Fluent Essays

The purpose of this assignment is to examine and use the article, International Taxation in an Era of Digital Disruption: Analyzing the Current Debate, to prepare a memo for your supervisor who has read the article and wants a formal summary prepared. The memo of 500-750 words should address the following: Summary of the key points in Part I of the article. A summary of the options provided by the author in Parts II and III of the article. Your opinion on whether you agree with the authors recommendations. If you agree, support you points with a discussion of why you think the authors recommendations make good international tax policy. If you disagree, support your points with a discussion of why the recommendations are not good international tax policy. While APA style is not required for the body of this assignment, solid academic writing is expected, and documentation of sources should be presented using APA formatting guidelines, which can be found in the APA Style Guide, located in the Student Success Center. This assignment uses a rubric. Please review the rubric prior to beginning the assignment to become familiar with the expectations for successful completion. You are required to submit this assignment to LopesWrite. Refer to the LopesWrite Technical Support articles for assistance. Form 1118 (Rev. December 2020) Department of the Treasury Internal Revenue Service Foreign Tax Credit—Corporations ▶ Attach to the corporation’s tax return. ▶ Go to www.irs.gov/Form1118 for instructions and the latest information. For calendar year 20 , or other tax year beginning , 20 , and ending , 20 OMB No. 1545-0123 Attachment Sequence No. 118 Name of corporation Employer identification number Use a separate Form 1118 for each applicable category of income (see instructions). a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) . . . . . . . . . . . . . . ▶ c If one of the RBT codes is entered on line a, enter the country code for the treaty country (see instructions) . . . . . . . . . . . . ▶ Schedule A Income or (Loss) Before Adjustments (Report all amounts in U.S. dollars. See Specific Instructions.) 1. EIN or Reference ID Number (see instructions)* 2. Foreign Country or U.S. Possession (enter two-letter code—use a separate line for each) (see instructions) Gross Income or (Loss) From Sources Outside the United States 3. Inclusions Under Sections 951(a)(1) and 951A (see instructions) 4. Dividends (see instructions) 5. Interest (a) Exclude Gross-Up (b) Gross-Up (section 78) (a) Exclude Gross-Up (b) Gross-Up (section 78) A B C Totals (add lines A through C) . . . . . . . ▶ 6. Gross Rents, Royalties, and License Fees 7. Sales 8. Gross Income From Performance of Services 9. Section 986(c) Gain 10. Section 987 Gain 11. Section 988 Gain 12. Other (attach schedule) A B C Totals 13. Total (add columns 3(a) through 12) 14. Allocable Deductions (a) Dividends Received Deduction (see instructions) (b) Deduction Allowed Under Section 250(a)(1)(A)—Foreign Derived Intangible Income (c) Deduction Allowed Under Section 250(a)(1)(B)—Global Intangible Low-Taxed Income Rental, Royalty, and Licensing Expenses (d) Depreciation, Depletion, and Amortization (e) Other Allocable Expenses (f) Expenses Allocable to Sales Income A B C Totals 14. Allocable Deductions (continued) (g) Expenses Allocable to Gross Income From Performance of Services (h) Other Allocable Deductions (attach schedule) (see instructions) (i) Total Allocable Deductions (add columns 14(a) through 14(h)) 15. Apportioned Share of Deductions (enter amount from applicable line of Schedule H, Part II, column (d)) 16. Net Operating Loss Deduction 17. Total Deductions (add columns 14(i) through 16) 18. Total Income or (Loss) Before Adjustments (subtract column 17 from column 13) A B C Totals * For section 863(b) income, NOLs, income from RICs, high-taxed income, section 965, section 951A, and reattribution of income by reason of disregarded payments, use a single line (see instructions). Also, for reporting branches that are QBUs, use a separate line for each such branch. For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 10900F Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) 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 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) Distributions of Previously Taxed Earnings and Profits (c) Branch Remittances (d) Interest (e) Rents, Royalties, and License Fees (f) Other Date Paid Date Accrued A B C Totals (add lines A through C) . ▶ 2. Foreign Taxes Paid or Accrued (attach schedule showing amounts in foreign currency and conversion rate(s) used) Other Foreign Taxes Paid or Accrued on: (g) Sales (h) Services Income (i) Other (j) Total Foreign Taxes Paid or Accrued (add columns 2(a) through 2(i)) 3. Tax Deemed Paid (see instructions) A B C Totals 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(j)) . . . . . . . . . . . . . . . . . . . . . . . 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 18 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 any American Samoa economic development credit) 11 Multiply line 9 by line 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 Increase in limitation (section 960(c)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Credit limitation (add lines 11 and 12) (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Separate foreign tax credit (enter the smaller of line 6 or line 13). Enter here and on the appropriate line of Part III . . . . . . . . . . . . ▶ Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 3 Schedule B Foreign Tax Credit (continued) (Report all foreign tax amounts in U.S. dollars.) Part III—Summary of Separate Credits (Enter amounts from Part II, line 14 for each applicable category of income. Do not include taxes paid to sanctioned countries.) 