International

Boycott Factor (Section 999(c)(1))

SCHEDULE A

(Form 5713)

OMB No. 1545-0216

(Rev. January 1997) Complete only if you are not computing a loss of tax benefits using the specifically

attributable taxes and income method on Schedule B (Form 5713) Department of the Treasury

Internal Revenue Service © Attach to Form 5713. © See instructions on back.

Name Identifying number

Name of country being boycotted (check one): Israel Other (identify) ©

Name Purchases, sales, and payroll attributable to boycotting operations, by operation of

country

(1)

Boycott payroll

(4)

Boycott sales

(3)

Boycott purchases

(2)

a

b

c

d

e

f

g

h

i

j

k

l

m

n

o

Total

1 Numerator of boycott factor (add totals of columns (2), (3), and (4))

2 Denominator of boycott factor:

a Total purchases from countries other than United States

b Total sales to or from countries other than United States

Total payroll paid or accrued for services performed in countries other

than United States

c

d Total of lines 2a, b, and c

3 International boycott factor (divide line 1 by line 2d). Enter here and on Schedule C (Form 5713)

(see instructions) ©

If you are involved in more than one boycott, use a separate Schedule A for each boycott and attach to Form 5713.

For Paperwork Reduction Act Notice, see page 1 of the instructions for Form 5713. Cat. No. 12050W Schedule A (Form 5713) (Rev. 1-97)
Schedule A (Form 5713) (Rev. 1-97) Page 2

Column (3).—Enter the sales that are

made to or from boycotting countries

and that are attributable to the

operation reported on each line.

Controlled groups.—All members of

a controlled group generally share one

international boycott factor, which

reflects all their purchases, sales, and

payroll. However, if you belong to two

or more controlled groups, your

General Instructions

References are to the Internal

Revenue Code.

Purpose.—Complete Schedule A

(Form 5713) if you cooperated with or

participated in an international

boycott. Use the international boycott

factor to figure the loss of tax benefits.

If you do not use the international

boycott factor for this purpose, you

must specifically attribute taxes and

income on Schedule B (Form 5713).

Column (4).—Enter the total payroll

that was paid or accrued for services

performed in boycotting countries and

that are attributable to the operation

reported on each line.

Line 1.—Add columns (2), (3), and (4).

The numerator of your international

boycott factor includes all of the

following:

Partnerships and trusts.—You are

deemed to have a prorated share of

the purchases, sales, and payroll of

each partnership in which you are a

partner and of each trust if you are

treated as the owner under section

671. As a result, your international

boycott factor may also reflect

purchases, sales, and payroll of Who must file.—Anyone who partnerships and trusts. cooperates with or participates in an

international boycott must file either

this form or Schedule B (Form 5713)

to figure the loss of tax benefits. One

act of cooperation or participation

creates the presumption that you

cooperate with or participate in the

boycott unless you rebut the

presumption as explained below. The

presumption applies to all your

operations and those of each member

of any controlled groups (defined in

section 993(a)(3)) to which you belong,

in each country that helps carry out

the boycott.

1. Purchases you made from

boycotting countries.

2. Sales you made to or from

boycotting countries.

3. Payroll you paid or accrued for

services performed in boycotting

countries.

Specific Instructions

Do not include amounts attributable

to operations for which you rebutted

the presumption of cooperating with

or participating in the boycott.

Compute a separate boycott factor

and a separate schedule for each

international boycott you cooperated

with or participated in. Include your

own operations and, if applicable, the

operations of partnerships, trusts, and

members of your controlled group.

Line 2.—The denominator of the

international boycott factor reflects all

your purchases, sales, and payroll in

or related to all countries other than

the United States. If applicable, the

denominator also reflects these items

for your controlled groups,

partnerships, and trusts. Include here

the amounts that are attributable to

operations for which you rebutted the

presumption of cooperating with or

participating in the boycott.

See the specific instructions for

questions on lines 7 through 13 of

Form 5713 to see what years you

should report purchases, sales, and

payroll for partnerships, trusts, and

controlled groups. Boycott operations.—All your

operations in a boycotting country are

considered to be boycott operations,

unless you rebut the presumption of

cooperating with or participating in the

boycott, as explained below. In

addition, your operations that are not

in a boycotting country are boycott

operations if they are connected to

your cooperation with or participation

in the boycott.

Partnerships.—For a partnership,

complete only lines a through o, the

total of columns (2), (3), and (4), and

line 2. Give this information to all

partners so they can compute their

own international boycott factor.

Line 3.—Partnerships do not enter the

amount from line 3 on Schedule C. All

others enter the international boycott

factor from line 3 of this form on the

appropriate line of Schedule C (Form

5713) as follows:

Column (1).—Enter the name of the

country that requires participation in or

cooperation with an international

boycott as a condition of doing

business in that country. The country

named in column (1) is not necessarily

the country in which the operation

takes place. For example, if you have

an operation in Country Z that is not a

boycotting country and the operation

related to Country X that is a

boycotting country, enter the name of

Country X in column (1). The Secretary

maintains a list, under section

999(a)(3), of countries that require

participation in or cooperation with an

international boycott. This list may not

be all-inclusive.

● If you reduce your foreign tax credit

(section 908(a)), enter the international

boycott factor on line 2a(2).

Rebutting the presumption of

boycott cooperation or participation.—

You can rebut the presumption of

cooperation with or participation in a

boycott for a particular operation by

demonstrating that the operation is

separate from any cooperation with or

participation in an international

boycott. The presumption applies only

to operations in countries that carry

out the boycott. You do not need to

rebut the presumption for operations

that are related to those countries, but

that take place outside of those

countries.

● If you are denied a tax deferral on

subpart F income (section 952(a)(3)),

enter the international boycott factor

on line 3a(4).

● If you are denied a tax deferral on

IC-DISC income (section

995(b)(1)(F)(ii)), enter the international

boycott factor on line 4a(2).

Column (2).—Enter all purchases that

are made from boycotting countries

that are attributable to the operation

reported on each line.

● If you are denied an exemption of

foreign trade income of a FSC (section

927(e)(2)), enter the international

boycott factor on line 5a(2).

International boycott factor.—Your

international boycott factor reflects

boycott purchases, boycott sales, and

boycott payroll.

Show all boycott purchases, boycott

sales, and boycott payroll from one

operation on one line.

Complete columns (1) through (4) in

the following manner:

international boycott factor will reflect

the purchases, sales, and payroll of all

the controlled groups to which you

belong.