Form 1118 

(Rev. December 2014)

Department of the Treasury 

Internal Revenue Service 

Foreign Tax Credit—Corporations

▶ Information about Form 1118 and its separate instructions is at www.irs.gov/form1118. 

▶ Attach to the corporation's tax return.

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

OMB No. 1545-0123

Name of corporation Employer identification number

Use a separate Form 1118 for each applicable category of income listed below. See Categories of Income in the instructions. Also, see Specific Instructions. 

Check only one box on each form.

Passive Category Income Section 901(j) Income: Name of Sanctioned Country ▶

General Category Income Income Re-sourced by Treaty: Name of Country ▶

Schedule A Income or (Loss) Before Adjustments (Report all amounts in U.S. dollars. See Specific Instructions.)

1. Foreign Country or

U.S. Possession (Enter 

two-letter code; see 

instructions. Use

a separate line for 

each.) *

Gross Income or (Loss) From Sources Outside the United States (INCLUDE Foreign Branch Gross Income here and on Schedule F)

2. Deemed Dividends (see instructions)

(a) Exclude gross-up (b) Gross-up (sec. 78)

3. Other Dividends

(a) Exclude gross-up (b) Gross-up (sec. 78)

4. Interest

5. Gross Rents,

Royalties, and 

License Fees

6. Gross Income

From Performance 

of Services

7. Other (attach

schedule)

8. Total (add columns

2(a) through 7)

 

A

B

C

D

E

F

Totals (add lines A through F)

* For section 863(b) income, NOLs, income from RICs, and high-taxed income, use a single line (see instructions).

Deductions (INCLUDE Foreign Branch Deductions here and on Schedule F)

9. Definitely Allocable Deductions

Rental, Royalty, and Licensing Expenses

(a) Depreciation,

Depletion, and

Amortization

(b) Other 

Expenses

(c) Expenses

Related to Gross 

Income From 

Performance of 

Services

(d) Other

Definitely 

Allocable 

Deductions

(e) Total Definitely

Allocable

Deductions (add 

columns 9(a) 

through 9(d))

10. Apportioned Share

of Deductions Not 

Definitely Allocable 

(enter amount from 

applicable line of 

Schedule H, Part II, 

column (d))

11. Net Operating

Loss Deduction

12. Total

Deductions (add 

columns 9(e) 

through 11)

13. Total Income or

(Loss) Before

Adjustments (subtract

column 12 from

column 8)

 

A

B

C

D

E

F

Totals

For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 10900F Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 2 

Schedule B Foreign Tax Credit (Report all foreign tax amounts in U.S. dollars.)

Part I—Foreign Taxes Paid, Accrued, and Deemed Paid (see instructions)

1. Credit is Claimed

for Taxes (check one):

Paid Accrued

Date Paid Date Accrued

2. Foreign Taxes Paid or Accrued (attach schedule showing amounts in foreign currency and conversion rate(s) used)

Tax Withheld at Source on:

(a) Dividends (b) Interest (c) Rents, Royalties,

and License Fees

Other Foreign Taxes Paid or Accrued on:

(d) Section

863(b) Income

(e) Foreign

Branch Income (f) Services Income (g) Other

(h) Total Foreign Taxes

Paid or Accrued (add

columns 2(a) through 2(g))

3. Tax Deemed Paid

(from Schedule C—

Part I, column 12, 

Part II, column 8(b), 

and Part III, column 8) 

A

B

C

D

E

F

Totals (add lines A through F)

Part II—Separate Foreign Tax Credit (Complete a separate Part II for each applicable category of income.)

1a Total foreign taxes paid or accrued (total from Part I, column 2(h)) . . . . . . . . . . . . . . . . . . . . . . .

b Foreign taxes paid or accrued by the corporation during prior tax years that were suspended due to the rules of section 909 and for 

which the related income is taken into account by the corporation during the current tax year (see instructions) . . . . . . . .

2 Total taxes deemed paid (total from Part I, column 3) . . . . . . . . . . . . . . . . . . . . . . . . . . .

3 Reductions of taxes paid, accrued, or deemed paid (enter total from Schedule G) . . . . . . . . . . . . . . . . . . ( )

4 Taxes reclassified under high-tax kickout . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5 Enter the sum of any carryover of foreign taxes (from Schedule K, line 3, column (xiv) and from Schedule I, Part III, line 3) plus any 

carrybacks to the current tax year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

6 Total foreign taxes (combine lines 1a through 5) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

7 Enter the amount from the applicable column of Schedule J, Part I, line 11 (see instructions). If Schedule J is not required to be completed, enter the 

result from the “Totals” line of column 13 of the applicable Schedule A . . . . . . . . . . . . . . . . . . . . . . . . . . .

