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TLS, have you I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING


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cycle update? Sch J (Form 1118), PAGE 1 of 4
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Schedule J Adjustments to Separate Limitation Income (Loss) Categories for Determining


(Form 1118) Numerators of Limitation Fractions, Year-End Recharacterization Balances, and
(Rev. December 2004) Overall Foreign Loss Account Balances OMB No. 1545-0122

For calendar year 20 , or other tax year beginning , 20 , and ending , 20


Department of the Treasury
Internal Revenue Service 䊳 Attach to Form 1118. For Paperwork Reduction Act Notice, see the Instructions for Form 1118.
Name of corporation Employer identification number

Part I Adjustments to Separate Limitation Income or (Losses) in Determining Numerators of Limitation Fractions (See instructions.)
(vi) (vii) (viii)
(i) (ii) (iii) (iv) (v) Certain (ix)
Dividends Taxable income
General Passive High Financial Shipping from a DISC attributable to distributions Other
limitation income withholding services income or former foreign trade from a FSC or
income tax interest income income*
DISC income former FSC
1 Income or (loss) before adjustments (see
instructions).
2 Allocation of current year separate limitation losses:
a General limitation income ( )( )( )( ) ( ) ( ) ( ) ( )
b Passive income ( ) ( )( )( ) ( ) ( ) ( ) ( )
c High withholding tax interest ( ) ( ) ( )( ) ( ) ( ) ( ) ( )
d Financial services income ( ) ( )( ) ( ) ( ) ( ) ( ) ( )
e Shipping income ( ) ( )( )( ) ( ) ( ) ( ) ( )
f Dividends from a DISC or former DISC ( ) ( )( )( )( ) ( ) ( ) ( )
g Taxable income attributable to foreign trade income ( ) ( )( )( )( )( ) ( ) ( )
h Certain distributions from a FSC or former FSC ( ) ( )( )( )( )( )( ) ( )
i Other Income* ( ) ( )( )( )( )( )( )( )
3 Subtotal—Combine lines 1 through 2i.
4 Overall foreign losses
5 Recapture of overall foreign losses

6 Subtotal—Subtract line 5 from line 3.


7 Recharacterization of separate limitation income:
a General limitation income ( )
b Passive income ( )
c High withholding tax interest ( )
d Financial services income ( )
e Shipping income ( )
f Dividends from a DISC or former DISC ( )
g Taxable income attributable to foreign trade income ( )
h Certain distributions from a FSC or former FSC ( )
i Other Income* ( )
8 Subtotal—Combine lines 6 through 7i.
* Important: See Computer-Generated Schedule J in instructions. Cat. No. 10309U Schedule J (Form 1118) (Rev. 12-2004)
4
I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
Sch J (Form 1118), PAGE 2 of 4
MARGINS: TOP 13 mm (1⁄2 "), CENTER SIDES. PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20. INK: BLACK
FLAT SIZE: 279 mm (11")  216 mm (8 ⁄2 ")
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PERFORATE: (NONE)
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Schedule J (Form 1118) (Rev. 12-2004) Page 2


(vi) (vii) (viii)
(i) (ii) (iii) (iv) (v) Taxable income Certain (ix)
General Passive High Financial Shipping Dividends from attributable to distributions Other
limitation income withholding services income a DISC or foreign trade from a FSC or income*
income tax interest income former DISC income former FSC

9 Subtotal—Enter amounts from Part I, line 8


10 Allocation of current year U.S. source losses
(see instructions)
11 Numerator of Limitation Fraction—Subtract line 10
from line 9. Enter each result here and on Part II,
line 6, of corresponding Schedule B.

