Page4

AFFIDAVIT

I swear (or affirm) that the foregoing is to the best of my knowledge and belief a true and complete statement of facts
relating to the credit for tax as provided in section 131 of the Internal Revenue Code.

Subscribed and sworn to before me this

aany 194.

iflicer administering oath)

(Official capacity)

(Signature of claimant or agent)

EXTRACTS FROM SECTION 131 OF THE INTERNAL REVENUE CODE
TAXES OF FOREIGN COUNTRIES AND POSSESSIONS OF UNITED STATES

Sno, 181, (a) Allowance of Credit—If the taxpayer
chooses to have the benefits of this section, the tax imposed
by this chapter, except the tax imposed under section 102,
shall be credited with:

(1) Citizens and Domestic Corporations—In the case
of a citizen of the United States and of a domestic corpora-
tion, the amount of any income, war-profits, and excess-
profits taxes paid or accrued during the taxable year to
any foreign country or to any possession of the United
States; and

(2) Resident of United States.—In the case of a resi-
dent of the United States, the amount of any such taxes
paid or accrued during the taxable year to any possession
of the United States; and

(8) Alien. Resident of United States—In the case of
an alien resident of the United States, the amount of any
such taxes paid or accrued during the taxable year to any
foreign country, if the foreign country of which such alien
resident is a citizen or subject, in imposing such taxes,
allows a_similar credit to citizens of the United States
residing in such country; and

(4) Partnerships and Estates—In the case of any
such’ individual who is a member of a partnership or a
beneficiary of an estate or trust, his proportionate share of
such taxes of the partnership or the estate or trust paid or
accrued during the taxable year to a foreign country or to
any possession of the United States, as the case may be.

‘uch choice may be made or changed at any time prior
to the expiration of the period prescribed for makin;
claim for credit or refund of the tax imposed by this
chapter.

b) Limit on Credit—The amount of the credit taken
under this section shall be subject to each of the following
limitations:

(1) The amount of the credit in respect of the tax paid
or acerued to any country shall not exceed, in the case of
a taxpayer other than a corporation, the same proportion
of the tax against which such credit is taken, which the
taxpayer's net income from sources within such country
bears to his entire net income for the same taxable year,
or in the ease of a corporation, the same proportion of the
tax against which such credit is taken, which the taxpayer's
normal-tax net income from sources within such country
bears to its entire normal-tax net income for the same
taxable year; and

(2) The total amount of the credit shall not exceed, in
the case of a, taxpayer other than a corporation, the same
proportion of the tax against which such credit is taken,
Which the taxpayer's net income from sources without the
United States bears to his entire net income for the same
taxable year, or, in the case of a corporation, the same
proportion of the tax against which such credit is taken,
Which the taxpayer's normal-tax net income from sources

without the United States bears to its entire normal-tax net
income for the same taxable year;
. $ ? x * *

(c) Adjustments on Payment of Accrued Taxes.—If
acerued taxes when paid differ from the amounts claimed
as credits by the taxpayer, or if any tax paid is refunded
in whole or in part, the taxpayer shall notify the Commis-
sioner, who shall redetermine the amount of the tax for
the year or years affected, and the amount of tax due upon
such redetermination, if any, shall be paid by the tax-
payer upon notice and demand by the collector, or the
amount of tax overpaid, if any, shall be credited or refunded
to the taxpayer in accordancé with the provisions of sec-
tion $22, In the case of such a tax accrued but not paid,
the Commissioner as a condition precedent to the allowance
of this credit may require the taxpayer to give a bond with
sureties satisfactory to and to be approved by the Commis-
sioner in such sum as the Commissioner may require, con-
ditioned upon the payment by the taxpayer of any amount
of tax found due upon any such redetermination; and the
bond herein prescribed shall contain such further conditions
as the Commissioner may require.