8a Total taxable income from all sources (enter taxable income from the corporation’s tax return) . . . . . . . . . . . . . .

b Adjustments to line 8a (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

c Subtract line 8b from line 8a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9 Divide line 7 by line 8c. Enter the resulting fraction as a decimal (see instructions). If line 7 is greater than line 8c, enter 1 . . . . . . . . . . .

10 Total U.S. income tax against which credit is allowed (regular tax liability (see section 26(b)) minus American Samoa economic development credit) . .

11 Credit limitation (multiply line 9 by line 10) (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

12 Separate foreign tax credit (enter the smaller of line 6 or line 11 here and on the appropriate line of Part III) . . . . . . . . . . . . . . .

Part III—Summary of Separate Credits (Enter amounts from Part II, line 12 for each applicable category of income. Do not include taxes paid to sanctioned countries.)

1 Credit for taxes on passive category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2 Credit for taxes on general category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3 Credit for taxes on income re-sourced by treaty (combine all such credits on this line) . . . . . . . . . . . . . . . .

4 Total (add lines 1 through 3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5 Reduction in credit for international boycott operations (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . .

6 Total foreign tax credit (subtract line 5 from line 4). Enter here and on the appropriate line of the corporation’s tax return . . . . . . . . . .

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 3 

Schedule C Tax Deemed Paid by Domestic Corporation Filing Return 

Use this schedule to figure the tax deemed paid by the corporation with respect to dividends from a first-tier foreign corporation under section 902(a), and deemed 

inclusions of earnings from a first- or lower-tier foreign corporation under section 960(a). Report all amounts in U.S. dollars unless otherwise specified.

Part I—Dividends and Deemed Inclusions From Post-1986 Undistributed Earnings

1a. Name of Foreign Corporation 

(identify DISCs and 

former DISCs)

1b. EIN (if any) of 

the foreign 

corporation

1c. Reference ID 

number 

(see instructions)

2. Tax Year End 

(Yr-Mo) (see

instructions)

3. Country of 

Incorporation (enter 

country code - see

instructions)

4. Post-1986

Undistributed

Earnings (in

functional currency

—attach schedule)

5. Opening Balance 

in Post-1986

Foreign Income

Taxes

6. Foreign Taxes Paid and Deemed Paid for Tax 

Year Indicated

(a) Taxes Paid (b) Taxes Deemed Paid 

(see instructions)

 

7. Post-1986 Foreign Income

Taxes (add columns 5, 

6(a), and 6(b))

8. Dividends and

Deemed Inclusions

(a) Functional Currency (b) U.S. Dollars

9. Divide column 8(a) by 

column 4

10. Multiply column 7 

by column 9 11. Section 960(c) Limitation 12. Tax Deemed Paid (subtract column 11 from column 10)

 

Total (Add amounts in column 12. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3.) . . . . . . . . . . . . . ▶

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 4 

Schedule C Tax Deemed Paid by Domestic Corporation Filing Return (Continued) 

Part II—Dividends Paid Out of Pre-1987 Accumulated Profits

1a. Name of Foreign 

Corporation (identify 

DISCs and former 

DISCs)

1b. EIN (if any) of 

the foreign 

corporation

1c. Reference ID 

number (see 

instructions)

2. Tax Year End

(Yr-Mo) (see

instructions)

3. Country of

Incorporation (enter

country code - see

instructions)

4. Accumulated 

Profits for Tax Year 

Indicated (in 

functional currency

computed under 

section 902) (attach 

schedule)

5. Foreign Taxes 

Paid and Deemed 

Paid on Earnings 

and Profits 

(E&P) for Tax Year

Indicated

(in functional 

currency)

(see instructions)

6. Dividends Paid

(a) Functional 

Currency (b) U.S. Dollars

7. Divide column 

6(a) by 

column 4

8. Tax Deemed Paid

(see instructions)

(a) Functional 

Currency (b) U.S. Dollars

 

Total (Add amounts in column 8b. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3.) . . . . . . . . . . . . . ▶

Part III—Deemed Inclusions From Pre-1987 Earnings and Profits

1a. Name of Foreign

Corporation (identify 

DISCs and former

DISCs)

1b. EIN (if any) of 

the foreign 

corporation

1c. Reference ID 

number (see 

instructions)

2. Tax Year 

End (Yr-Mo) 

(see

instructions)

3. Country of

Incorporation 

(enter country 

code - see

instructions)