1 Credit for taxes on section 951A category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Credit for taxes on foreign branch category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Credit for taxes on passive category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Credit for taxes on general category income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Credit for taxes on section 901(j) category income (combine all such credits on this line) . . . . . . . . . . . . . . . . 6 Credit for taxes on income re-sourced by treaty (combine all such credits on this line) . . . . . . . . . . . . . . . . 7 Total (add lines 1 through 6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Reduction in credit for international boycott operations (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Total foreign tax credit (subtract line 8 from line 7). Enter here and on the appropriate line of the corporation’s tax return . . . . . . . . . ▶ Schedule C Tax Deemed Paid With Respect to Section 951(a)(1) Inclusions by Domestic Corporation Filing Return (Section 960(a)) Use this schedule to report the tax deemed paid by the corporation with respect to section 951(a)(1) inclusions of earnings from foreign corporations under section 960(a). For each line in Schedule C, include the column 10 amount in column 3 of the line in Schedule B, Part I that corresponds with the identifying number specified in column 1 of Schedule A and that also corresponds with the identifying number entered in column 1b of this Schedule C (see instructions). 1a. Name of Foreign Corporation 1b. EIN or Reference ID Number of the Foreign Corporation (see instructions) 1c. QBU Reference ID (if applicable) 2. Tax Year End (Year/Month) (see instructions) 3. Country of Incorporation (enter country code—see instructions) 4. Functional Currency of Foreign Corporation (enter code - see instructions) 5. Subpart F Income Group (a) Reg. sec. 1.960-1(d) (2)(ii)(B)(2)(enter code) (b) Reg. sec. 1.904-4(c) (3)(i)-(iv) (enter code) (c) Unit 6. Total Net Income in Subpart F Income Group (in functional currency of foreign corporation) 7. Total Current Year Taxes in Subpart F Income Group (in U.S. Dollars) 8. Section 951(a)(1) Inclusion Attributable to Subpart F Income Group (a) Functional Currency (b) U.S. Dollars 9. Divide column 8(a) by column 6 10. Tax Deemed Paid (multiply column 7 by column 9) Total (add amounts in column 10) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 4 Schedule D Tax Deemed Paid With Respect to Section 951A Income by Domestic Corporation Filing the Return (Section 960(d)) Use this schedule to figure the tax deemed paid by the corporation with respect to section 951A inclusions of earnings from foreign corporations under section 960(d). Part I—Foreign Corporation’s Tested Income and Foreign Taxes 1a. Name of Foreign Corporation 1b. EIN or Reference ID Number of the Foreign Corporation (see instructions) 2. Tax Year End (Year/Month) (see instructions) 3. Country of Incorporation (enter country code— see instructions) 4. Functional Currency of Foreign Corporation (enter code) 5. Pro rata share of CFC’s tested income from applicable Form 8992 schedule (see instructions) 6. CFC’s tested income from applicable Form 8992 schedule (see instructions) 7. Divide column 5 by column 6 8. CFC’s tested foreign income taxes from Schedule Q (Form 5471) (see instructions) 9. Pro rata share of tested foreign income taxes paid or accrued by CFC (Multiply amount in column 7 by amount in column 8) Total (add amounts in column 5) . . . . . . . . . . . . . . . . . . . . ▶ Total (add amounts in column 9) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Part II—Foreign Income Tax Deemed Paid 1. Global Intangible Low-Taxed Income (Section 951A Inclusion) 2. Inclusion Percentage. Divide Part II, Column 1, by Part I, Column 5 Total 3. Multiply Part I, Column 9 Total, by Part II, Column 2 Percentage 4. Tax Deemed Paid (Multiply Part II, column 3, by 80\%. Enter the result here and include on the line of Schedule B, Part I, column 3 that corresponds with the line with “951A” in column 2 of Schedule A.) Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 5 Schedule E Tax Deemed Paid With Respect to Previously Taxed Earnings and Profits (PTEP) by Domestic Corporation Filing the Return (Section 960(b)) Part I—Tax Deemed Paid by Domestic Corporation Use this part to report the tax deemed paid by the domestic corporation with respect to distributions of PTEP from first-tier foreign corporations under section 960(b). For each line in Schedule E, Part I, include the column 11 amount in column 3 of the line in Schedule B, Part I that corresponds with the identifying number specified in column 1 of Schedule A and that also corresponds with the identifying number specified in column 1b of this Schedule E, Part I (see instructions). 1a. Name of Distributing Foreign Corporation 1b. EIN or Reference ID Number of the Foreign Corporation (see instructions) 2. Tax Year End (Year/Month) (see instructions) 3. Country of Incorporation (enter country code— see instructions) 4. Functional Currency of the Distributing Foreign Corporation 5. PTEP Group (enter code) 6. Annual PTEP account (enter year) 7. Total amount of PTEP in the PTEP Group 8. Total amount of the PTEP group taxes with respect to PTEP group 9. Distribution from the PTEP Group 10. Divide column 9 by column 7 11. Foreign income taxes properly attributable to PTEP and not previously deemed paid (multiply column 8 by column 10) Total (add amounts in column 11) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Part II—Tax Deemed Paid by First- and Lower-Tier Foreign Corporations Use this part to report the tax deemed paid by a foreign corporation with respect to distributions of PTEP from lower-tier foreign corporations under section 960(b) that relate to distributions reported in Part I (see instructions). 