Part II Year-End Balances of Future Separate Limitation Income That Must Be Recharacterized
a General limitation income
b Passive income
c High withholding tax interest
d Financial services income
e Shipping income
f Dividends from a DISC or former DISC
g Taxable income attributable to foreign trade
income
h Certain distributions from a FSC or former FSC
i Other income*
Part III Overall Foreign Loss Account Balances (section 904(f)(1))
Complete for each separate limitation income category
1 Beginning balance
2 Current year additions
3 Current year reductions (other than recapture) ( )( )( )( )( )( )( )( )( )
4 Subtotal—Combine lines 1 through 3
5 Current year recapture (from Part I, line 5)

6 Ending balance—Subtract line 5 from line 4.


* Important: See Computer-Generated Schedule J in instructions.
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I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
Sch J (1118), PAGE 3 OF 4
MARGINS; TOP 13mm (1/2"), CENTER SIDES. PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20. INK: BLACK
FLAT SIZE: 216mm (8-1/2") x 279mm (11")
PERFORATE: None
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Schedule J (Form 1118) (Rev. 12-2004) Page 3

General Instructions 2. If the combined separate limitation To compute the portion of the $2,000
losses for the tax year do not exceed separate limitation loss that is allocable
Section references are to the Internal the combined separate limitation income to general limitation income, Corporation
Revenue Code unless otherwise noted. for the tax year, the pro rata share of X divides the $4,000 of income by
each separate limitation loss to allocate $5,000 (the combined separate limitation
Purpose of Schedule to each category with positive income is income from all separate categories with
as follows: positive income). The result of 80% is
● Use Part I to show adjustments to Separate limitation multiplied by the separate limitation loss
separate limitation income or (losses) in income Separate of $2,000. Corporation X enters the
determining the numerator of the × limitation loss product of $1,600 on line 2e, column (i).
Combined separate being allocated
limitation fraction for each separate limitation income from To compute the portion of the $2,000
category. all categories with separate limitation loss that is allocable
positive income
● Use Part II to show the year-end to financial services income, Corporation
balances of future separate limitation 3. If the combined separate limitation X divides the $1,000 of separate
income that must be recharacterized as losses for the tax year exceed the limitation income by $5,000. The result
income of other separate categories (as combined separate limitation income for of 20% is multiplied by the separate
the result of current year or prior year the tax year, the pro rata share of each limitation loss of $2,000. Corporation X
separate limitation losses that were separate limitation loss to allocate to enters the product of $400 on line 2e,
allocated to those other separate each category having income is as column (iv).
categories). follows: Corporation X enters $2,400 ($4,000
● Use Part III to show: (a) the balances Separate limitation loss minus $1,600) on line 3, column (i); $600
in the corporation’s overall foreign loss being allocated Separate limitation ($1,000 minus $400) on line 3, column
× income in a given
accounts at the beginning of the tax Combined separate category (iv); and $0 (negative $2,000 plus
year, (b) any current year adjustments, limitation losses from all positive $2,000) on line 3, column (v).
and (c) the balances in the overall categories with losses
Line 4. Enter the overall foreign losses
foreign loss accounts at the end of the If separate limitation losses can be for the tax year (from line 3) if they have
tax year. allocated, enter the total amounts reduced U.S. source income for the tax
Important: Complete Schedule J only allocated in the bold-outlined boxes as year.
once. Include adjustments for each positive numbers. Enter each separate Important: If an overall foreign loss has
applicable separate category. amount allocated to a given category reduced U.S. source income, do not
across the same line under the complete the remainder of Part I for that