4. E&P for Tax Year 

Indicated

(in functional 

currency

translated from U.S. 

dollars, 

computed under 

section 964) (attach 

schedule)

5. Foreign Taxes 

Paid and Deemed 

Paid for

Tax Year Indicated 

(see instructions)

6. Deemed Inclusions

(a) Functional 

Currency (b) U.S. Dollars

7. Divide column 

6(a) by 

column 4

8. Tax Deemed Paid

(multiply column 5 

by column 7)

 

Total (Add amounts in column 8. Enter the result here and include on “Totals” line of Schedule B, Part I, column 3.) . . . . . . . . . . . . . . ▶

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 5 

Schedule D Tax Deemed Paid by First- and Second-Tier Foreign Corporations under Section 902(b) 

Use Part I to compute the tax deemed paid by a first-tier foreign corporation with respect to dividends from a second-tier foreign corporation. Use Part II to 

compute the tax deemed paid by a second-tier foreign corporation with respect to dividends from a third-tier foreign corporation. Report all amounts in U.S.

dollars unless otherwise specified.

Part I—Tax Deemed Paid by First-Tier Foreign Corporations

Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (Include the column 10 results in Schedule C, Part I, column 6(b).)

1a. Name of Second-Tier Foreign Corporation 

and Its Related First-Tier Foreign Corporation

1b. EIN (if any) of the 

second-tier foreign 

corporation

1c. Reference ID number 

(see instructions)

2. Tax Year End (Yr-Mo) (see

instructions)

3. Country of Incorporation

(enter country code - see

instructions)

4. Post-1986 Undistributed

Earnings (in functional

currency—attach schedule)

5. Opening Balance in

Post-1986 Foreign Income

Taxes

 

6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated

(a) Taxes Paid (b) Taxes Deemed Paid (see 

instructions)

7. Post-1986 Foreign Income

Taxes (add columns 5, 

6(a), and 6(b))

8. Dividends Paid (in functional currency)

(a) of Second-tier Corporation (b) of First-tier Corporation

9. Divide column 8(a) by 

column 4

10. Tax Deemed Paid 

(multiply column 7 by 

column 9)

 

Section B—Dividends Paid Out of Pre-1987 Accumulated Profits (Include the column 8(b) results in Schedule C, Part I, column 6(b).)

1a. Name of Second-Tier 

Foreign Corporation and Its 

Related First-Tier Foreign 

Corporation

1b. EIN (if any) of 

the second-tier 

foreign 

corporation

1c. Reference ID 

number (see 

instructions)

2. Tax Year End

(Yr-Mo) (see

instructions)

3. Country of

Incorporation 

(enter country 

code - see

instructions)

4. Accumulated 

Profits for Tax 

Year Indicated (in 

functional currency

—attach schedule)

5. Foreign Taxes 

Paid and Deemed 

Paid for Tax Year

Indicated

(in functional 

currency—see 

instructions)

6. Dividends Paid (in functional 

currency)

(a) of Second-tier 

Corporation

(b) of First-tier 

Corporation

7. Divide Column 

6(a) by 

Column 4

8. Tax Deemed Paid

(see instructions)

(a) Functional 

Currency of 

Second-tier 

Corporation

(b) U.S. Dollars

 

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 6 

Schedule D Tax Deemed Paid by First- and Second-Tier Foreign Corporations under Section 902(b) (Continued)

Part II—Tax Deemed Paid by Second-Tier Foreign Corporations

Section A—Dividends Paid Out of Post-1986 Undistributed Earnings (In general, include the column 10 results in Section A, column 6(b), of Part I. However, see instructions for 

Schedule C, Part I, column 6(b) for an exception.)

1a. Name of Third-Tier Foreign Corporation and 

Its Related Second-Tier Foreign Corporation

1b. EIN (if any) of the thirdtier foreign corporation1c. Reference ID number 

(see instructions)

2. Tax Year End (Yr-Mo) (see

instructions)

3. Country of 

Incorporation (enter 

country code - see

instructions)

4. Post-1986 Undistributed

Earnings (in functional

currency—attach schedule)

5. Opening Balance in

Post-1986 Foreign Income

Taxes

 

6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated

(a) Taxes Paid (b) Taxes Deemed Paid (from 

Schedule E, Part I, column 10)

7. Post-1986 Foreign Income

Taxes (add columns 5, 

6(a), and 6(b))

8. Dividends Paid (in functional currency)

(a) of Third-tier Corporation (b) of Second-tier Corporation

9. Divide column 8(a) by 

column 4

10. Tax Deemed Paid 

(multiply column 7 by 

column 9)

 

Section B—Dividends Paid Out of Pre-1987 Accumulated Profits (In general, include the column 8(b) results in Section A, column 6(b), of Part I. However, see instructions for 

Schedule C, Part I, column 6(b) for an exception.)