(d) Year in Which Credit Taken.—The credits provided
for in this section,may, at the option of the taxpayer and
irrespective of the’method of accounting employed in keep-
ing his books, be taken in the year in which the taxes of the
foreign country or the possession of the United States
accrued, subject, ‘however, to the conditions prescribed in
subsection (c) of this section. If the taxpayer elects to
take such credits in the year in which the taxes of the
foreign country or the possession of the United States
accrued, the credits for all subsequent years shall be taken
upon the same basis, and no portion of any such taxes shall
be allowed as a deduction in the same or any succeeding

year.
(e) Proof of Credits.—The credits provided in this sec-
tion shall be allowed only if the taxpayer establishes to the
satisfaction of the Commissioner (1) the total amount of
income derived from sources without the United States,
determined as provided in section 119, (2) the amount of
income derived from each country, the tax paid or accrued
to which is claimed as a credit under this section, such
amount to be determined under rules and regulations pre-
scribed by the Commissioner with the approval of the
Secretary, and (3) all other information necessary for the
verification and computation of such credits.
* * * * * * *
(h) Credit for Taxes in Lieu of Income, Etc., Taxes.—
For the purposes of this section and section 23 (c) (1), the
term “income, war-profits, and excess-profits taxes” shall
include a tax paid in lieu of a tax upon. income, war-profits,
or excess-profits otherwise generally imposed by any for-
eign country or by any possession of the United States.

INSTRUCTIONS

Wuen Crevir For TAXES May Br TAKEN.—The credit for taxes provided by section 131 (a) may ordinarily be taken
either in the return for the year in which the taxes accrued or in which the taxes were paid, dependent upon whether the
accounts of the taxpayer are kept and his returns filed upon the accrual basis or upon the cash receipts and disbursements
basis. Where a taxpayer keeps his books of account on the accrual basis, a credit for taxes, paid to a foreign country
must also be taken on that basis and the time of payment of the taxes has in such case nothing to do with the time of
credit. A taxpayer whose books of account are kept on the cash receipts and disbursements basis has the privilege of tak-
ing the credit for foreign taxes on an accrual basis, but if he elects to do so, the credit for foreign taxes with respect to all

uw

sequent years must be taken upon the same basis.

LO-A1T3S-L —U. S. GOVERNMENT PRINTING OFFICE


Form 1116 Page 1
U. 8, TREASURY DEPARTMENT
INTERNAL REVENUE SERVICE

STATEMENT IN SUPPORT OF CREDIT CLAIMED BY INDIVIDUAL FOR TAXES PAID OR ACCRUED
TO A FOREIGN COUNTRY OR A POSSESSION OF THE UNITED STATES
TO BE FILED BY AN INDIVIDUAL, PARTNERSHIP, OR FIDUCIARY
For Calendar Year 1944

Or fiscal year beginning _... .... 1944, and ending ._....

Name ..
Address

TO BE FILLED IN IF CLAIMANT IS AN INDIVIDUAL

Claim for credit is made by the taxpayer named above, who is a citizen or subject of _..

(Name of country)
based on income .

and is a resident of

for the taxable year begun -. ., and ended ...

taxes -... *, as follows:

(Paid or acerued)

ions for any income, war-profits, and

I. Total net income from all sources (computed without dedu
excess-profits taxes paid or accrued to foreign countries or possessions of the United States)... $......
8.

IL. Total United States income tax (before credit for foreign taxes)

SCHEDULE A—Tax Paid or Accrued to a Possession of the United States ****°

Name of possession of U. S. Character of tax

Statute imposing tax .

Date of accrual . Date of payment (if paid) — 7
(To be given even if claim is based on payment) (To be given even if claim is based on accrual)
1. Amount of tax* (evidenced by attached receipt or return) .. 4, which (converted
(In foreign money)
at an exchange rate of -. _*) equals in dollar:

* which (converted at an exchange
)-.
SCHEDULE B—Tax Paid or Accrued to a Foreign Country °""*°

.- Character of tax i

2, Income from sources in this possession ....