Computer-Generated Schedule J appropriate column heading to which it separate category. However, complete
A computer-generated Schedule J can was allocated. Parts II and III for that category to show
be filed if it conforms to the IRS version Note: The numbers entered across any the year-end balance in the separate
of the schedule. Expand Schedule J to given line should “zero out.” limitation loss and overall foreign loss
properly complete Parts I, II, and III of The combined separate limitation accounts.
the Schedule if the corporation has more losses for the tax year that are more Line 5. Recapture overall foreign losses
than one separate category of “other than the combined separate limitation that reduced U.S. source income in prior
income.” Income from each sanctioned income for the tax year reduce the U.S. tax years (section 904(f)(1)). To do this,
country to which section 901(j) applies source income (if any) for the tax year. If treat a portion of the current year
and each item of income resourced the corporation has no U.S. source separate limitation income that is of the
under a tax treaty are treated as a income for the tax year, or if the excess same category as the loss that resulted
separate category of “other income.” of its combined separate limitation in the prior year overall foreign loss as
losses for the tax year over combined U.S. source income. Recapture
Specific Instructions separate limitation income for the tax continues until the applicable overall
year exceeds its U.S. source income for foreign loss account balance (Part III) is
Part I the tax year, the excess is treated as a reduced to zero.
net operating loss. This loss may be The amount of any current year
Note: See Notice 89-3, 1989-1 C.B.
carried over or back to other tax years separate limitation income subject to
623, and Regulations section 1.904(f)-12
according to the rules of section 172. recapture is the smaller of the balance in
for more information on the ordering of
adjustments in Part I. Example 1. Corporation X has separate the applicable overall foreign loss
limitation income of $4,000 in its general account (the applicable line 1 amount of
Line 1. Enter in each applicable column
limitation income category (line 1, Part III), or 50% of all amounts entered
the income or (loss) from column 12 of
column (i)) and separate limitation on line 3, Part I.
the corresponding Schedule A for that
income of $1,000 in its financial services The corporation can make an annual,
separate category.
income category (line 1, column (iv)). In revocable election to recapture a greater
Important: Be sure to consider on this addition, the corporation has a separate
line the possible interplay between portion of the balance in an overall
limitation loss of $2,000 in its shipping foreign loss account by attaching a
separate limitation losses and any net income category (line 1, column (v)).
operating losses or net capital losses of statement to Form 1118 indicating:
Since the corporation’s combined 1. The percentage and dollar amount
which they may be a part.
separate limitation losses for the tax of the separate limitation income that is
Line 2. This allocation grid must be year ($2,000) do not exceed its
completed to show the pro rata share of treated as U.S. source income and
combined separate limitation income for
each separate limitation loss to allocate the tax year ($5,000), the entire $2,000 2. The percentage and dollar amount
among other applicable separate may be allocated to other separate of the balance (both before and after
categories. categories. Therefore, Corporation X recapture) in the overall foreign loss
To determine each pro rata share: enters a positive $2,000 account that is recaptured.
1. Add all of the separate limitation in the bold-outlined box on line 2e,
loss amounts entered across line 1. column (v).
Then add all of the separate limitation
income amounts entered across line 1.
4
I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
Sch J (1118), PAGE 4 OF 4
MARGINS; TOP 13mm (1/2"), CENTER SIDES. PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20. INK: BLACK
FLAT SIZE: 216mm (8-1/2") x 279mm (11")
PERFORATE: None
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Schedule J (Form 1118) (Rev. 12-2004) Page 4


