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Part I

Publication 5384 — Statistics of Income Program Documentation: Data Items by Forms and Schedules, Program Year 2024 · 2026-10-03 edition · updated 2026-10-04 · United States

See section 907(c) and underlying regulations for rules on the income to include in Part I. Note: Do not include any dividend or interest income that is passive income. See the Instructions for Form 1118 for the definition of passive income. Column 1(a). For information pertaining to the entry of EINs and reference ID numbers, see Identifying Numbers in the separate instructions for Form 1118. For section 863(b) income, leave column 1(a) blank. Column 1(b). Enter the two-letter codes (from the list at www.irs.gov/CountryCodes ) of all foreign countries and U.S. possessions within which income is sourced and/or to which taxes were paid, accrued, or deemed paid. For section 863(b) income, enter “863(b)” instead of a two-letter code. Column 2. Enter gross income from sources outside the United States and its possessions from the following.

  • The extraction (by the corporation or any other person) of minerals from oil or gas wells located outside the United States and its possessions.

  • The sale or exchange of assets used in the trade or business of extracting minerals from oil or gas wells located outside the United States and its possessions.

See section 907(c)(1). Column 3. Enter gross income from sources outside the United States and its possessions from the following.

  • The processing of minerals extracted (by the corporation or any other person) from oil or gas wells into their primary products.

  • The transportation of such minerals or primary products.

  • The distribution or sale of such minerals or primary products.

  • The disposition of assets used in the trade or business described in the three previous bulleted items.

  • The performance of any other related service. See section 907(c)(2). Column 4. Enter amounts taxable under section 951(a) or 951A (including section 78 gross-up) that are attributable to the controlled foreign corporation’s combined foreign oil and gas income. Column 5. Include the corporation’s distributive share of partnership combined foreign oil and gas income. Include in column 5 interest income paid by a foreign corporation to the extent the category of income of such interest is determined under section 904(d)(3). Do not include interest income paid by a foreign subsidiary out of foreign oil and gas extraction income of the payor, even if it is not passive income.

See section 907(c)(3). Columns 7 and 8. Enter the deductions allocated and apportioned to foreign oil and gas income in the separate category. See the regulations under section 861. Column 10. For each country, subtract column 9 from column 6 and enter the result in column 10. When totaling the column 10 amounts, note that a taxable loss from a foreign country offsets taxable income from other countries. Columns 11 and 12. Attach a schedule to show how the foreign taxes paid, accrued, or deemed paid with respect to combined foreign oil and gas income were figured.

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▸Contents — Publication 5384 — Statistics of Income Program Documentation: Data Items by Forms and Schedules, Program Year 2024

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