Part III
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
Line 2. Enter the sum of any carryover of foreign oil and gas tax to the current year. Attach a schedule showing the computation in detail. Corporations are encouraged to attach a schedule that is similar to Schedule K (Form 1118), which is used to report a running balance of the corporation’s section 904(c) carryovers. If this approach is taken, the amount to be entered on line 2 is the amount that corresponds to Schedule K (Form 1118), line 3, column (xiv). Please note that special rules apply to the carryback and carryover of foreign taxes paid or accrued on combined foreign oil and gas income and related taxes. For example, in applying foreign tax carryovers from prior tax years, in the case of any tax year that is an unused credit year (as defined in section 907(f)) under each of sections 907(f) and 904(c), the provisions of section 907(f) are to be applied before section 904(c). See section 907(f) and Regulations section 1.907(f)-1 for additional information.
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| (vi) U.S. income | ✔ | ✔ | ✔ ) ( | ✔ | ✔ | ✔ | ✔ | ✔ ( ) | |||||||||||||
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| (v) Other income* (identify a ) |
✔ | ( ) ✔ |
( ) ✔ |
( ) ✔ |
( ) ✔ |
✔ ✔ |
✔ | ✔ | ( ) ✔ |
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✔ | ✔ | ✔ | ✔ | ✔ | ( ) ✔ |
✔ | |||
| (iv) General category income |
✔ | ( ) ✔ |
( ) ✔ |
( ) ✔ |
✔ | ( ) ✔ ✔ |
✔ | ✔ | ( ) ✔ |
✔ | ( ) ✔ |
✔ | ✔ | ✔ | ✔ | ( ) ✔ |
✔ | ✔ | |||
| (iii) Passive category income |
✔ | ( ) ✔ |
( ) ✔ |
✔ | ( ) ✔ |
( ) ✔ ✔ |
✔ | ✔ | ( ) ✔ |
✔ | ( ) ✔ |
✔ | ✔ | ✔ | ( ) ✔ |
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| (ii) Foreign branch income |
✔ | ( ) ✔ |
✔ | ( ) ✔ |
( ) ✔ |
( ) ✔ ✔ |
✔ | ✔ | ( ) ✔ |
✔ | ( ) ✔ |
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| (i) Section 951A income |
✔ | ✔ | ( ) ✔ |
( ) ✔ |
( ) ✔ |
( ) ✔ ✔ |
✔ | ✔ | ( ) ✔ |
✔ | ( ) ✔ |
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✔ | ✔ | ✔ | ✔ | ✔ | |||
| **1 ** Income or (loss) before adjustments |
**1 ** Income or (loss) before adjustments |
**2 ** Allocation of separate limitation losses: |
**a **Section 951A income | **b **Foreign branch income | **c **Passive category income | d General category income |
**e ** Other income* (identifya ) |
**3 ** **Subtotal—**Combine lines 1 through 2e. |
**4 ** Allocation of overall foreign losses |
**5 ** Allocation of domestic losses |
**6 ** **Subtotal—**Combine lines 3 through 5. |
**7 ** Recapture of overall foreign losses |
**8 ** **Subtotal—**Combine lines 6 and 7. |
**9 ** Recharacterization of separate limitation income: |
**a **Section 951A income | **b **Foreign branch income | **c **Passive category income | d General category income |
**e ** Other income* (identifya ) |
10 Recapture of overall domestic losses |
11 Numerator of Limitation Fraction— Combine lines 8 through 10. Enter each result here and on Schedule B, Part II, line 7, of corresponding Form 1118. |
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(vii) Subtotal (add columns (i) through (vi))
| (vi) 5th Preceding Tax Year |
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|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| (v) 6th Preceding Tax Year |
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| (iv) 7th Preceding Tax Year |
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| (iii) 8th Preceding Tax Year |
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| (ii) 9th Preceding Tax Year |
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| (i) 10th Preceding Tax Year |
-0- | ||||||||||||||
| Foreign Tax Carryover Reconciliation |
**1 ** Foreign tax carryover from the prior tax year (enter amounts from the appropriate columns of line 8 of the prior year Schedule K (see instructions)) |
**2 ** Adjustments to line 1 (enter description —see instructions): |
**a ** Carryback adjustment (see instructions) |
**b ** Adjustments for section 905(c) redeterminations (see instructions) |
c | d | e | f | g | **3 ** Adjusted foreign tax carryover from prior tax year (combine lines 1 and 2) |
