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SCHEDULE S                         Exclusion of Income From the International                                           OMB No. 1545-0123
(Form 1120-F)
                               Operation of Ships or Aircraft Under Section 883
                                                   ▶
Department of the Treasury                           Attach to Form 1120-F.                                             2021
Internal Revenue Service         ▶ Go to www.irs.gov/Form1120F for instructions and the latest information.
Name of corporation                                                                                          Employer identification number

Part I  Qualified Foreign Corporation
1a Enter the name of the qualified foreign country in which the foreign corporation was organized ▶

b  Check one (and only one) of the following boxes to indicate the type of equivalent exemption granted by the foreign country 
   listed on line 1a above.
        Domestic law
        Exchange of notes
        Income tax convention
c  Enter the applicable authority of the equivalent exemption type indicated on line 1b (see instructions) ▶

2  Enter the gross income in each of the following categories of qualified income for which the exemption is being claimed.
   Note: If an amount is not readily determinable, enter a reasonable estimate. If an estimate is used on any of the lines below, 
   check here ▶
a  Income from the carriage of passengers and cargo .      .              . . . . . . . . .       . . . .  . .        2a
b  Time or voyage (full) charter income of a ship or wet lease income of an aircraft .    .       . . . .  . .        2b
c  Bareboat charter income of a ship or dry lease income of an aircraft           . . . . .       . . . .  . .        2c
d  Incidental bareboat charter income of a ship or incidental dry lease income of an aircraft .       . .  . .        2d
e  Incidental container-related income     . . . . . .     .              . . . . . . . . .       . . . .  . .        2e
f  Income  incidental  to  the  international  operation  of  ships  or  aircraft  other  than  incidental  income
   included on lines 2d and 2e above.      . . . . . .     .              . . . . . . . . .       . . . .  . .        2f
g  Capital gains derived by a qualified foreign corporation engaged in the international operation of ships 
   or  aircraft  from  the  sale,  exchange  or  other  disposition  of  a  ship,  aircraft,  container  or  related
   equipment or other moveable property used by that qualified foreign corporation in the international
   operation of ships or aircraft .  .   . . . . . . .     .              . . . . . . . . .       . . . .  . .        2g
h  Income  from  participation  in  a  pool,  partnership,  strategic  alliance,  joint  operating  agreement, 
   code-sharing  arrangement,  international  operating  agency,  or  other  joint  venture  described  in
   Regulations section 1.883-1(e)(2) .     . . . . . .     .              . . . . . . . . .       . . . .  . .        2h
   Stock ownership test of Regulations section 1.883-1(c)(2):
3  Check one (and only one) of the following boxes to indicate the test under which the stock ownership test of Regulations 
   section 1.883-1(c)(2) was satisfied.
        The publicly-traded test of Regulations section 1.883-2(a). Complete Part II.
        The CFC stock ownership test of Regulations section 1.883-3(a). Complete Part III.
        The qualified shareholder stock ownership test of Regulations section 1.883-4(a). Complete Part IV.
4  Check  the  box  if  any  of  the  shares  of  the  foreign  corporation’s  stock  or  the  stock  of  any  direct,  indirect,  or  constructive 
   shareholder are issued in bearer form.    . . . . .     .              . . . . . . . . .       . . . .  . .      . . . . . .
5  If the box on line 4 is checked:
a  Check  the  box  on  this  line  5a  if  none  of  the  bearer  shares  (other  than  bearer  shares  maintained  in  a  dematerialized  or 
   immobilized book-entry system) were relied on to satisfy any of the stock ownership tests described in Regulations section
   1.883-1(c)(2)  .        . . . . . .   . . . . . . .     .              . . . . . . . . .       . . . .  . .      . . . . . .
b  Check the box on this line 5b if any of the bearer shares were maintained in a dematerialized or immobilized book-entry system
   and were relied on to satisfy any of the stock ownership tests described in Regulations section 1.883-1(c)(2)  .       . . .
Part II Stock Ownership Test for Publicly-Traded Corporations
6  Enter the name of the country in which the stock is primarily traded ▶
7  Enter the name of the securities market(s) on which the stock is listed ▶
8  Enter a description of each class of stock relied on to meet the “regularly traded test” of Regulations section 1.883-2(d) (see 
   instructions for description requirements) ▶

