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                                                                                                                    Department of the Treasury
                                                                                                                    Internal Revenue Service
2023

Instructions for

Form 1120-PC

U.S. Property and Casualty Insurance Company Income Tax Return

Section references are to the Internal Revenue Code                         Contents                                                                  Page
unless otherwise noted.                                                     Schedule M-1          . . . . . . . . . . . . . . . . . . . . . . . . . .   26
Contents                                                             Page   Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
What's New . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
                                                                            Future Developments
Photographs of Missing Children . . . . . . . . . . . . . . . .          2
                                                                            For the latest information about developments related to 
The Taxpayer Advocate Service . . . . . . . . . . . . . . . . .          2  Form 1120-PC and its instructions, such as legislation 
How To Get Forms and Publications . . . . . . . . . . . . . .            2  enacted after they were published, go to IRS.gov/
General Instructions  . . . . . . . . . . . . . . . . . . . . . . . . .  2  Form1120PC.
Purpose of Form . . . . . . . . . . . . . . . . . . . . . . . . .        2
                                                                            What's New
Who Must File      . . . . . . . . . . . . . . . . . . . . . . . . . .   2
Where To File . . . . . . . . . . . . . . . . . . . . . . . . . . .      3  Increase in penalty for failure to file.              For tax returns 
Electronic Filing     . . . . . . . . . . . . . . . . . . . . . . . . .  2  required to be filed in 2024, the minimum penalty for 
                                                                            failure to file a tax return that is more than 60 days late has 
When To File     . . . . . . . . . . . . . . . . . . . . . . . . . . .   2
                                                                            increased to the smaller of the tax due or $485. See Late 
Who Must Sign . . . . . . . . . . . . . . . . . . . . . . . . . .        3  filing of return, later.
Paid Preparer Authorization . . . . . . . . . . . . . . . . .            3
                                                                            Expiration of 100% business meal expense deduc-
Statements     . . . . . . . . . . . . . . . . . . . . . . . . . . . .   4
                                                                            tion.   The temporary 100% business meal expenses 
Assembling the Return          . . . . . . . . . . . . . . . . . . . .   4  deduction for food and beverages provided by a 
Tax Payments . . . . . . . . . . . . . . . . . . . . . . . . . . .       4  restaurant does not apply to amounts paid or incurred 
Estimated Tax Payments . . . . . . . . . . . . . . . . . . .             4  after 2022.
Interest and Penalties       . . . . . . . . . . . . . . . . . . . . .   5  Corporate alternative minimum tax (CAMT).                         For tax 
Accounting Methods . . . . . . . . . . . . . . . . . . . . . .           5  years beginning after 2022, certain corporations must 
Accounting Period        . . . . . . . . . . . . . . . . . . . . . . .   6  determine whether they are subject to the new CAMT and 
Rounding Off to Whole Dollars . . . . . . . . . . . . . . .              6  calculate CAMT, if applicable. See the instructions for 
Recordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . .        6  page 1, line 6. Also, see new Schedule I, Question 20.
Other Forms and Statements That May Be                                      Elective payment election.              Applicable entities and 
Required       . . . . . . . . . . . . . . . . . . . . . . . . . . . .   6  electing taxpayers can elect to treat certain credits as 
Specific Instructions . . . . . . . . . . . . . . . . . . . . . . . . .  6  elective payments. Resulting overpayment may result in 
Period Covered        . . . . . . . . . . . . . . . . . . . . . . . . .  6  refunds. See the instructions for line 15g. Also see the 
                                                                            Instructions for Form 3800.
Name and Address . . . . . . . . . . . . . . . . . . . . . . .           7
Identifying Information . . . . . . . . . . . . . . . . . . . . .        7  Relief from additions to tax for underpayments appli-
Employer Identification Number (EIN) . . . . . . . . . .                 8  cable to the new corporate alternative minimum tax. 
                                                                            For tax year 2023, the IRS will waive the penalty for failure 
Section 953 Elections . . . . . . . . . . . . . . . . . . . . .          8
                                                                            to make estimated tax payments for taxes attributable to a 
Final Return, Name Change, Address                                          CAMT liability for affected corporations. Affected 
Change, or Amended Return . . . . . . . . . . . . . .                    8  corporations must still file Form 2220 even if they owe no 
Taxable Income        . . . . . . . . . . . . . . . . . . . . . . . . .  8  estimated tax penalty. However, affected corporations 
Tax Computation and Payments . . . . . . . . . . . . . .                 8  may exclude the CAMT tax liability when calculating the 
Schedule A     . . . . . . . . . . . . . . . . . . . . . . . . . . .     10 required annual payment on Form 2220. Affected 
Schedule B, Part I . . . . . . . . . . . . . . . . . . . . . . .         18 corporations must also include an amount of estimated 
                                                                            tax penalty on page 1, line 17 of Form 1120-PC even if 
Schedule B, Part II      . . . . . . . . . . . . . . . . . . . . . .     18
                                                                            that amount is zero. Failure to follow these instructions 
Schedule C     . . . . . . . . . . . . . . . . . . . . . . . . . . .     19 could result in the corporation receiving a penalty notice 
Schedule E     . . . . . . . . . . . . . . . . . . . . . . . . . . .     21 that will require an abatement request to apply the relief 
Schedule F     . . . . . . . . . . . . . . . . . . . . . . . . . . .     22 provided by Notice 2023-42. See Notice 2023-42, 
Schedule G     . . . . . . . . . . . . . . . . . . . . . . . . . . .     23 2023-26 I.R.B. 1085, available at IRS.gov/irb/ 
Schedule H     . . . . . . . . . . . . . . . . . . . . . . . . . . .     23 2023-26_IRB#NOT-2023-42. Also, see the instructions for 
                                                                            page 1, line 17.
Schedule I   . . . . . . . . . . . . . . . . . . . . . . . . . . . .     23
Schedule L   . . . . . . . . . . . . . . . . . . . . . . . . . . . .     26

Jan 29, 2024                                                         Cat. No. 64537I