**4 ** Foreign tax carryover used in current tax year (enter as a negative number) |
**5 ** Foreign tax carryover expired unused in current tax year (enter as a negative number) |
**6 ** Foreign tax carryover generated in current tax year |
**7 ** Actual or estimated amount of line 6 to be carried back to prior tax year (enter as a negative number) |
**8 ** Foreign tax carryover to the following tax year. Combine lines 3 through 7. |
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| 8 Foreign tax carryover to the following tax year. Combine lines 3 through 7. | 7 Actual or estimated amount of line 6 to be carried back to prior tax year (enter as a negative number) | 6 Foreign tax carryover generated in current tax year | 5 Foreign tax carryover expired unused in current tax year (enter as a negative number) | 4 Foreign tax carryover used in current tax year (enter as a negative number) | 3 Adjusted foreign tax carryover from prior tax year (combine lines 1 and 2). Include the column (xiv) total on the current year Form 1118, Schedule B, Part II, line 5. | g | f | e | d | c | b Adjustments for section 905(c) redeterminations (see instructions) | a Carryback adjustment (see instructions) | 2 Adjustments to line 1 (enter description—see instructions): | 1 Foreign tax carryover from the prior tax year (enter amounts from the appropriate columns of line 8 of the prior year Schedule K (see instructions)) | Foreign Tax Carryover (continued) Reconciliation |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| (viii) Subtotal from page 1 (enter the amounts from column (vii) on page 1) |
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| (ix) 4th Preceding Tax Year |
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| (x) 3rd Preceding Tax Year |
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| (xi) 2nd Preceding Tax Year |
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| (xii) 1st Preceding Tax Year |
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| (xiii) Current Tax Year |
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| (xiv) Totals (add columns (viii) through (xiii)) |
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Number, street, and room or suite no. If a P.O. box, see instructions.
City or town, state, and ZIP code
Address of service center where your tax return is filed
Type of filer (check one):
Individual Partnership Corporation Trust Estate Other 1 Individuals— Enter adjusted gross income from your tax return (see instructions) 2 Partnerships and corporations: a Partnerships—Enter each partner’s name and identifying number.
b Corporations—Enter the name and employer identification number of each member of the controlled group (as defined in
section 993(a)(3)). Do not list members included in the consolidated return; instead, attach a copy of Form 851. List all other members of the controlled group not included in the consolidated return. If you list any corporations below or if you attach Form 851, you must designate a common tax year. Enter on line 4b the name and employer identification number of the corporation whose tax year is designated.
3 Partnerships— Each partnership filing Form 5713 must give the following information: a Partnership’s total assets (see instructions) . . . . . . . . . . . . . . . b Partnership’s ordinary income (see instructions) . . . . . . . . . . . . . 4 Corporations— Each corporation filing Form 5713 must give the following information: a Type of form filed (Form 1120, 1120-FSC, 1120-IC-DISC, 1120-L, 1120-PC, etc.) . . . b Common tax year election (see instructions)
(1) Name of corporation � (2) Employer identification number . . . . . . . . . . . . . . . . . (3) Common tax year beginning, 20 , and ending , 20 . c Corporations filing this form enter:
(1) Total assets (see instructions) . . . . . . . . . . . . . . . . . . (2) Taxable income before net operating loss and special deductions (see instructions) . .