(In foreign money)
®) equals in dollars (reported on Form 1040, as Item

rate of ..

Name of foreign country -.

Statute imposing tax -...

Date of accrual ... _ Date of payment (if paid) -

(To be given even if claim is based on payment) (To be given even if claim is based on accrual)
1. Amount of tax* (evidenced by attached receipt or return) _. oes, Whieh (converted
(in foreign money)
at an exchange rate of _) equals in dollar:

2. Income from sources in this foreign country -.. ‘ which (converted at an exchange

(in foreign money)
-) equals in dollars (reported on Form 1040, as Item .-

SCHEDULE C—Tax Paid or Acerued With Respect to Taxpayer's Income Withheld Under a Law of a Foreign Country®
or a Possession of the United States*

rate of __

Character of tax

Name of foreign country or possession of U. S...
(income, war-profits, of excess-profits)

Statute imposing tax __.

Name of withholding agent _ . Date of withholding —..

1, Amount of tax withheld (evidenced by attached receipts or statement from withholding agent)

which (converted at an exchange rate of __. *) equals in dollars...

“Gi foreign money)
2. Income from sources in above-named country or possession, which is not included in any other sched-

ule on this form , which (converted at an exchange rate of -.

equals in dollars (reported on Form 1040, as Item ..
(See footnotes on page 2)
1e—si738—4


Page 2

SCHEDULE D—Income (or Loss) from Sources Within a Foreign Country or a Possession of the United States on Which
No Income or Profits Taxes Were Imposed °

1, Name of country

2, Amount of income (or loss) ..

‘, which (converted at an exchange rate
(In foreign money)

*) equals in dollars (reported on Form 1040, as Item ..

of _

-)

SCHEDULE E—Tax Paid or Accrued to a Foreign Country or a Possession of the United States by a Partnership, Estate, or
Trust, in Which Claimant Has an Interest *

Partnership, estate, or trust ___

(Name) (Address)

Fiduciary (if estate or trust).

(Name) (Address)
Character and extent of claimant's interest in partnership, estate, or trust

Name of foreign country or possession of U. S.

Character of tax
(Income, war-pro

Statute imposing tax -.

Date of accrual _

Date of payment (if paid)

(To be given even if claim is based on payment) ‘To be given even if claim

1, Total tax paid by partnership or fiduciary -

4, which (converted at an exchange rate of
(In foreign money)

*) equals in dollars...

2, Claimant’s share of such tax as reported on partnership or fiduciary return...

8. Total net income derived from partnership or fiduciary (reported on Form 1040, as Ttem _.

4, That portion of such income which was derived from sources within this foreign country or possession
of United States.

TO BE FILLED IN BY A PARTNERSHIP OR FIDUCIARY

SCHEDULE F—Tax Paid or Accrued to a Foreign Country on ora Possession of the United States by a Partnership, Estate,
or Trust

Partnership, estate, or trust ..

(Name) (Address)

Fiduciary (if estate or trust) .

(Name) (Address)

The attached . return is based on income

year begun .. _, 19......, and ended

Name of foreign country or possession of U. S. .. ~ Character of tax
ine

Statute imposing tax -.

(To be named fully and clearly s0 as to be easily identified)

Date of accrual Date of payment (if paid) -
(Both date of accrual and date of payment (if paid) must be given) (Both date of accrual and date of Payment (if paid) must be given)

1. Total amount of this tax payment or accrual (evidenced by attached receipt or return)

Gin foreign ‘acne?

which (converted at an exchange rate of . °) equals in dollars __

2. Total net income reported on partnership or fiduciary return

3. That portion of such income which was derived from sources within this foreign country or posses-
sion of United States ..

FOOTNOTES

11f income return is based on income “accrued,” or you elect under Section 131 (d) to claim credit for taxes accrued, write “accrued” In the space
provided. (See Section 181 (d) and instructions on pase 4.