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Photographs of
                                                              General Instructions
Missing Children
The Internal Revenue Service is a proud partner with the      Purpose of Form
National Center for Missing & Exploited Children®             Use Form 1120-PC to report the income, gains, losses, 
(NCMEC). Photographs of missing children selected by          deductions, and credits, and to figure the income tax 
the Center may appear in instructions on pages that would     liability of insurance companies, other than life insurance 
otherwise be blank. You can help bring these children         companies.
home by looking at the photographs and calling 
1-800-THE-LOST (1-800-843-5678) if you recognize a            Who Must File
child.                                                        Every domestic nonlife insurance company and every 
                                                              foreign corporation that would qualify as a nonlife 
The Taxpayer Advocate Service                                 insurance company subject to taxation under section 831, 
The Taxpayer Advocate Service (TAS) is an independent         if it were a U.S. corporation, must file Form 1120-PC. This 
organization within the IRS that helps taxpayers and          includes organizations described in section 501(m)(1) that 
protects taxpayer rights. TAS's job is to ensure that every   provide commercial-type insurance and organizations 
taxpayer is treated fairly and knows and understands their    described in section 833.
rights under the Taxpayer Bill of Rights.                     Exceptions.    A nonlife insurance company that is:
  As a taxpayer, the corporation has rights that the IRS      Exempt under section 501(c)(15) should file Form 990, 
must abide by in its dealings with the corporation. TAS can   Return of Organization Exempt From Income Tax;
help the corporation if:                                      Subject to taxation under section 831, and disposes of 
A problem is causing financial difficulty for the business; its insurance business and reserves, or otherwise ceases 
The business is facing an immediate threat of adverse       to be taxed under section 831, but continues its corporate 
action; and                                                   existence while winding up and liquidating its affairs, 
The corporation has tried repeatedly to contact the IRS     should file Form 1120, U.S. Corporation Income Tax 
but no one has responded, or the IRS hasn't responded         Return.
by the date promised.                                         Life insurance companies. Life insurance companies 
                                                              should file Form 1120-L, U.S. Life Insurance Company 
  The TAS tax toolkit at TaxpayerAdvocate.IRS.gov can 
                                                              Income Tax Return.
help the corporation understand these rights.
                                                              Foreign-owned domestic disregarded entities.               If a 
  TAS has offices in every state, the District of Columbia,   foreign person, including a foreign corporation, wholly 
and Puerto Rico. Local advocates' numbers are in their        owns a domestic disregarded entity (DE), the domestic 
local directories and at TaxpayerAdvocate.IRS.gov/            DE is treated as a domestic corporation separate from its 
Contact-Us. The corporation can also call TAS at              owner (the foreign corporation) for purposes of the 
877-777-4778.                                                 reporting requirements under section 6038A that apply to 
                                                              25% foreign-owned domestic corporations. These rules 
  TAS also works to resolve large-scale or systemic 
                                                              apply to a domestic DE owned by a foreign insurance 
problems that affect many taxpayers. If the corporation 
                                                              company that makes an election under section 953(c)(3)
knows of one of these broad issues, please report it to 
                                                              (C) but do not apply to a domestic DE owned by a foreign 
TAS through the Systemic Advocacy Management 
                                                              insurance company that makes an election under section 
System at IRS.gov/SAMS.
                                                              953(d) (for information on these elections, see the 
  For more information, go to                                 instructions for item D). If a foreign insurance company 
IRS.gov/Advocate.                                             electing under section 953(c)(3)(C) wholly owns a 
                                                              domestic DE, the DE is required to file Form 5472, 
How To Get Forms                                              Information Return of a 25% Foreign-Owned U.S. 
                                                              Corporation or a Foreign Corporation Engaged in a U.S. 
and Publications
                                                              Trade or Business. For additional information and 
Internet. You can access the IRS website 24 hours a day,      coordination with Form 5472 filing by the domestic DE, 
7 days a week, at IRS.gov to:                                 see the Instructions for Form 5472.
Download forms, instructions, and publications;
Order IRS products online;                                  Electronic Filing
Research your tax questions online;                         Go to IRS.gov/Filing for the latest information. Also, go to 
Search publications online by topic or keyword;             IRS.gov/MeF and click on the link for “Modernized e-File 
View Internal Revenue Bulletins (IRBs) published in         Forms” for information on which forms the corporation can 
recent years; and                                             or must e-file.
Sign up to receive local and national tax news by email.
                                                              When To File
Tax forms and publications.   The corporation can view, 
                                                              Generally, a corporation must file its income tax return by 
print, or download all of the forms and publications it may 
                                                              the 15th day of the 4th month after the end of its tax year. 
need on IRS.gov/FormsPubs. Otherwise, the corporation 
                                                              A new corporation filing a short-period return must 
can go to IRS.gov/OrderForms to place an order and have 
                                                              generally file by the 15th day of the 4th month after the 
forms mailed to it. The IRS will process your order for 
                                                              short period ends. A corporation that has dissolved must 
forms and publications as soon as possible.

2                                                                                    Instructions for Form 1120-PC (2023)



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Where To File
File the corporation's return at the applicable IRS address listed below.

If the corporation's principal business, office, or agency is located in:    Use the following address:
                                                                             Department of the Treasury 
The United States                                                            Internal Revenue Service
                                                                             Ogden, UT 84201-0012
                                                                             Internal Revenue Service
A foreign country or U.S. territories                                        P.O. Box 409101
                                                                             Ogden, UT 84409

generally file by the 15th day of the 4th month after the                 Paid Preparer Use Only section. If an employee of the 
date it dissolved.                                                        corporation completes Form 1120-PC, the paid preparer 
  However, a corporation with a fiscal tax year ending                    space should remain blank. Anyone who prepares Form 
June 30 must file by the 15th day of the 3rd month after                  1120-PC but does not charge the corporation should not 
the end of its tax year. A corporation with a short tax year              complete that section. Generally, anyone who is paid to 
ending any time in June will be treated as if the short year              prepare the return must sign it and complete the section.
ended on June 30, and must file by the 15th day of the 3rd                  The paid preparer must complete the required preparer 
month after the end of its tax year.                                      information and:
                                                                          Sign the return in the space provided for the preparer's 
  If the due date falls on a Saturday, Sunday, or legal                   signature,
holiday, the corporation can file on the next business day.               Include their Preparer Tax Identification Number (PTIN); 
                                                                          and
Private Delivery Services                                                   Give a copy of the return to the taxpayer.
                                                                          
Corporations can use certain private delivery services 
(PDSs) designated by the IRS to meet the “timely mailing                  Note.  A paid preparer may sign original or amended 
as timely filing” rule for tax returns. Go to IRS.gov/PDS for             returns by rubber stamp, mechanical device, or computer 
the current list of designated services.                                  software program.