5 Estates or trusts— Enter total income (Form 1041, page 1) . . . . . . . . . 6 Enter the total amount (before reduction for boycott participation or cooperation) of the following tax benefits (see instructions): a Foreign tax credit . . . . . . . . . . . . . . . . . . . . . . . b Deferral of earnings of controlled foreign corporations . . . . . . . . . . . c Deferral of IC-DISC income . . . . . . . . . . . . . . . . . . . . d FSC exempt foreign trade income . . . . . . . . . . . . . . . . . . e Foreign trade income qualifying for the extraterritorial income exclusion . . . . . Please Under penalties of perjury, I declare that I have examined this report, including accompanying schedules and statements, and to the best of my
knowledge and belief, it is true, correct, and complete.
Sign Here
Signature Date Title
For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 12030E Form 5713 (Rev. 12-2010)
Under penalties of perjury, I declare that I have examined this report, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete.
Signature Date
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Form 5713 (Rev. 12-2010) Page 2
Form 5713 (Rev. 12-2010)
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Form 5713 (Rev. 12-2010) Page 3 Yes No 9 Nonlisted countries boycotting Israel— Did you have operations in any nonlisted country which you know or have reason to know requires participation in or cooperation with an international boycott directed against Israel? If “Yes,” complete the following table. If more space is needed, attach additional sheets using the exact format and check
If “Yes,” complete the following table. If more space is needed, attach additional sheets using the exact format and check
If “Yes,” attach a copy (in English) of any and all boycott clauses agreed to, and attach a general statement of the agreement. If the agreement was in a form other than a written agreement, attach a separate sheet explaining the nature and form of any and all such agreements. (See instructions.) Note: If the answer to either question 11 or 12 is “Yes,” you must complete the rest of Form 5713. If you answered “Yes” to question 12, you must complete Schedules A and C or B and C (Form 5713).
Form 5713 (Rev. 12-2010)
✔
✔
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Form 5713 (Rev. 12-2010) Page 4
b Requests and agreements— if the answer to any part of 13a is “Yes,” complete the following table. If more space is
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Statement of Withholding on
Copy A
For Internal
Revenue Service Center
For Privacy Act and Paperwork Reduction Act Notice,
see the Instructions
for Form 8288.
| WITHHOLDING AGENT’S name, street address, city or town, state or province, country, ZIP or foreign postal code, and phone no. |
1 Date of transfer (mm/ / / |
OMB No. 1545-0902 8288-A Form (Rev. January 2023) |
|
|---|---|---|---|
| WITHHOLDING AGENT’S name, street address, city or town, state or province, country, ZIP or foreign postal code, and phone no. |
WITHHOLDING AGENT’S name, street address, city or town, state or province, country, ZIP or foreign postal code, and phone no. |
2 Gain recognized by foreign corporation $ |
2 Gain recognized by foreign corporation $ |
| WITHHOLDING AGENT’S U.S. TIN | U.S. TIN of FOREIGN PERSON subject to withholding (see instructions) |
3 Amount realized $ |
4 Federal income tax withheld $ |
| FOREIGN PERSON’S name subject to withholding | FOREIGN PERSON’S name subject to withholding | 5Withholding under section: a1445 b 1446(f)(1) |
6FOREIGN PERSON subject to withholding: a Individual b Corporation c Partnership d Other (specify) |
| Foreign address (number, street, and apt. or suite no.) | |||
| City or town, state or province, country (not U.S.), and ZIP or foreign postal code | City or town, state or province, country (not U.S.), and ZIP or foreign postal code | 7 Country code of FOREIGN PERSON subject to withholding |
7 Country code of FOREIGN PERSON subject to withholding |
| Mailing address of FOREIGN PERSON subject to withholding (if different) | Mailing address of FOREIGN PERSON subject to withholding (if different) | 8 Description of property transferred | 8 Description of property transferred |
Form 8288-A (Rev. 1-2023)
Cat. No. 62261L
Attach Copies A and B to Form 8288
Department of the Treasury - Internal Revenue Service
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1 Type of election (see instructions):
2 a Has the eligible entity previously filed an entity election that had an effective date within the last 60 months?
Yes. Go to line 2b. No. Skip line 2b and go to line 3.
2 b Was the eligible entity’s prior election an initial classification election by a newly formed entity that was effective on the date of formation?