2To ‘secure credit for taxes paid or accrued to possessions of the United States, claimant must be a citizen other than a citizen entitled to benefits of
Section 251, or a resident of the United States.

"Amount of tax" means tax proper, excluding any amount that represents interest or penalties. If the tax has been actually paid in full, the
arent of the tax (excluding interest and penalties) so paid is the amount to be entered in this blank, even though the claim be based on the accrual
of the tax.

“State this amount in the curreney of the foreign country or p ion of the United States (e. s., pounds, franes, marks). .

'Give the rate of exchange used and attach a statement describing in reasonable detail why and how this particular tate was determined.

© To secure credit for taxes paid or accrued to a foreign country, claimant must be a citizen other than_a citizen entitled to benefits of Section 251,
or a resident of the United States. | Moreover, if he is an alien resident, he must be a citizen or subject of a foreign country which allows “a similar
credit to citizens of the United States residing in such country.” (See Section 131 (a) on page 4.)

‘Where there is more than one possession of the United States or one foreign country, to which taxes are paid by claimant individually, or by
partnership, estate, or trust in which claimant has an interest, additional Schedules A to G, inclusive, should be attached, and the amount of the credit
shown on each Schedule A to F, inclusive, should be included in each geparate Summary G.

‘The sum of amounts shown in Item VI of Schedule G from various foreign countries or possessions of United States is subject to the limitation of
Section 131 (b) (2) as computed in Combined Summary.
Tn case there is net loss from sources within a foreign country or possession of United States, report it n this schedule,

16—41798-1


Page 3

SCHEDULE G °—Separate Summary‘ of Income Received From and Taxes Paid to Each Foreign, Country or Possession of
United States as Shown in Schedules A to E on Pages 1 and 2

Name of foreign country or possession of United States -. .

Column A Column B
Income or loss ‘Taxes paid or accrued *

Schedule A, Schedule A, Item 1_....

Schedule B, Schedule B, Item 1.....

Schedule C, Schedule C, Item 1__...

Schedule D, Schedule E, Item 2...

Schedule E, Item 4 Total (enter as Item II below)...

Total (enter as Item I below)... $

I. Total net income from sources within this foreign country or possession of United States (computed
without deductions for any income and profits taxes imposed by any foreign country or possession
of United States)...

Il, Total tax paid or accrued to this foreign country or possession of United States.

IM. Total net income from all sources (same as Item I, page 1).....

IV. Ratio of income from sources within this foreign sory or Poses
income from all sources (Item I divided by Item IIl)...........

V. Total United States income tax on Item III (same as Item II, page 1)... -

VI. Amount of tax which may be claimed as a credit under the limitation of Section 131 (b) (1) (Item V
multiplied by Item IV, or Item II, whichever amount is the smaller) $

COMBINED SUMMARY ®* OF INCOME RECEIVED FROM AND CREDITS FOR TAXES PAID TO ALL FOREIGN
COUNTRIES OR POSSESSIONS OF UNITED STATES AS SHOWN IN SCHEDULE G, ITEMS I AND VI,
RESPECTIVELY

FOREIGN COUNTRY OR POSSESSION OF UNITED STATES Re ees (item Vie Schedute G)

Totals (enter as Items I and II below)...

I, Net income from sources without United States_...

II. Sum of credits for taxes paid or accrued to foreign courtries or possessions of United States com-
puted separately under limitation of Section 131 (b) (1).

III. Total net income from all sources (computed without deduction for any income and profits taxes paid
or accrued to foreign countries or possessions of United States) (same as Item III, Schedule G)...

IV, Ratio of income from sources without United States to total income from all sources (Item T divided
by Item III)...

V. Total United States income tax on Item III (same as Item V, Schedule G)...

VI. Amount of tax which may be claimed as a credit under the limitation of Section 181 (b) (2) (Item v
multiplied by Item IV, or Item II, whichever amount is the smaller)-... . §$.

(See footnotes on page 2)

16—41738-1