SECTION 6. DRAFTING

INFORMATION

The principal author of this revenue procedure is Elizabeth Cowan of the Office of Associate Chief Counsel (Procedure & Administration). For further information regarding this revenue procedure, contact Branch 2 of Procedure and Administration at (202) 622–4940 (not a toll-free call).

of expense/deduction items); and Column (d), Income (Loss) per Tax Return, of Part II (reconciliation of income (loss) items) and Column (d), Deduction per Tax Return, of Part III (reconciliation of expense/deduction items).

(d) Form 1120–PC. Schedule M–3 (Form 1120–PC), Net Income (Loss) Rec- onciliation for U.S. Property and Casualty Insurance Companies With Total Assets of $10 Million or More : Column (a), In- come (Loss) per Income Statement, of Part II (reconciliation of income (loss) items) and Column (a), Expense per In- come Statement, of Part III (reconciliation of expense/deduction items); Column (b), Temporary Difference, and Column (c), Permanent Difference, of Part II (reconciliation of income (loss) items) and Part III (reconciliation of expense/deduction items); and Column (d), Income (Loss) per Tax Return, of Part II (reconciliation of income (loss) items) and Column (d), Deduction per Tax Return, of Part III (reconciliation of expense/deduction items).

(e) Form 1120–S. Schedule M–3 (Form 1120–S), Net Income (Loss) Reconcilia- tion for S Corporations With Total Assets of $10 Million or More : Column (a), In- come (Loss) per Income Statement, of Part II (reconciliation of income (loss) items) and Column (a), Expense per In- come Statement, of Part III (reconciliation of expense/deduction items); Column (b), Temporary Difference, and Column (c), Permanent Difference, of Part II (reconciliation of income (loss) items) and Part III (reconciliation of expense/deduction

items); and Column (d), Income (Loss) per Tax Return, of Part II (reconciliation of income (loss) items) and Column (d), Deduction per Tax Return, of Part III (reconciliation of expense/deduction items).

(f) Form 1120–F. Schedule M–3 (Form 1120–F), Net Income (Loss) Reconcilia- tion for Foreign Corporations With Total Assets of $10 Million or More : Column (b), Temporary Difference, Column (c), Permanent Difference, and Column (d), Other Permanent Differences for Allo- cations to Non-ECI and ECI, of Part II (reconciliation of income (loss) items) and Part III (reconciliation of expense/deduction items).

(4) Foreign Tax Items: (a) International Boycott Transactions: Transactions disclosed on Form 5713, International Boycott Report ; Schedule A, International Boycott Factor (Sec- tion 999(c)(1)) ; Schedule B, Specifically Attributable Taxes and Income (Section 999(c)(2)) ; and Schedule C, Tax Effect of the International Boycott Provisions, must be completed when required by their instructions.

(b) Treaty-Based Return Position: Transactions and amounts under section 6114 or section 7701(b) as disclosed on Form 8833, Treaty-Based Return Posi- tion Disclosure Under Section 6114 or 7701(b), must be completed when required by its instructions.

(5) Other: (a) Moving Expenses: Complete Form 3903, Moving Expenses, and attach to the return.

2012–51 I.R.B. 722 December 17, 2012