  The PDS can tell you how to get written proof of the                    Paid Preparer Authorization
mailing date.                                                             If the corporation wants to allow the IRS to discuss its 
  For the IRS mailing address to use if you are using a                   2023 tax return with the paid preparer who signed it, 
PDS, go to IRS.gov/PDSstreetAddresses.                                    check the “Yes” box in the signature area of the return. 
                                                                          This authorization applies only to the individual whose 
        Private delivery services cannot deliver items to                 signature appears in the “Paid Preparer Use Only” section 
  !     P.O. boxes. You must use the U.S. Postal Service                  of the return. It does not apply to the firm, if any, shown in 
CAUTION to mail any item to an IRS P.O. box address.
                                                                          that section.
                                                                            If the “Yes” box is checked, the corporation is 
Extension of Time To File                                                 authorizing the IRS to call the paid preparer to answer any 
File Form 7004, Application for Automatic Extension of                    questions that may arise during the processing of its 
Time To File Certain Business Income Tax, Information,                    return. The corporation is also authorizing the paid 
and Other Returns, to request an extension of time to file.               preparer to:
Generally, the corporation must file Form 7004 by the                     Give the IRS any information that is missing from the 
regular due date of the return. See the Instructions for                  return;
Form 7004.                                                                Call the IRS for information about the processing of the 
                                                                          return or the status of any related refund or payment(s); 
Who Must Sign                                                             and
The return must be signed and dated by:                                   Respond to certain IRS notices about math errors, 
The president, vice president, treasurer, assistant                     offsets, and return preparation.
treasurer, chief accounting officer; or                                     The corporation is not authorizing the paid preparer to 
Any other corporate officer (such as a tax officer)                     receive any refund check, bind the corporation to anything 
authorized to sign.                                                       (including any additional tax liability), or otherwise 
  If a return is filed on behalf of a corporation by a                    represent the corporation before the IRS.
receiver, trustee, or assignee, the fiduciary must sign the                 The authorization will automatically end no later than 
return instead of the corporate officer. Returns and forms                the due date (excluding extensions) for filing the 
signed by a receiver or trustee in bankruptcy on behalf of                corporation's 2024 tax return. If the corporation wants to 
a corporation must be accompanied by a copy of the order                  expand the paid preparer's authorization or revoke the 
or instructions of the court authorizing signing of the return            authorization before it ends, see Pub. 947, Practice Before 
or form.                                                                  the IRS and Power of Attorney.

Instructions for Form 1120-PC (2023)                                                                                                 3



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Statements                                                       Electronic Deposit Requirement
                                                                 Corporations must use electronic funds transfer to make 
NAIC annual statement.   Regulations section                     all federal tax deposits (such as deposits of employment, 
1.6012-2(c) requires that the National Association of            excise, and corporate income tax). Generally, electronic 
Insurance Commissioners (NAIC) annual statement be               funds transfers are made using the Electronic Federal Tax 
filed with Form 1120-PC. A foreign insurance company             Payment System (EFTPS).
subject to tax under section 831 that is not required to file 
an annual statement must file a copy of the pro forma               If the corporation does not want to use EFTPS, it can 
annual statement. A penalty for the late filing of a return      arrange for its tax professional, financial institution, payroll 
may be imposed for not including the annual statement            service, or other trusted third party to make deposits on its 
when the return is filed. However, see Electronic filing,        behalf. Also, it can arrange for its financial institution to 
next.                                                            submit a same-day payment (discussed later) on its 
  Electronic filing. If the domestic or foreign nonlife          behalf. EFTPS is a free service provided by the 
insurance company files Form 1120-PC electronically, do          Department of the Treasury. Services provided by a tax 
not attach the annual statement or pro forma annual              professional, financial institution, payroll service, or other 
statement to the electronically filed return. However, you       third party may have a fee.
must provide a copy of the annual statement or pro forma 
annual statement to the IRS if requested and retain it with         To get more information about EFTPS or to enroll in 
your other tax records for the period required by the            EFTPS, go to EFTPS.gov or call 800-555-4477. To 
regulations.                                                     contact EFTPS using Telecommunications Relay Services 
  Reconciliation. Corporations that do not file a                (TRS) for people who are deaf, hard of hearing, or have a 
Schedule M-3 (Form 1120-PC), Net Income (Loss)                   speech disability, dial 711 and provide the TRS assistant 
Reconciliation for U.S. Property and Casualty Insurance          the 800-555-4477 number above or 800-733-4829.
Companies With Total Assets of $10 Million or More, with         Depositing on time.   To make EFTPS deposits on time, 
Form 1120-PC must attach a statement that reconciles the         the corporation must submit the transaction by 8 p.m. 
NAIC annual statement to Form 1120-PC.                           Eastern time the day before the date the deposit is due. If 
                                                                 the corporation uses a third party to make deposits on its 
Assembling the Return
                                                                 behalf, they may have different cutoff times.
To ensure that the corporation's tax return is correctly 
processed, attach all schedules and other forms after            Same-day wire payment option.    If the corporation fails 
page 9 of Form 1120-PC in the following order.                   to submit a deposit transaction on EFTPS by 8 p.m. 
                                                                 Eastern time the day before the date a deposit is due, it 
  1. Schedule N (Form 1120).
                                                                 can still make the deposit on time by using the Federal Tax 
  2. Form 4626.                                                  Collection Service (FTCS). Before using the same-day 
  3. Form 4136.                                                  wire payment method, the corporation will need to make 
  4. Form 8978.                                                  arrangements with its financial institution ahead of time 
                                                                 regarding availability, deadlines, and costs. Financial 
  5. Form 965-B.                                                 institutions may charge a fee for payments made this way. 
  6. Form 8941.                                                  To learn more about making a same-day wire payment, go 
  7. Form 3800.                                                  to IRS.gov/SameDayWire.

  8. Additional schedules in alphabetical order.                 Estimated Tax Payments
  9. Additional forms in numerical order.                        Generally, the following rules apply to the corporation's 
  10. Supporting statements and attachments.                     payments of estimated tax.
  Complete every applicable entry space on Form                  The corporation must make installment payments of 
                                                                 estimated tax if it expects its total tax for the year (less 
1120-PC. Do not enter “See Attached” or “Available Upon 
                                                                 applicable credits) to be $500 or more.
Request” instead of completing the entry spaces. If more 
space is needed on the forms or schedules, attach                The installments are due by the 15th day of the 4th, 6th, 
                                                                 9th, and 12th months of the tax year. If any date falls on a 
separate sheets using the same size and format as the 
                                                                 Saturday, Sunday, or legal holiday, the installment is due 
printed forms. If there are supporting statements and 
                                                                 on the next regular business day.
attachments, arrange them in the same order as the 
schedules or forms they support and attach them last.            The corporation must use electronic funds transfer to 
                                                                 make installment payments of estimated tax.
Show the totals on the printed forms. Enter the 
corporation's name and employer identification number            If, after the corporation figures and deposits estimated 
                                                                 tax, it finds that its tax liability for the year will be more or 
(EIN) on each supporting statement or attachment.
                                                                 less than originally estimated, it may have to refigure its 
Tax Payments                                                     required installments. If earlier installments were 
                                                                 underpaid, the corporation may owe a penalty. See 
Generally, the corporation must pay any tax due in full no 
                                                                 Estimated tax penalty.
later than the due date for filing its tax return (not including 
extensions). See the instructions for line 18. If the due        If the corporation overpaid estimated tax, it may be able 
                                                                 to get a quick refund by filing Form 4466, Corporation 
date falls on a Saturday, Sunday, or legal holiday, the 
                                                                 Application for Quick Refund of Overpayment of 
payment is due on the next day that isn't a Saturday, 
                                                                 Estimated Tax. See the instructions for Form 1120-PC, 
Sunday, or legal holiday.
                                                                 line 15c.