1a. Name of Third-Tier 

Foreign Corporation and Its 

Related Second-Tier Foreign 

Corporation

1b. EIN (if any) of 

the third-tier 

foreign 

corporation

1c. Reference ID 

number (see 

instructions)

2. Tax Year End

(Yr-Mo) (see

instructions)

3. Country of

Incorporation 

(enter country 

code - see

instructions)

4. Accumulated 

Profits for Tax Year 

Indicated (in 

functional currency

—attach schedule)

5. Foreign Taxes 

Paid and Deemed 

Paid for Tax Year

Indicated

(in functional 

currency—see 

instructions)

6. Dividends Paid (in functional 

currency)

(a) of Third-tier 

Corporation

(b) of Second-tier 

Corporation

7. Divide Column 

6(a) by 

Column 4

8. Tax Deemed Paid

(see instructions)

(a) In Functional 

Currency of 

Third-tier 

Corporation

(b) U.S. Dollars

 

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 7 

Schedule E Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b) 

Use this schedule to report taxes deemed paid with respect to dividends from eligible post-1986 undistributed earnings of fourth-, fifth- and sixth-tier controlled 

foreign corporations. Report all amounts in U.S. dollars unless otherwise specified.

Part I—Tax Deemed Paid by Third-Tier Foreign Corporations (In general, include the column 10 results in Schedule D, Part II, Section A, column 6(b). 

However, see instructions for Schedule C, Part I, column 6(b) for an exception.)

1a. Name of Fourth-Tier Foreign Corporation and 

Its Related Third-Tier Foreign Corporation

1b. EIN (if any) of the 

fourth-tier foreign 

corporation

1c. Reference ID number 

(see instructions)

2. Tax Year End (Yr-Mo) (see

instructions)

3. Country of Incorporation

(enter country code- see

instructions)

4. Post-1986 Undistributed

Earnings (in functional

currency—attach schedule)

5. Opening Balance in

Post-1986 Foreign Income

Taxes

 

6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated

(a) Taxes Paid (b) Taxes Deemed Paid (from 

Part II, column 10)

7. Post-1986 Foreign Income

Taxes (add columns 5, 

6(a), and 6(b))

8. Dividends Paid (in functional currency)

(a) of Fourth-tier CFC (b) of Third-tier CFC

9. Divide column 8(a) by 

column 4

10. Tax Deemed Paid 

(multiply column 7 by 

column 9)

 

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 8 

Schedule E Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b) (Continued)

Part II—Tax Deemed Paid by Fourth-Tier Foreign Corporations (In general, include the column 10 results in column 6(b) of Part I. However, see instructions 

for Schedule C, Part I, column 6(b) for an exception.)

1a. Name of Fifth-Tier Foreign Corporation and Its 

Related Fourth-Tier Foreign Corporation

1b. EIN (if any) of the 

fifth-tier foreign corporation

1c. Reference ID number 

(see instructions)

2. Tax Year End (Yr-Mo) (see

instructions)

3. Country of 

Incorporation (enter 

country code - see

instructions)

4. Post-1986 Undistributed

Earnings (in functional

currency—attach schedule)

5. Opening Balance in

Post-1986 Foreign Income

Taxes

 

6. Foreign Taxes Paid and Deemed Paid for Tax Year Indicated

(a) Taxes Paid (b) Taxes Deemed Paid (from 

Part III, column 10)

7. Post-1986 Foreign Income

Taxes (add columns 5, 

6(a), and 6(b))

8. Dividends Paid (in functional currency)

(a) of Fifth-tier CFC (b) of Fourth-tier CFC

9. Divide column 8(a) by 

column 4

10. Tax Deemed Paid 

(multiply column 7 by 

column 9)

 

Part III—Tax Deemed Paid by Fifth-Tier Foreign Corporations (In general, include the column 10 results in column 6(b) of Part II above. However, see 

instructions for Schedule C, Part I, column 6(b) for an exception.)