Yes. Go to line 3. No. Stop here. You generally are not currently eligible to make the election (see instructions).
3 Does the eligible entity have more than one owner?
Yes. You can elect to be classified as a partnership or an association taxable as a corporation. Skip line 4 and go to line 5.
No. You can elect to be classified as an association taxable as a corporation or to be disregarded as a separate entity. Go to line 4.
4 If the eligible entity has only one owner, provide the following information:
a Name of owner �
5 If the eligible entity is owned by one or more affiliated corporations that file a consolidated return, provide the name and employer identification number of the parent corporation:
a Name of parent corporation �
For Paperwork Reduction Act Notice, see instructions. Cat. No. 22598R Form 8832 (Rev. 12-2013)
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Form 8832 (Rev. 12-2013) Page 2 Part I Election Information (Continued) 6 T ype of entity (see instructions):
a A domestic eligible entity electing to be classified as an association taxable as a corporation. b A domestic eligible entity electing to be classified as a partnership. c A domestic eligible entity with a single owner electing to be disregarded as a separate entity. d A foreign eligible entity electing to be classified as an association taxable as a corporation. e A foreign eligible entity electing to be classified as a partnership. f A foreign eligible entity with a single owner electing to be disregarded as a separate entity.
7 If the eligible entity is created or organized in a foreign jurisdiction, provide the foreign country of organization �
8 Election is to be effective beginning (month, day, year) (see instructions) . . . . . . . . . . . . �
9 Name and title of contact person whom the IRS may call for more information 10 Contact person’s telephone number
Consent Statement and Signature(s) (see instructions)
Under penalties of perjury, I (we) declare that I (we) consent to the election of the above-named entity to be classified as indicated above, and that I (we) have examined this election and consent statement, and to the best of my (our) knowledge and belief, this election and consent statement are true, correct, and complete. If I am an officer, manager, or member signing for the entity, I further declare under penalties of perjury that I am authorized to make the election on its behalf.
Signature(s) Date Title
Form 8832 (Rev. 12-2013)
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Form 8991 (Rev. 12-2024) Page 2
6 Does the taxpayer elect to use financial statements per Regulations section 1.59A-3(b)(4)(i)(D) for purposes of calculating interest expense allocable to a foreign corporation’s effectively connected income? . . . Yes No 7 In the current year, did the taxpayer capitalize to inventory, or include in cost of goods sold (COGS), costs for any payment to a related foreign party that the taxpayer treated as a deduction in any prior tax year? . Yes No 8 If “Yes” for line 7, enter the following:
(i) (ii) (iii) (iv)
Amount Capitalized Line Item Reported Description of Item or Included in COGS on in Prior Year
Tax Year Form 3115 Was Filed
Form 8991 (Rev. 12-2024)
a b c
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| (Check all applicable boxes in columns (c), (d), and (e) below) | (e) | Any Person Related Within the Meaning of Section 482 to the Taxpayer | |||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|
| (Check all applicable boxes in columns (c), (d), and (e) below) |
(d) | Person Related Under Section 267(b) or 707(b)(1) to the Taxpayer or Any 25% Owner of the Taxpayer |
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| (Check all applicable boxes in columns (c), (d), and (e) below) |
(c) | Any 25% Owner of the Taxpayer |
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| (a-1) (a-2) (b-1) (b-2) |
(b-2) | Taxpayer’s Base Erosion Tax Benefits |
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| (a-1) (a-2) (b-1) (b-2) |
(b-1) | Taxpayer’s Base Erosion Payments |
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| (a-1) (a-2) (b-1) (b-2) |
(a-2) | Aggregate Group’s Base Erosion Tax Benefits |
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| (a-1) (a-2) (b-1) (b-2) |
(a-1) | Aggregate Group’s Base Erosion Payments |
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| (a-1) (a-2) (b-1) (b-2) |
(a-1) | Type of Base Erosion Payments | 1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ |
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| Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
