Enlarge image | SCHEDULE M-3 Net Income (Loss) Reconciliation for Foreign OMB No. 1545-0123 (Form 1120-F) Corporations With Reportable Assets of $10 Million or More Department of the Treasury Attach to Form 1120-F. Internal Revenue Service Go to www.irs.gov/Form1120F for instructions and the latest information. 2023 Name of corporation Employer identification number A Has the corporation reported taxable income on Form 1120-F, page 5, using a treaty provision to attribute business profits to a U.S. permanent establishment under rules other than section 864(c)? . . . . . . Yes No B Did the corporation prepare a non-consolidated, worldwide, certified audited income statement for the period (see instructions)? . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No C Did the corporation prepare a non-consolidated, worldwide income statement for the period (see instructions)? Yes No D Did the corporation prepare certified audited income statement(s) for the set(s) of books reported on Form 1120-F, Schedule L? . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No Part I Financial Information and Net Income (Loss) Reconciliation (see instructions) 1 Is the corporation a foreign bank as defined in Regulations section 1.882-5(c)(4)? Yes. Complete the remainder of Part I as follows: If D is “Yes,” use the income statement described in D to complete lines 2 through 5 and 7 through 11. If D is “No,” use the income statement(s) for the set(s) of books reported on Form 1120-F, Schedule L to complete lines 2 through 5 and 7 through 11. No. Complete the remainder of Part I as follows: If B is “Yes,” use the income statement described in B to complete lines 2 through 11. If B is “No” and C is “Yes,” use the income statement described in C to complete lines 2 through 11. If B and C are “No” and D is “Yes,” use the income statement described in D to complete lines 2 through 11. If B, C, and D are “No,” use the income statement described in the instructions to complete lines 2 through 11. 2a Enter the income statement period: Beginning Ending b Has the corporation’s income statement been restated for the income statement period entered on line 2a? Yes. Attach an explanation and the amount of each item restated. No. c Has the corporation’s income statement been restated for any of the 5 income statement periods immediately preceding the period on line 2a? Yes. Attach an explanation and the amount of each item restated. No. 3 Is any of the corporation’s stock publicly traded on any exchange, U.S. or foreign? Yes. List exchange(s) and symbol No. 4 Non-consolidated foreign corporation net income (loss) in U.S. dollars from the income statement source identified in line 1 . . . . . . . . . . . . . . . . . . . . . . . . . . 4 5a Net income from includible disregarded foreign entities not included on line 4 (attach statement) . . 5a b Net loss from includible disregarded foreign entities not included on line 4 (attach statement) . . . 5b ( ) c Net income from includible disregarded U.S. entities not included on line 4 (attach statement) . . . 5c d Net loss from includible disregarded U.S. entities not included on line 4 (attach statement) . . . . 5d ( ) 6 Net income (loss) from foreign locations not included on line 4 (attach statement) . . . . . . . 6 7a Net income of non-includible entities (attach statement) . . . . . . . . . . . . . . . 7a ( ) b Net loss of non-includible entities (attach statement) . . . . . . . . . . . . . . . . 7b 8 Adjustments to intercompany transactions (attach statement) . . . . . . . . . . . . . 8 9 Adjustments to reconcile income statement period to tax year (attach statement) . . . . . . . 9 10 Other adjustments to reconcile to amount on line 11 (attach statement) . . . . . . . . . . 10 11 Adjusted financial net income (loss) of non-consolidated foreign corporation. Combine lines 4 through 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Note: Part I, line 11, must equal Part II, line 28, column (a) or Schedule M-1, line 1 (see instructions). For Paperwork Reduction Act Notice, see the Instructions Cat. No. 39667H Schedule M-3 (Form 1120-F) 2023 for Form 1120-F. |
Enlarge image | Schedule M-3 (Form 1120-F) 2023 Page 2 Name of corporation Employer identification number Part II Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (d) (a) (b) (c) Other Permanent (e) Income (Loss) Items Income (Loss) per Temporary Permanent Differences Income (Loss) Income Statement Differences Differences for Allocations to per Tax Return Non-ECI and ECI 1 Gross receipts . . . . . . . . 2 Cost of goods sold (attach statement) . 3a Dividends from foreign entities . . . b Dividends from U.S. entities . . . . c Substitute dividend payments received 4a Interest income excluding interest equivalents . . . . . . . . . b Substitute interest payments received c Interest equivalents not included on line 4b 5 Gross rental income . . . . . . 6 Gross royalty income . . . . . . 7 Fee and commission income . . . 8 Income (loss) from equity method corporations . . . . . . . . 9 Net income (loss) from U.S. partnerships 10 Net income (loss) from certain foreign partnerships (see instructions) . . . 11 Net income (loss) from other pass- through entities (attach statement) . . 12 Items relating to reportable transactions (attach statement) . . . . . . . 13 Hedging transactions . . . . . . 