1a. Name of Sixth-Tier Foreign Corporation and 

Its Related Fifth-Tier Foreign Corporation

1b. EIN (if any) of the 

sixth-tier foreign corporation

1c. Reference ID number 

(see instructions)

2. Tax Year End (Yr-Mo) (see

instructions)

3. Country of 

Incorporation (enter 

country code - see

instructions)

4. Post-1986 Undistributed

Earnings (in functional

currency—attach schedule)

5. Opening Balance in

Post-1986 Foreign Income

Taxes

 

6. Foreign Taxes Paid for Tax Year Indicated

7. Post-1986 Foreign 

Income Taxes 

(add columns 5 and 6)

8. Dividends Paid (in functional currency)

(a) of Sixth-tier CFC (b) of Fifth-tier CFC

9. Divide column 8(a) by 

column 4

10. Tax Deemed Paid 

(multiply column 7 by 

column 9)

 

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 9 

Schedule F Gross Income and Definitely Allocable Deductions for Foreign 

Branches

1. Foreign Country or U.S. Possession (Enter

two-letter code from Schedule A, column 1.

Use a separate line for each.)

2. Gross Income 3. Definitely Allocable

Deductions

A

B

C

D

E

F

Totals (add lines A through F)* ▶

* Note: The Schedule F totals are not carried over to any other Form 1118 Schedule. (These totals were already included in

 Schedule A.) However, the IRS requires the corporation to complete Schedule F under the authority of section 905(b).

Schedule G Reductions of Taxes Paid, Accrued, or Deemed Paid

Part I - Reduction Amounts

A Reduction of Taxes Under Section 901(e)—Attach 

separate schedule

B Reduction of Foreign Oil and Gas Taxes—Enter 

amount from Schedule I, Part II, line 4

C

Reduction of Taxes Due to International Boycott Provisions— 

Enter appropriate portion of Schedule C (Form 5713), line 2b. 

Important: Enter only “specifically attributable taxes” here.

D Reduction of Taxes for Section 6038(c) Penalty— 

Attach separate schedule

E Taxes suspended under section 909

F Other Reductions of Taxes—Attach schedule(s)

Total (add lines A through F). Enter here and on Schedule

B, Part II, line 3 . . . . . . . . . . . . . . ▶

Part II - Other Information

Check this box if, during the tax year, the corporation paid or accrued any 

foreign tax that was disqualified for credit under section 901(m) . . . .

Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 10 

Schedule H Apportionment of Deductions Not Definitely Allocable (complete only once)

Part I—Research and Development Deductions

(a) Sales Method

Product line #1 (SIC Code: ) *

(i) Gross Sales (ii) R&D Deductions

Product line #2 (SIC Code: ) *

(iii) Gross Sales (iv) R&D

Deductions

(b) Gross Income Method — Check method used: Option 1 Option 2

(v) Gross Income (vi) R&D Deductions

Product line #1 (SIC Code: ) * Product line #2 (SIC Code: ) *

(vii) Gross Income (viii) R&D Deductions 

(c) Total R&D

Deductions Not

Definitely Allocable

(enter the sum of all 

amounts entered in all 

applicable “R&D 

Deductions” columns)

 

1 Totals (see instructions)

2 Total to be apportioned

3 Apportionment among 

statutory groupings:

a General category income

b Passive category income

c Section 901(j) income*

d Income re-sourced by treaty*

4 Total foreign (add lines 3a 

through 3d)

* Important: See Computer-Generated Schedule H in instructions. Form 1118 (Rev. 12-2014) 
Form 1118 (Rev. 12-2014) Page 11 

Schedule H Apportionment of Deductions Not Definitely Allocable (continued)

Part II—Interest Deductions, All Other Deductions, and Total Deductions

(a) Average Value of Assets—Check method used:

Fair market value Tax book value

Alternative tax book value

(i) Nonfinancial

Corporations (ii) Financial Corporations

(b) Interest Deductions

(iii) Nonfinancial

Corporations

(iv) Financial

Corporations

(c) All Other

Deductions Not

Definitely Allocable (d) Totals (add the

corresponding

amounts from

column (c), Part I;

columns (b)(iii) and

(b)(iv), Part II; and

column (c), Part II).

Enter each amount

from lines 3a

through 3d below 

in column 10 of the

corresponding

Schedule A.

 

1a Totals (see instructions)

b

Amounts specifically allocable under Temp. Regs. 

1.861-10T(e)

c Other specific allocations under Temp. Regs. 1.861-10T

d Assets excluded from apportionment formula

2 Total to be apportioned (subtract the sum of lines 1b, 

1c, and 1d from line 1a)

3 Apportionment among statutory groupings:

a General category income

b Passive category income

c Section 901(j) income*

d Income re-sourced by treaty*

4 Total foreign (add lines 3a through 3d)

* Important: See Computer-Generated Schedule H in instructions. Form 1118 (Rev. 12-2014)