Foreign Base Company Income and Insurance Income and Summary of U.S. Shareholder's Pro Rata Share of Subpart F Income of a C.F.C.
Foreign Base Company Income and Insurance Income and Summary of U.S. Shareholder's Pro Rata Share of Subpart F Income of a C.F.C.
Summary: This is an example of worksheet A, which is used to determine the shareholder's share of Subpart F income. The line items to be completed are:
| "1.Gross foreign personal holding company income (determined after the application of section 952(b):" |
| "1a.Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A) (excluding amounts described in sections 954(c)(2), (3), and (6))" field |
| "1b.Income equivalent to interest (section 954(c)(1)(E))" field |
| "1c.Net income from a notional principal contract (section 954(c)(1)(F))" field |
| "1d. Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D))" field |
| "1e.Excess of gains over losses from commodity transactions (section 954(c)(1)(C))" field |
| "1f.Excess of gains over losses from certain property transactions (section 954(c)(1)(B))" field |
| "1g.Payments in lieu of dividends (section 954(c)(1)(G))" field |
| "1h.Certain amounts received for services under personal service contracts (see section 954(c)(1)(H))" |
| "1i.Certain amounts from sales of partnership interests to which the look-through rule of section 954(c)(4) applies" |
| "2.Gross foreign personal holding company income. Add lines 1a through 1i" field |
| "3.Gross foreign base company sales income (determined after the application of section 952(b)) (see section 954(d))" field |
| "4.Gross foreign base company services income (determined after the application of section 952(b)) (see section 954(e))" field |
| "5.Gross foreign base company income. Add lines 2 through 4" field |
| "6.Gross insurance income (determined after the application of section 952(b)) (see sections 953 and 954(b)(3)(C) and the instructions for lines 16 and 17)" field |
| "7.Gross foreign base company income and gross insurance income. Add lines 5 and 6" field |
| "8.Enter 5% of total gross income (as computed for income tax purposes)" field |
| "9.Enter 70% of total gross income (as computed for income tax purposes)" field |
| "10.If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 18" field |
| "11.If line 7 is more than line 9, enter total gross income (as computed for income tax purposes) " field |
| "12.Total adjusted gross foreign base company income and insurance income (enter the greater of line 7 or line 11). See instructions" field |
| "13. Adjusted net foreign personal holding company income:" |
| "13a.Enter amount from line 2" field |
| "13b.Expenses directly related to amount on line 2" field |
| "13c.Subtract line 13b from line 13a" field |
| "13d.Related person interest expense (see section 954(b)(5))" field |
| "13e.Other expenses allocated and apportioned to the amount on line 2 under section 954(b)(5)" field |
| "13f.Net foreign personal holding company income. Subtract the sum of lines 13d and 13e from line 13c" field |
| "13g.Amount of line 13f excluded pursuant to section 952(c)" field |
| "13h.Subtract line 13g from Line 13f" field |
| "13i.Amount of line 13h excluded pursuant to the high tax exception of section 954(b)(4)" field |
| "13j.Adjusted net foreign personal holding company income. Subtract line 13i from line 13h" field |
| "14.Adjusted net foreign base company sales income:" |
| "14a.Enter amount from line 3" field |
| "14b.Expenses allocated and apportioned to the amount on line 3 under section 954(b)(5)" field |
| "14c.Net foreign base company sales income. Subtract line 14b from line 14a" field |
| "14d.Amount of line 14c excluded pursuant to section 952(c)" field |
| "14e.Subtract line 14d from Line 14c" field |
| "14f.Amount of line 14e excluded pursuant to the high tax exception of section 954(b)(4)" field |
| "14g.Adjusted net foreign base company sales income. Subtract line 14f from line 14e" field |
| "15.Adjusted net foreign base company services income:" |
| "15a.Enter amount from line 4" field |
| "15b.Expenses allocated and apportioned to line 4 under section 954(b)(5)" field |
| "15c.Net foreign base company services income. Subtract line 15b from line 15a" field |
| "15d.Amount of line 15c excluded pursuant to section 952(c)" field |
| "15e.Subtract line 15d from Line 15c" field |
| "15f.Amount of line 15e excluded pursuant to the high tax exception of section 954(b)(4)" field |
| "15g.Adjusted net foreign base company services income. Subtract line 15f from line 15e" field |
| "16.Adjusted net insurance income (other than related person insurance income):" |
| "16a.Enter amount from line 6 (other than related person insurance income)" field |
| "16b.Expenses allocated and apportioned to the amount on line 16a under section 953" field |