9  Do  one  or  more  5%  shareholders  (see  instructions  for  definition)  own  in  the  aggregate  50%  or  more 
   of  the  vote  and  value  of  the  outstanding  shares  of  any  class  of  stock  for  more  than  half  the  number  of  days  during 
   the tax year? .         . . . . . .   . . . . . . .     .              . . . . . . . . .       . . . .  . .      . . Yes   No
   If “Yes,” complete line 10.
   If “No,” skip line 10.
For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.         Cat. No. 50766D            Schedule S (Form 1120-F) 2021



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Schedule S (Form 1120-F) 2021                                                                                                 Page 2 
10   For each class of stock relied on to meet the “regularly traded test” of Regulations section 1.883-2(d), indicate:
a  (i)    The number of days during the tax year of the corporation in which the class of stock was closely held, without regard to 
          the exception in Regulations section 1.883-2(d)(3)(ii) ▶
     (ii) The total percentage of the vote and value of the class of stock that was owned by 5% shareholders during 
          such days ▶               %
b         For  all  qualified  shareholders  on  which  the  corporation  intends  to  rely  to  satisfy  the  closely-held  exception  test  of
          Regulations section 1.883-2(d)(3)(ii), and who own stock in the closely-held block (directly, indirectly, or by applying the
          attribution rules of Regulations section 1.883-4(c)), enter:
     (i)  The total number of qualified shareholders, as defined in Regulations section 1.883-4(b)(1) ▶
     (ii) The total percentage of the value of the shares of the class of stock in the closely-held block of stock owned, directly or 
          indirectly, by such qualified shareholders by country of residence (see instructions):

                                Country code (see instructions)                Percentage

     (iii) The number of days during the tax year of the corporation that such qualified shareholders owned, directly or indirectly, 
          their shares in the closely-held block of stock ▶

Part III   Stock Ownership Test for Controlled Foreign Corporations (CFC)
11 a Enter the percentage of the value of all outstanding shares of the CFC that is owned by all “qualified U.S. persons” identified in 
     the qualified ownership statements required under Regulations section 1.883-3(c)(2), applying the attribution of ownership rules 
     of Regulations section 1.883-3(b)(4) ▶       %
b    Enter the percentage of the value of all outstanding shares of the CFC that is owned by the “qualified U.S. persons” referred to 
     on line 11a above as bearer shares maintained in a dematerialized or immobilized book-entry system ▶              %
12   Enter the period during which such qualified U.S. persons held such stock (see instructions) ▶

13   Enter the period during which the foreign corporation was a CFC (see instructions) ▶

14   Is the CFC directly held by qualified U.S. persons? .      . .   . .  . . . . . .   .      . .   . . . . .  Yes          No

Part IV    Qualified Shareholder Stock Ownership Test
15   Check the box if more than 50% of the value of the outstanding shares of the corporation is owned (or treated as owned by
     reason of Regulations section 1.883-4(c)) by qualified shareholders for each category of income for which the exemption is 
     claimed . .    .         . . . . . . . . . .         . .   . .   . .  . . . . . .   .      . .   . . . . .  .     . . .  .
16   With respect to all qualified shareholders relied on to satisfy the 50% ownership test of Regulations section 1.883-4(a):
a    Enter the total number of such qualified shareholders as defined in Regulations section 1.883-4(b)(1) ▶
b    Enter the total percentage of the value of the outstanding shares owned, applying the attribution rules of Regulations section 
     1.883-4(c), by such qualified shareholders by country of residence or organization, whichever is applicable.

                                Country code (see instructions)                Percentage

                                                                      Total

c    Enter the percentage of the value of the outstanding shares that is owned by the qualified shareholders as bearer shares  
     maintained in a dematerialized or immobilized book-entry system ▶             %

d    Enter the number of days during the tax year of the foreign corporation that such stock was held by qualified shareholders ▶

                                                                                                           Schedule S (Form 1120-F) 2021






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