1a. Name of Distributing Foreign Corporation 1b. EIN or Reference ID Number of the Foreign Corporation (see instructions) 2. Tax Year End (Year/Month) (see instructions) 3. Country of Incorporation (enter country code—see instructions) 4a. Name of Recipient Foreign Corporation 4b. EIN or Reference ID Number of the Foreign Corporation (see instructions) 5. Tax Year End (Year/Month) (see instructions) 6. Country of Incorporation (enter country code—see instructions) 7. Functional Currency of the Distributing Foreign Corporation 8. PTEP Group (enter code) 9. Annual PTEP account (enter year) 10. Total Amount of PTEP in the PTEP Group 11. Total Amount of the PTEP group taxes with respect to PTEP group 12. PTEP Distributed 13. Divide column 12 by column 10 14. Foreign income taxes properly attributable to PTEP and not previously deemed paid (multiply column 11 by column 13) Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 6 Schedule F-1 Tax Deemed Paid by Domestic Corporation Filing Return—Pre-2018 Tax Years of Foreign Corporations 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. IMPORTANT: Applicable to dividends or inclusions from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend or inclusion, do not complete Schedule F-1 (see instructions). Part I—Dividends and Deemed Inclusions From Post-1986 Undistributed Earnings For each line in Schedule F-1, Part I, include the column 12 amount in column 3 of the line in Schedule B, Part I that corresponds with the identifying number specified in column 1 of Schedule A and that also corresponds with the identifying number specified in either column 1b or 1c of this Schedule F-1, Part I (see instructions). 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 (Year/Month) (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) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 7 Schedule F-1 Tax Deemed Paid by Domestic Corporation Filing Return—Pre-2018 Tax Years of Foreign Corporations (continued) IMPORTANT: Applicable to dividends or inclusions from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend or inclusion, do not complete Schedule F-1 (see instructions). Part II—Dividends Paid Out of Pre-1987 Accumulated Profits For each line in Schedule F-1, Part II, include the column 8(b) amount in column 3 of the line in Schedule B, Part I that corresponds with the identifying number specified in column 1 of Schedule A and that also corresponds with the identifying number specified in either column 1b or 1c of this Schedule F-1, Part I (see instructions). 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 (Year/Month) (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) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Part III—Deemed Inclusions From Pre-1987 Earnings and Profits For each line in Schedule F-1, Part III, include the column 8 amount in column 3 of the line in Schedule B, Part I that corresponds with the identifying number specified in column 1 of Schedule A and that also corresponds with the identifying number specified in either column 1b or 1c of this Schedule F-1, Part I (see instructions). 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 (Year/Month) (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) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ▶ Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 8 Schedule F-2 Tax Deemed Paid by First- and Second-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Tax Years of Foreign Corporations 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. IMPORTANT: Applicable to dividends from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend, do not complete Schedule F-2 (see instructions). 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 F-1, 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 (Year/Month) (see instructions) 3. Country of Incorporation (enter country code— see instructions) 4. Accumulated Profits for Tax Year Indicated (in functional currency— see instructions) 5. Opening Balance 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 F-1, 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 (Year/Month) (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. 12-2020) Form 1118 (Rev. 12-2020) Page 9 Schedule F-2 Tax Deemed Paid by First- and Second-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Tax Years of Foreign Corporations (continued) IMPORTANT: Applicable to dividends from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend, do not complete Schedule F-2 (see instructions). Part II—Dividends 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 F-1, 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 (Year/Month) (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 F-3, 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 F-1, 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 (Year/Month) (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) Functional Currency of Third-Tier Corporation (b) U.S. Dollars Form 1118 (Rev. 12-2020) Form 1118 (Rev. 12-2020) Page 10 Schedule F-3 Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Tax Years of Foreign Corporations 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. IMPORTANT: Applicable to dividends from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend, do not complete Schedule F-3 (see instructions). Part I—Tax Deemed Paid by Third-Tier Foreign Corporations (In general, include the column 10 results in Schedule F-2, Part II, Section A, column 6(b). However, see instructions for Schedule F-1, 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 (Year/Month) (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. 12-2020) Form 1118 (Rev. 12-2020) Page 11 Schedule F-3 Tax Deemed Paid by Certain Third-, Fourth-, and Fifth-Tier Foreign Corporations Under Section 902(b)—Pre-2018 Tax Years of Foreign Corporations (continued) IMPORTANT: Applicable to dividends from tax years of foreign corporations beginning on or before December 31, 2017. If taxpayer does not have such a dividend, do not complete Schedule F-3 (see instructions). 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 F-1, 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 (Year/Month) (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 F-1, 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 (Year/Month) (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 …