14a Mark-to-market income (loss) under section 475(a) . . . . . . . . b Mark-to-market income (loss) subject to section 475(d)(3)(B) . . . . . . c Mark-to-market income (loss) under section 475(e) . . . . . . . . d Mark-to-market income (loss) under section 475(f) . . . . . . . . 15 Gain (loss) from certain section 988 transactions . . . . . . . . 16a Interest income from global securities dealing . . . . . . . . . . b Dividends from global securities dealing c Gains (losses) and other fixed and determinable, annual, or periodic income from global securities dealing not included on lines 16a and 16b . . 17 Sales versus lease (for sellers and/or lessors) . . . . . . . . . . 18 Section 481(a) adjustments . . . . 19 Unearned/deferred revenue . . . . 20 Original issue discount, imputed interest, and phantom income . . . 21a Income statement gain/loss on sale, exchange, abandonment, worthlessness, or other disposition of assets other than inventory and pass-through entities . . b Gross capital gains from Schedule D, excluding amounts from pass-through entities . . . . . . . . . . Schedule M-3 (Form 1120-F) 2023 |
Enlarge image | Schedule M-3 (Form 1120-F) 2023 Page 3 Name of corporation Employer identification number Part II Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (continued from page 2) (d) (a) (b) (c) Other Permanent (e) Income (Loss) Items Income (Loss) per Temporary Permanent Differences Income (Loss) Income Statement Differences Differences for Allocations to per Tax Return Non-ECI and ECI 21c Gross capital losses from Schedule D, excluding amounts from pass-through entities, abandonment losses, and worthless stock losses . . . . . d Net gain/loss reported on Form 4797, line 17, excluding amounts from pass-through entities, abandonment losses, and worthless stock losses . . e Abandonment losses . . . . . . f Worthless stock losses (attach statement) g Other gain/loss on disposition of assets other than inventory . . . . . . 22 Capital loss limitation and carryforward used . . . . . . . . . . 23 Gross effectively connected income of foreign banks from books that do not give rise to U.S. booked liabilities . . . . . . . . . 24 Other income (loss) items with differences (attach statement) . . . 25 Total income (loss) items. Combine lines 1 through 24 . . . . . . . 26 Total expense/deduction items (from Part III, line 33) . . . . . . . 27 Other items with no differences . . . 28 Reconciliation totals. Combine lines 25 through 27 . . . . . . . . . Note: Line 28, column (a), must equal Part I, line 11, and column (e) must equal Form 1120-F, page 5, line 29. Part III Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (d) (a) (b) (c) Other Permanent (e) Expense/Deduction Items Expense per Temporary Permanent Differences Deduction per Income Statement Differences Differences for Allocations to Tax Return Non-ECI and ECI 1 U.S. current income tax expense . . 2 U.S. deferred income tax expense . . 3 Non-U.S. current income tax expense (other than foreign withholding taxes) . 4 Non-U.S. deferred income tax expense . . . . . . . . . 5 Non-U.S. withholding taxes . . . . 6 Compensation with section 162(m) limitation . . . . . . . . . 7 Salaries and other base compensation 8 Stock option expense . . . . . 9 Other equity-based compensation . . 10 Meals and entertainment . . . . . 11 Fines and penalties . . . . . . 12 Judgments, damages, awards, and similar costs . . . . . . . . Schedule M-3 (Form 1120-F) 2023 |
Enlarge image | Schedule M-3 (Form 1120-F) 2023 Page 4 Name of corporation Employer identification number Part III Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (continued from page 3) (d) (a) (b) (c) Other Permanent (e) Expense/Deduction Items Expense per Temporary Permanent Differences Deduction per Income Statement Differences Differences for Allocations to Tax Return Non-ECI and ECI 13 Pension and profit-sharing . . . . 14 Other post-retirement benefits . . . 15 Deferred compensation . . . . . 16 Charitable contributions . . . . . 17 Section 162(r)–FDIC premiums paid by certain large financial institutions (see instructions) . . . . . . . . 18 Current year acquisition or reorganization investment banking fees, legal and accounting fees . . . 19 Current year acquisition/reorganization other costs . . . . . . . . . 20 Amortization/impairment of goodwill . 21 Amortization of acquisition, reorganization, and start-up costs . . 22 Other amortization or impairment write-offs . . . . . . . . . 23 Depreciation . . . . . . . . 24 Bad debt expense . . . . . . 25 Purchase versus lease (for purchasers and/or lessees) . . . . . . . 26a Interest expense per books . . . . b Interest expense under Regulations section 1.882-5 (from Schedule I (Form 1120-F), line 23) . . . . . . . c Regulations section 1.882-5 allocation amount subject to deferral or disallowance (from Schedule I (Form 1120-F), line 24g) . . . . . . . ( ) d Substitute interest payments . . . e Interest equivalents (for example, guarantee fees) not included on line 26d 27 Substitute dividend payments . . . 28 Fee and commission expense . . . 29 Rental expense . . . . . . . 30 Royalty expense . . . . . . . 31 Expenses allocable to effectively connected income under Regulations section 1.861-8 from home office or other books that do not give rise to U.S. booked liabilities (from Schedule H (Form 1120-F), line 20) . . . . . 32 Other expense/deduction items with differences (attach statement) . . . 33 Total expense/deduction items. Combine lines 1 through 32. Enter here and on Part II, line 26 . . . . . . Schedule M-3 (Form 1120-F) 2023 |