, salaries, wages, premiums, annuities, compensation, and other FDAP gains, profits, and income. Note: Item 1 above includes dividend equivalents described in section 871(m); however, dividends and dividend equivalents received in calendar years 2019 through 2024 by a QDD in its equity derivatives dealer capacity are excluded.
Gains described in section 631(b) or (c), relating to disposal of timber, coal, or domestic iron ore with a retained economic interest.
On a sale or exchange of an OID obligation, the amount of the OID accruing while the obligation was held by the foreign corporation, unless this amount was taken into account on a payment.
On a payment received on an OID obligation, the amount of the OID accruing while the obligation was held by the foreign corporation, if such OID was not previously taken into account and if the tax imposed on the OID does not exceed the payment

with the corporation under section 52(a) or (b) or members of a foreign-parented multinational group.