4                                                                                     Instructions for Form 1120-PC (2023)



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  See section 6655 and Pub. 542, Corporations, for more         Form 941, Employer's QUARTERLY Federal Tax 
information on estimated taxes.                                 Return;
Estimated tax penalty.  A corporation that does not             Form 944, Employer's ANNUAL Federal Tax Return; or
make estimated tax payments when due may be subject             Form 945, Annual Return of Withheld Federal Income 
                                                                Tax.
to an underpayment penalty for the period of 
underpayment. Generally, a corporation is subject to the          The trust fund recovery penalty may be imposed on all 
penalty if its tax liability is $500 or more and it did not     persons who are determined by the IRS to be responsible 
timely pay at least the smaller of:                             for collecting, accounting for, or paying over these taxes, 
Its tax liability for the current year, or                    and who acted willfully in not doing so. The penalty is 
Its prior year tax.                                           equal to the full amount of the unpaid trust fund tax. See 
                                                                the Instructions for Form 720 or Pub. 15 (Circular E), 
  See section 6655 for details and exceptions, including 
                                                                Employer's Tax Guide, for details, including the definition 
special rules for large corporations.
                                                                of responsible persons.
  Use Form 2220, Underpayment of Estimated Tax by 
Corporations, to see if the corporation owes a penalty and      Note. The trust fund recovery penalty will not apply to any 
to figure the amount of the penalty. If Form 2220 is            amount of trust fund taxes an employer holds back in 
completed, enter the penalty on line 17. See the                anticipation of the credit for qualified sick and family leave 
instructions for line 17. Also see Relief from additions to     wages or the employee retention credit that they are 
tax for underpayments applicable to the new corporate           entitled to. See Pub. 15 for more information.
alternative minimum tax.
                                                                Other penalties. Other penalties can be imposed for 
        Foreign insurance companies, see Notice 90-13,          negligence, substantial understatement of tax, reportable 
  !     1990-1 C.B. 321, before computing estimated tax.        transaction understatements, and fraud. See sections 
CAUTION                                                         6662, 6662A, and 6663.

Interest and Penalties                                          Accounting Methods
        If the corporation receives a notice about penalties    Figure taxable income using the method of accounting 
                                                                regularly used in keeping the corporation's books and 
  !     after it files its return, send the IRS an explanation  records. In all cases, the method used must clearly show 
CAUTION and we will determine if the corporation meets the 
criteria for the reasonable-cause exception to the              taxable income. Permissible methods include cash, 
penalties. Do not attach an explanation when the                accrual, or any other method authorized by the Internal 
corporation's return is filed.                                  Revenue Code.

Interest. Interest is charged on taxes paid late even if an       The gross amounts of underwriting and investment 
extension of time to file is granted. Interest is also charged  income should be computed on the basis of the Statement 
on penalties imposed for failure to file, negligence, fraud,    of Income of the NAIC annual statement to the extent not 
substantial valuation misstatements, substantial                inconsistent with the Internal Revenue Code and its 
understatements of tax, and reportable transaction              regulations. In all cases, the method used must clearly 
understatements from the due date (including extensions)        show taxable income.
to the date of payment. The interest charge is figured at a     Change in accounting method. Generally, the 
rate determined under section 6621.                             corporation must get IRS consent to change either an 
Late filing of return.  A corporation that does not file its    overall method of accounting or the accounting treatment 
tax return by the due date, including extensions, may be        of any material item for income tax purposes. To obtain 
penalized 5% of the unpaid tax for each month or part of a      consent, the corporation must generally file Form 3115, 
month the return is late, up to a maximum of 25% of the         Application for Change in Accounting Method, during the 
unpaid tax. The minimum penalty for a tax return required       tax year for which the change was requested. See the 
to be filed in 2024 that is over 60 days late is the smaller of Instructions for Form 3115 and Pub. 538, Accounting 
the tax due or $485 (adjusted for inflation). The penalty       Periods and Methods, for more information and 
will not be imposed if the corporation can show that the        exceptions, including filing exceptions for qualified small 
failure to file on time was due to reasonable cause. See        business taxpayers. Also see the Instructions for Form 
Caution, earlier.                                               3115 for procedures that may apply for obtaining 
                                                                automatic consent to change certain methods of 
Late payment of tax.    A corporation that does not pay         accounting, non-automatic change procedures, and 
the tax when due may generally be penalized  /  of 1% of 1 2    reduced Form 3115 filing requirements.
the unpaid tax for each month or part of a month the tax is 
not paid, up to a maximum of 25% of the unpaid tax. See         Safe harbor method of accounting for premium ac-
Caution, earlier.                                               quisition expenses. Insurance companies subject to tax 
                                                                under section 831 are provided with a safe harbor method 
Trust fund recovery penalty.   This penalty may apply if        of accounting for premium acquisition expenses. Form 
certain excise, income, social security, and Medicare           3115 must be filed in order to change to the safe harbor 
taxes that must be collected or withheld are not collected      method. For more information, see the Instructions for 
or withheld, or these taxes are not paid. These taxes are       Form 3115.
generally reported on:
Form 720, Quarterly Federal Excise Tax Return;                Certain changes in method of accounting for organi-
                                                                zations to which section 833 applies. Blue Cross or 

Instructions for Form 1120-PC (2023)                                                                                        5