If the corporation disposes of property separate limitation loss recharacterized separate category(ies) with income on
that was used predominantly in a foreign should be entered as a positive number line 9 for the current tax year using the
trade or business and that generated on the same line under the appropriate rules set forth above.
foreign source income in the same column heading to which it was U.S. source losses in excess of the
separate category as the applicable recharacterized. combined line 9 income for a tax year
overall foreign loss account, the Note: The numbers entered across any must be treated as a net operating loss
corporation generally must recognize given line should “zero out.” that may be carried back or forward to
gain on the disposition to the extent of other tax years using the rules of section
Example 2. Assume the same facts in
the balance in the account (after 172.
Example 1 on page 3. Also assume that,
amounts are recaptured under section
in a subsequent tax year, Corporation X Part II
904(f)(1)), whether or not gain would
has $1,500 of income in its shipping
otherwise be recognized on the If a separate limitation loss was
income category (on line 6, column (v),
disposition. See section 904(f)(3) and allocated in a prior tax year and the
of its Schedule J).
Regulations section 1.904(f)-2(d). Such corporation has income during the
gain is treated as foreign source taxable Since there is not enough under
shipping income to recharacterize the current tax year in the separate category
income in the same separate category from which the loss was allocated, that
as the applicable overall foreign loss entire $2,000 prior-year balance
remaining to be recharacterized, current year income (if it was not
account and is subject to recapture to previously recharacterized) must be
the extent of the corporation’s foreign Corporation X will prorate the $1,500 of
income in that subsequent year as recharacterized as income of the
source taxable income in that separate category to which the loss was allocated
category or, if less, 100% of the follows.
in the prior year(s) (section 904(f)(5)).
corporation’s foreign source taxable ● To compute the portion to be
income. recharacterized as general limitation To determine the amounts to enter
income, Corporation X should: into the grid:
Note: For dispositions after October 22,
2004, the previous paragraph applies to 1. Divide the $1,600 remaining to be 1. Add the current year separate
certain dispositions of stock in a CFC. recharacterized from shipping income to limitation loss allocations (subject to
See section 904(f)(3)(D) for details. general limitation income by the $2,000 Regulations section 1.904(f)-1(d) capital
remaining to be recharacterized from gains adjustments) to last year’s
Line 7. If a separate limitation loss was year-end balances.
allocated in a prior tax year and the shipping income to all separate
corporation has income during the categories. 2. Subtract the amounts
current tax year in the separate category 2. Multiply the result (80%) by the recharacterized during the current tax
from which the loss was allocated, that $1,500 of shipping income. year.
current year income (if it was not 3. Enter $1,200 as a positive number 3. Enter the result on the line (line a–i)
previously recharacterized) must be on line 7e, column (i). for the separate category from which
recharacterized as income of the losses were previously allocated, under
separate category(ies) to which the loss ● To compute the portion to be the appropriate column (column (i)–(ix))
was allocated in the prior year(s) (section recharacterized as financial services to which the losses were previously
904(f)(5)). income, Corporation X should: allocated.
If a prior year separate limitation loss 1. Divide the $400 remaining to be Example 3. Assume the same facts in
was allocated to more than one separate recharacterized from shipping income to Example 1 on page 3. Also assume that
category and there is not enough financial services income by $2,000. Corporation X does not have any
current year income in the separate 2. Multiply the result (20%) by the remaining balances from any prior
category from which the loss was $1,500 of shipping income. allocations of losses from its shipping
allocated to recharacterize all remaining 3. Enter $300 as a positive number on income category to its general limitation
balances, then the current year income line 7e, column (iv). income or its financial services income.
must be recharacterized as income of Corporation X enters the $1,500 of The corporation should enter $1,600 on
the other separate categories on a pro shipping income that was line e, column (i), and $400 on line e,
rata basis in the following manner: recharacterized in the bold-outlined box column (iv).
Amount remaining to at line 7e, column (v). Note that the total Part III
be recharacterized amounts entered across line 7e now
Current year income as income of a given Line 1. Enter the ending balances from
in separate category equal zero.
separate category last year’s schedule.
from which losses × Finally, Corporation X completes the
were previously Amounts remaining to Part II recharacterization balances grid Lines 2, 3, and 5. Show any
allocated be recharacterized as
income of all separate by entering $400 ($1,600 minus $1,200) adjustments made to the overall foreign
categories on line e, column (i), and $100 ($400 loss accounts for each separate
minus $300) on line e, column (iv). category during the tax year. See
Any amount that is not recharacterized Regulations section 1.904(f)-1(d) for a list
during the tax year (i.e., the excess of Line 10. Enter U.S. source losses
allocated to separate categories with of possible additions to the accounts.
separate limitation losses previously See Regulations section 1.904(f)-1(e) for
allocated over current year income in income on line 9 for the current tax year.
Use the following formula: a list of possible reductions (including
that same separate category) must be recapture).
entered into the grid at Part II. Line 9 income in a given
Note: Recharacterization of separate category Line 6. Enter the year-end balances of
U.S. source loss × the overall foreign loss accounts for
limitation income does not result in Combined line 9 income
recharacterizing any tax. The rules of of all categories with each separate category.
Regulations section 1.904-6 apply on an income on line 9
annual basis for allocating taxes to U.S. source losses that are part of a
separate categories. net operating or net capital loss that are
If prior year separate limitation losses carried back or forward to the current
can be recharacterized, the total tax year (section 172 or Regulations
amounts recharacterized should be sections 1.1502-21(b) and 1.1502-79(a))
entered into the bold-outlined boxes as are allocated first to U.S. source income
negative numbers. Each prior-year for the current tax year, and then to the

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