1 Reserved for future use . . . . . . . . . . . . . . 2 Cost sharing transaction payments as defined in Regulations section 1.482-7(b)(1)(i) . . . . . . . . . . . . . . 3 Purchase or creations of property rights for intangibles (patents, trademarks, etc.) . . . . . . . . . . . . . . . . 4 Rents, royalties, and license fees . . . . . . . . . . . 5aCompensation/ Regulations section 1.59A-3(b)(3)(i) . . . . . . . . . . **b **Compensation/ Regulations section 1.59A-3(b)(3)(i) . . . $ 6 Interest expense . . . . . . . . . . . . . . . . 7 Payments for the purchase of tangible personal property . . . **8 ** Premiums and/ insurance and reinsurance as covered by Regulations section 1.59A-3(b)(1)(iii) . . . . . . . . . . . . . . . . |
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| 9a Nonqualified derivative payments . . . . . . . . . . b Qualified derivative payments excepted by Regulations section 1.59A-6(b) . . . . . . . . . . . $ 10 Payments reducing gross receipts made to surrogate foreign corporation . . . . . . . . . . . . . . . . . . 11 Other payments—specify . . . . . . . . . . . . . 12 Combine lines 2 through 11 . . . . . . . . . . . . 13 Base erosion tax benefits related to payments reported on lines 2 through 11, on which tax is imposed by section 871, 881, or 884(f), with respect to which tax has been withheld under section 1441 or 1442 at 30% statutory withholding tax rate or subject to tax under Regulations section 1.884-4(a)(2)(ii) at a 30% statutory rate (see instructions) . . . . . . . . . 14 Portion of base erosion tax benefits reported on lines 2 through 11, on which tax is imposed by section 871 or 881, with respect to which tax has been withheld under section 1441 or 1442 at reduced withholding rate pursuant to income tax treaty or subject to a reduced rate of tax under Regulations section 1.884-4(a)(2)(ii). Multiply the amount of the base erosion tax benefit by a fraction equal to the rate of tax imposed under the treaty over the 30% (0.30) statutory rate. See instructions. . . 15 Total base erosion tax benefits. Subtract the sum of line 13 and line 14 from line 12. Enter the amount from column (a-2) on Part I, line 2a. Enter the amount from column (b-2) on Part II, line 3b | Type of Base Erosion Payments | (a-1) (a-2) (b-1) (b-2) | ||||||||
|---|---|---|---|---|---|---|---|---|---|---|
| Aggregate Group’s Base Erosion Payments |
(a-1) | (a-1) | ||||||||
| Aggregate Group’s Base Erosion Tax Benefits |
(a-2) | (a-2) | ||||||||
| Taxpayer’s Base Erosion Payments |
(b-1) | (b-1) | ||||||||
| Taxpayer’s Base Erosion Tax Benefits |
(b-2) | (b-2) | ||||||||
| Any 25% Owner of the Taxpayer |
(c) | (Check all applicable boxes in columns (c), (d), and (e) below) |
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| Person Related Under Section 267(b) or 707(b)(1) to the Taxpayer or Any 25% Owner of the Taxpayer |
(d) | (d) | ||||||||
Any Person Related Within the Meaning of Section 482 to the Taxpayer |
(e) | (e) |
594 International Return Study
(i) Amount of deduction being waived for the tax year with respect to the item or property
(h) Amount of deduction claimed for the tax year with respect to the item or property |
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|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
(g) Country of organization of the foreign related party |
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(f) Taxpayer identification number of foreign related party |
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(e) Name of foreign related party that is or will be the recipient of the payment that generates the deduction |
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(d) Line number on the controlled group member tax return where the deduction is reported |
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(c) Provision of Code and regulations, as applicable, that allows the deduction for which this election relates |
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(b) Date on which, or period in which, the waived deduction was paid or accrued |
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| (a) Description of item or property to which the deduction relates |
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| (a) Description of item or property to which the deduction relates |
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595 International Return Study
Form 8991 (Rev. 12-2024) Page 6
Form 8991 (Rev. 12-2024)
596 International Return Study
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