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Blue Shield organizations under section 833(c)(2), or        section 1.351-3(d)(1)) that receives stock of a corporation 
organizations described in section 833(c)(3), can obtain     in exchange for property in a nonrecognition event must 
automatic consent to change the method of accounting for     include the statement required by Regulations section 
unearned premiums resulting from either a failure to meet    1.351-3(a) on or with the transferor's tax return for the tax 
the medical loss ratio (MLR) requirements of section         year of the exchange. The transferee corporation must 
833(c)(5), or meeting the MLR requirements after failing to  include the statement required by Regulations section 
do so in a prior year. Form 3115 must be filed in order to   1.351-3(b) on or with its return for the tax year of the 
make this change in accounting method. See the               exchange, unless all the required information is included 
Instructions for Form 3115.                                  in any statement(s) provided by a significant transferor 
                                                             that is attached to the same return for the same section 
Accounting Period                                            351 exchange. If the transferor or transferee corporation is 
An insurance company must figure its taxable income on       a controlled foreign corporation (CFC), each U.S. 
the basis of a tax year. A tax year is the annual accounting shareholder (within the meaning of section 951(b)) must 
period an insurance company uses to keep its records         include the required statement on or with its return.
and report its income and expenses.
                                                             Distributions under section 355. Every corporation that 
  As a general rule under section 843, the tax year for      makes a distribution of stock or securities of a controlled 
every insurance company is the calendar year. However, if    corporation, as described in section 355 (or so much of 
an insurance company joins in the filing of a consolidated   section 356 as it relates to section 355), must include the 
return, it may adopt the tax year of the common parent       statement required by Regulations section 1.355-5(a) on 
corporation even if that year is not a calendar year.        or with its return for the year of the distribution. A 
                                                             significant distributee (as defined in Regulations section 
Rounding Off to Whole Dollars                                1.355-5(c)) that receives stock or securities of a controlled 
The corporation may enter decimal points and cents when      corporation must include the statement required by 
completing its tax return. However, the corporation should   Regulations section 1.355-5(b) on or with its return for the 
round off cents to whole dollars on its return, forms, and   year of receipt. If the distributing or distributee corporation 
schedules to make completing its return easier. The          is a CFC, each U.S. shareholder (within the meaning of 
corporation must either round off all amounts on its return  section 951(b)) must include the statement on or with its 
to whole dollars, or use cents for all amounts. To round,    return.
drop amounts under 50 cents and increase amounts from 
50 to 99 cents to the next dollar. For example, $8.40        Dual-consolidated losses. If a domestic corporation 
rounds to $8 and $8.50 rounds to $9.                         incurs a dual-consolidated loss (as defined in Regulations 
                                                             section 1.1503(d)-1(b)(5)), the corporation (or 
  If two or more amounts must be added to figure the         consolidated group) may need to attach a domestic use 
amount to enter on a line, include cents when adding the     agreement and/or an annual certification, as provided in 
amounts and round off only the total.                        Regulations sections 1.1503(d)-6(d) and (g).
Recordkeeping                                                Election to reduce basis under section 362(e)(2)(C). 
Keep the corporation's records for as long as they may be    If property is transferred to a corporation subject to section 
needed for the administration of any provision of the        362(e)(2), the transferor and the transferee corporation 
Internal Revenue Code. Usually, records that support an      may elect, under section 362(e)(2)(C), to reduce the 
item of income, deduction, or credit on the return must be   transferor's basis in the stock received instead of reducing 
kept for 3 years from the date the return is due or filed,   the transferee corporation's basis in the property 
whichever is later. Keep records that verify the             transferred. Once made, the election is irrevocable. For 
corporation's basis in property for as long as they are      more information, see section 362(e)(2) and Regulations 
needed to figure the basis of the original or replacement    section 1.362-4. If an election is made, a statement must 
property.                                                    be filed in accordance with Regulations section 1.362-4(d)
                                                             (3).
  The corporation should keep copies of all filed returns. 
They help in preparing future and amended returns and in     Other forms and statements. See Pub. 542, 
the calculation of earnings and profits.                     Corporations, for a list of other forms and statements a 
                                                             corporation may need to file in addition to the forms and 
Other Forms and Statements That                              statements discussed throughout these instructions.
May Be Required
Reportable transaction disclosure statement.                 Specific Instructions

Participants in any reportable transaction must file Form    Period Covered
8886, Reportable Transaction Disclosure Statement. See 
the Instructions for Form 8886.                              Generally, file the 2023 return for calendar year 2023. 
                                                             However, if an insurance company joins in the filing of a 
Reportable transactions by material advisors.                consolidated return, it may adopt the tax year of the 
Material advisors to any reportable transaction must file    common parent corporation even if that year is not a 
Form 8918, Material Advisor Disclosure Statement. See        calendar year. For a fiscal or short tax year return, fill in the 
the Instructions for Form 8918.                              tax year space at the top of the form.
Transfers to a corporation controlled by the transfer-
or. Every significant transferor (as defined in Regulations 

6                                                                   Instructions for Form 1120-PC (2023)



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Name and Address                                             eliminating entries for intercompany transactions between 
                                                             corporations within the consolidated group. Attach 
Enter the corporation's true name (as set forth in the       consolidated balance sheets and a reconciliation of 
charter or other legal document creating it), address, and   consolidated retained earnings.
EIN on the appropriate lines. Enter the address of the 
corporation's principal office or place of business. Include   For more information on consolidated returns, see the 
the suite, room, or other unit number after the street       regulations under section 1502.
address. If the post office does not deliver mail to the 
                                                             Note.   If a nonlife insurance company is a member of an 
street address and the corporation has a P.O. box, show 
                                                             affiliated group, file Form 1120-PC as an attachment to the 
the box number instead.
                                                             consolidated return in addition to the supporting 
Note. Do not use the address of the registered agent for     statements discussed earlier. Across the top of page 1 of 
the state in which the corporation is incorporated. For      Form 1120-PC, enter “Supporting Statement to 
example, if a business is incorporated in Delaware or        Consolidated Return.”
Nevada and the corporation's principal office is located in 
Little Rock, Arkansas, the corporation should enter the      Life-Nonlife Consolidated Return
Little Rock address.                                         If the corporation is the common parent of a life-nonlife 
                                                             consolidated group, check Item A, boxes 1 and 2.
If the corporation has a foreign address, include the city 
or town, state or province, country, and foreign postal      Filing requirements. The common parent of a 
code. Do not abbreviate the country name. Follow the         life-nonlife consolidated group is required to do the 
country's practice for entering the name of the state or     following.
province and postal code.                                    File the applicable consolidated corporate income tax 
                                                             return as one of the following: a Form 1120-L, where the 
If the corporation receives its mail in care of a third 
                                                             common parent is a life insurance company; a Form 
party (such as an accountant or an attorney), enter on the 
                                                             1120-PC, where the common parent is an insurance 
street address line “C/O” followed by the third party's 
                                                             company, other than a life insurance company; or a Form 
name and street address or P.O. box.
                                                             1120, where the common parent is any other type of 
Item A. Identifying Information                              corporation.
                                                             Indicate clearly on the face of the return that the 
Consolidated Return                                          corporate tax return is a life-nonlife return. This 
If an affiliated group of corporations includes one or more  requirement is satisfied by checking Item A, boxes 1 and 
domestic life insurance companies taxed under section        2.
801, the common parent may elect to treat those              Show any setoffs required by paragraphs (e), (h), and 
companies as includible corporations. The life insurance     (j) of Regulations section 1.1502-47.
companies must have been members of the group for the        Report separately the nonlife consolidated taxable 
5 tax years immediately preceding the tax year for which     income or loss, determined under Regulations section 
the election is made. See section 1504(c)(2) and             1.1502-47(f), on a Form 1120 or 1120-PC (whether filed 
Regulations section 1.1502-47(b)(12).                        by the common parent or as an attachment to the 
                                                             consolidated return), for all nonlife members of the 
Corporations filing a consolidated return must check         consolidated group.
Item A, box 1, and attach Form 851, Affiliations Schedule,   Report separately the consolidated life insurance 
and other supporting statements to the return. Also, for the company taxable income (as defined by Regulations 
first year a subsidiary corporation is being included in a   section 1.1502-47(b)(3)) determined under Regulations 
consolidated return, attach Form 1122, Authorization and     section 1.1502-47, on a Form 1120-L (whether filed by the 
Consent of Subsidiary Corporation To Be Included in a        common parent or as an attachment to the consolidated 
Consolidated Income Tax Return, to the parent's              return), for all life members of the consolidated group.
consolidated return. Attach a separate Form 1122 for each 
new subsidiary being included in the consolidated return.    Schedule M-3 (Form 1120-PC)
File supporting statements for each corporation              A nonlife insurance company with total assets 
included in the consolidated return. Do not use Form         (nonconsolidated or consolidated for all companies 
1120-PC as a substitute for the supporting statement. On     included within a tax consolidation group) of $10 million or 
the supporting statement, use columns to show the            more on the last day of the tax year must file 
following, both before and after adjustments.                Schedule M-3 (Form 1120-PC) instead of Schedule M-1. 
                                                             A corporation filing Form 1120-PC that is not required to 
1. Items of gross income and deductions.
                                                             file Schedule M-3 may voluntarily file Schedule M-3 
2. A computation of taxable income.                          instead of Schedule M-1.
3. Balance sheets as of the beginning and end of the           If you are filing Schedule M-3 (Form 1120-PC), check 
tax year.                                                    Item A, box 3, at the top of page 1 of Form 1120-PC. See 
4. A reconciliation of income per books with income          the Instructions for Schedule M-3 (Form 1120-PC) for 
per return.                                                  more details.
5. A reconciliation of retained earnings.
                                                             Note.   If you do not file Schedule M-3 (Form 1120-PC) 
Enter on Form 1120-PC the totals for each item of            with Form 1120-PC, see Reconciliation under Statements, 
income, gain, loss, expense, or deduction, net of            earlier.

Instructions for Form 1120-PC (2023)                                                                                     7



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Item B. Employer Identification                              2. Section 953(d) to be treated as a domestic 
                                                             corporation.
Number (EIN)
                                                             Generally, a foreign corporation making either section 
Enter the corporation's EIN. If the corporation does not     953 election must file its return by sending it to:
have an EIN, it must apply for one. An EIN can be applied 
for in any of the following ways.                            Internal Revenue Service Center
Online—Go to                                               P.O. Box 409101
IRS.gov/EIN. The EIN is issued immediately once the          Ogden, UT 84409
application information is validated.
By faxing or mailing Form SS-4, Application for            See Notice 87-50, 1987-2 C.B. 357; and Rev. Proc. 
Employer Identification Number.                              2003-47, 2003-28 I.R.B. 55, for the procedural rules, 
        Corporations located in the United States or U.S.    election statement formats, and filing addresses for 
                                                             making the respective elections under section 953(c)(3)
CAUTION corporations may call 267-941-1099 (not a 
  !     territories can use the online application. Foreign  (C) or section 953(d).
toll-free number) for more information on obtaining an EIN.  Once either election is made, it will apply to the tax year 
See the Instructions for Form SS-4.                          for which made and all subsequent tax years unless 
                                                             revoked with the consent of the IRS. Also, any loss of a 
EIN applied for, but not received.   If the corporation has  foreign corporation electing to be treated as a domestic 
not received its EIN by the time the return is due, enter    insurance company under section 953(d) will be treated 
“Applied For” and the date the corporation applied in the    as a dual-consolidated loss and may not be used to 
space for the EIN. However, if the corporation is filing its reduce the taxable income of any other member of the 
return electronically, an EIN is required at the time the    affiliated group for this tax year or any other tax year.
return is filed. An exception applies to subsidiaries of 
corporations whose returns are filed with the parent's       If a section 953(d) election is made, include the 
electronically filed consolidated Form 1120. These           additional tax required to be paid on page 1, line 14. On 
subsidiaries should enter “Applied For” in the space for the the dotted line to the left of line 14, enter “Section 953(d)” 
EIN on their returns. The subsidiaries' returns are          and the amount. Attach a statement showing the 
identified under the parent corporation's EIN.               computation. See section 953(d) for more details.

  For more information, see the Instructions for Form        Note. A captive insurance company can make an election 
SS-4.                                                        under section 831(b) and an election under section 953(d) 
                                                             if it is a foreign insurance company.
Item D. Section 831(b) and Section 
                                                             Item E. Final Return, Name Change, 
953 Elections
Check the applicable box(es) if an election is made under    Address Change, or Amended Return
section(s) 831(b), 953(c)(3)(C), or 953(d).                  Indicate a final return, name change, address change, or 
                                                             amended return by checking the appropriate box.
Section 831(b) election. Check the 831(b) box if the 
insurance company elects to be taxed on taxable              Note. If a change in address or responsible party occurs 
investment income in lieu of the tax otherwise applicable    after the return is filed, use Form 8822-B, Change of 
under section 831(a). Section 831(b) applies to a small      Address or Responsible Party — Business, to notify the 
company, as defined under section 831(b)(2)(A), if such      IRS. See the instructions for Form 8822-B for details.
company meets the diversification requirements of section 
831(b)(2)(B) and such corporation elects the application     Taxable Income
of section 831(b) for such tax year under section 831(b)(2)
                                                             Line 1, Taxable income, and line 2, Taxable invest-
(A)(iii). See the instructions for Schedule I, Question 14, 
                                                             ment income. If the corporation is a small company as 
later. See Regulations section 301.9100-8(a) for the rules 
                                                             defined in section 831(b)(2) and elects under section 
regarding the timing and manner of making the election 
                                                             831(b)(2)(A)(iii) to be taxed on taxable investment income, 
under section 831(b)(2)(A)(iii).
                                                             complete Schedule B (ignore Schedule A) and enter the 
Note. The election under section 831(b)(2)(A)(iii) applies   amount from Schedule B, line 21, on page 1, line 2. Also, 
to the tax year for which made and for all subsequent tax    complete Schedule I, Question 14. All other corporations 
years for which a corporation is a small company, as         should complete Schedule A (ignore Schedule B) and 
defined under section 831(b)(2)(A), and such corporation     enter on page 1, line 1, the amount from Schedule A, 
meets the diversification requirements of section 831(b)     line 37.
(2)(B). Once made, an election under section 831(b)(2)(A)
(iii) may only be revoked with the consent of the Secretary. Tax Computation and Payments
Section 953 elections. Check the applicable box if the       Line 3. Income tax.   Multiply taxable income (page 1, 
corporation is a foreign corporation and elects under:       line 1) by 21%. (0.21). Enter this amount on line 3.
  1. Section 953(c)(3)(C) to treat its related person        Deferred tax under section 1291.     If the corporation 
insurance income as effectively connected with the           was a shareholder in a passive foreign investment 
conduct of a trade or business in the United States, or      company (PFIC) and received an excess distribution or 
                                                             disposed of its investment in the PFIC during the year, it 
                                                             must include the total increase in taxes due under section 

8                                                                                  Instructions for Form 1120-PC (2023)



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1291(c)(2) from Form 8621 in the amount entered on              Line 8d. Credit for prior year minimum tax.    Enter any 
line 3. On the dotted line next to line 3, enter “Section       allowable credit from Form 8827, Credit for Prior Year 
1291” and the amount.                                           Minimum Tax—Corporations. Complete and attach Form 
Do not include on line 3 any interest due under section         8827.
1291(c)(3). Instead, include the amount of interest owed 
                                                                Line 8e. Bond credits from Form 8912.  Enter the 
on line 12z.
                                                                allowable credits from Form 8912, Credit to Holders of Tax 
For more information on reporting the deferred tax and          Credit Bonds, line 12.
interest, see the Instructions for Form 8621.
                                                                Line 8f. Total credits. Add lines 8a through 8e. Enter the 
Additional tax under section 197(f). A corporation 
                                                                total on line 8f.
that elects to recognize gain and pay tax on the sale of a 
section 197 intangible under the related person exception       Line 10. Foreign corporations. A foreign corporation 
to the anti-churning rules should include any additional tax    carrying on an insurance business in the United States is 
due in the total for line 3. On the dotted line next to line 3, taxed as a domestic insurance company on its income 
enter “Section 197” and the amount. See section 197(f)(9)       effectively connected with the conduct of a trade or 
(B)(ii).                                                        business in the United States (see sections 864(c) and 
                                                                897 for a definition).
Line 4. Enter amount of tax that a reciprocal must in-
clude.   A mutual insurance company that is an                    Generally, any other U.S.-source income received by 
interinsurer or reciprocal underwriter may elect, under         the foreign corporation is taxed at 30% (or at a lower treaty 
section 835, to limit the deduction for amounts paid or         rate) under section 881. If the corporation has this income, 
incurred to a qualifying attorney-in-fact to the amount of      attach a statement showing the kind and amount of 
the deductions of the attorney-in-fact allocable to the         income, the tax rate, and the amount of tax. Enter the tax 
income received by the attorney-in-fact from the                on line 10. However, see Reduction of section 881 tax, 
reciprocal. If this election is made, any increase in taxable   later.
income of a reciprocal as a result of this limitation is taxed 
at the highest rate of tax specified in section 11(b).          Note. Interest received from certain portfolio debt 
                                                                investments that were issued after July 18, 1984, is not 
Make no entry on line 4 if the mutual insurance                 subject to the tax. See section 881(c).
company's taxable income before including the section 
835(b) amount is $100,000 or more. Otherwise, this tax is         See section 842 for more information.
21% of the section 835(b) amount. If an entry is made on          Minimum effectively connected net investment 
line 4, attach a statement showing how the tax was              income.  See section 842(b) and Notice 89-96, 1989-2 
computed.                                                       C.B. 417, for the general rules for computing this amount. 
                                                                Also, see Rev. Proc. 2023-21, 2023-19 I.R.B. 837 (or any 
Reciprocal underwriters making the section 835(a)               successor), available at IRS.gov/irb/2023-19_IRB#REV-
election are allowed a credit on line 15f for the amount of     PROC-2023-21, for the domestic asset/liability 
tax paid by the attorney-in-fact that is related to the         percentages and domestic investment yields needed to 
income received by the attorney-in-fact from the reciprocal     compute this amount.
in the tax year.
                                                                  Any additional income required by section 842(b) must 
See section 835 and the related regulations for special         be included in taxable income (for example, Schedule A, 
rules and information regarding the statements required to      line 13).
be attached to the return.
                                                                  Reduction of section 881 tax. Additional taxes 
Line 5. Base erosion minimum tax amount.       If the           resulting from the net investment income adjustment may 
corporation had gross receipts of at least $500 million in      offset a corporation's section 881 tax on U.S.-source 
any 1 of the 3 preceding tax years, see section 59A and         income. The tax reduction is determined by multiplying the 
the Instructions for Form 8991 for further guidance on the      section 881 tax by the ratio of the amount of income 
determination of the amount of base erosion minimum tax.        adjustment to income subject to the section 881 tax, 
Line 6. Corporate alternative minimum tax.       Enter on       computed without the exclusion for interest on state and 
line 6 the amount from Form 4626, Alternative Minimum           local bonds or income exempted from taxation by treaty. 
Tax—Corporations, Part II, line 13, if applicable. See the      See section 842(c)(1). Attach a statement showing how 
Instructions for Form 4626.                                     the reduction under section 881 was figured. Enter the net 
                                                                tax imposed by section 881 on line 10.
Line 8a. Foreign tax credit. To find out when a 
corporation can take the credit for payment of income tax       Line 11. Personal holding company tax.        A corporation 
to a foreign country or U.S. territory, see Form 1118,          (other than a corporation described in section 542(c)) is 
Foreign Tax Credit—Corporations.                                taxed as a personal holding company (PHC) under 
                                                                section 542 if:
Line 8b. Credit from Form 8834.  Enter any qualified            At least 60% of its adjusted ordinary gross income for 
electric vehicle passive activity credits from prior years      the tax year is PHC income, and
allowed for the current tax year from Form 8834, Qualified      At any time during the last half of the tax year more than 
Electric Vehicle Credit, line 7. Attach Form 8834.              50% in value of its outstanding stock is directly or 
Line 8c. General business credit. Enter on line 8c the          indirectly owned by five or fewer individuals.
allowable credit from Form 3800, General Business 
Credit, Part II, line 38. See the Instructions for Form 3800.

Instructions for Form 1120-PC (2023)                                                                                      9



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  See Schedule PH (Form 1120), U.S. Personal Holding           Line 15f. Credit by reciprocal for tax paid by attor-
Company (PHC) Tax, for definitions and details on how to       ney-in-fact under section 835(d). Enter the amount of 
figure the tax.                                                tax paid by an attorney-in-fact as a result of income 
Line 12a. Recapture of investment credit.     If the           received by the attorney-in-fact from the reciprocal during 
corporation disposed of investment credit property or          the tax year. For more information, see section 835 and 
changed its use before the end of the 5-year recapture         the related regulations, and the instructions for line 4, 
period under section 50(a), enter the increase in tax from     earlier.
Form 4255, Recapture of Investment Credit. See the             Line 15g. Elective payment election amount from 
Instructions for Form 4255.                                    Form 3800.  Enter on line 15g the total net elective 
Line 12b. Recapture of low-income housing credit.          If  payment election amount from Form 3800, Part III, line 6, 
the corporation disposed of property (or there was a           column (i). See the Instructions for Form 3800.
reduction in the qualified basis of the property) for which it Line 15z. Other credits and payments.      Enter the 
took the low-income housing credit, and the corporation        amount of any other credits the corporation may take 
did not follow the procedures that would have prevented        and/or payments made. Enter an explanation of the entry 
recapture of the credit, it may owe a tax. See Form 8611,      to the left of the entry space.
Recapture of Low-Income Housing Credit. Complete and           Backup withholding.        If the corporation had federal 
attach Form 8611.                                              income tax withheld from any payments it received 
Line 12z. Other. If the corporation includes any               because, for example, it failed to give the payer its correct 
additional taxes and interest such as the items discussed      EIN, include the amount withheld in the total for line 15z. 
below, attach a statement showing the computation of           Enter the amount withheld and the words “Backup 
each item included in the total for line 12z and identify the  Withholding” on the dotted line to the left of the entry 
applicable Code section and the type of tax or interest.       space for line 15z.
Recapture of Indian employment credit. Generally, if an      Line 16. Total. Combine the amounts on lines 15d 
employer terminates the employment of a qualified              through 15z and enter the total on line 16.
employee less than 1 year after the date of initial 
employment, any Indian employment credit allowed for a         Line 17. Estimated tax penalty. Generally, the 
prior tax year because of wages paid or incurred to that       corporation does not have to file Form 2220 with its 
employee must be recaptured. See Form 8845 and                 income tax return because the IRS will figure the amount 
section 45A.                                                   of any penalty and notify the corporation of any amount 
Recapture of new markets credit (see Form 8874, New          due. However, see the Instructions for Form 2220 for 
Markets Credit, and Form 8874-B, Notice of Recapture           circumstances where the corporation must file Form 2220 
Event for New Markets Credit).                                 even if it owes no penalty.
Recapture of employer-provided childcare facilities and      If Form 2220 is attached, check the box on line 17 and 
services credit (see Form 8882).                               enter any penalty on this line.
Interest on deferred tax attributable to certain nondealer 
                                                                       If the corporation's tax liability includes a CAMT 
installment obligations (see section 453A(c)).
                                                                       liability, the corporation must complete and attach 
Interest due on deferred gain (see section 1260(b)).         CAUTION!
                                                                       Form 2220. The affected corporation must also 
Interest due under section 1291(c)(3). See Form 8621 
                                                               include an amount of estimated tax penalty on Form 
and its instructions.
                                                               1120-PC, line 17, even if that amount is zero. Failure to 
Alternative tax on qualifying shipping activities (see 
                                                               follow these instructions could result in the corporation 
Form 8902).
                                                               receiving a penalty notice that will require an abatement 
Line 14. Total tax.  Include any deferred tax on the           request to apply any penalty relief. See Notice 2023-42.
termination of a section 1294 election applicable to 
shareholders in a qualified electing fund (QEF) in the         Line 18. Amount owed.      If the corporation cannot pay 
amount entered on line 14.                                     the full amount of tax owed, it can apply for an installment 
  Subtract any deferred tax on the corporation's share of      agreement online. Go to IRS.gov/OPA for the latest 
undistributed earnings of a QEF (see Form 8621).               information.
  How to report. Attach a statement showing the                Line 20. Electronic deposit of tax refund of $1 million 
computation of each item included in, or subtracted from,      or more. If the corporation is due a refund of $1 million or 
the total for line 14. On the dotted line next to line 14,     more and wants it electronically deposited into its 
specify (a) the applicable Code section, (b) the type of tax,  checking or savings account at any U.S. bank or other 
and (c) the amount of tax.                                     financial institution instead of having a check sent to the 
Line 15c. Current year’s refund applied for on Form            corporation, complete Form 8302 and attach it to the 
4466. If the corporation overpaid estimated tax, it may be     corporation's tax return.
able to get a quick refund by filing Form 4466. The 
overpayment must be at least 10% of the corporation's          Schedule A—Taxable Income
expected income tax liability and at least $500. File Form 
4466 after the end of the corporation's tax year, and no       Gross income.   Under section 832, gross amounts of 
later than the due date for filing the corporation’s tax       underwriting and investment income should be computed 
return. Form 4466 must be filed before the corporation         on the basis of the Statement of Income of the NAIC 
files its tax return. See the instructions for Form 4466.

10                                                                                Instructions for Form 1120-PC (2023)



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annual statement to the extent not inconsistent with the      The net capital loss for these corporations is the 
Internal Revenue Code and its regulations.                    amount by which losses for the year from sales or 
                                                              exchanges of capital assets exceed the gains from these 
Income from qualifying shipping activities.     Gross 
                                                              sales or exchanges plus the smaller of:
income does not include income from qualifying shipping 
activities if the corporation makes an election under         1. Taxable income (computed without gains or losses 
section 1354 to be taxed on its notional shipping income      from sales or exchanges of capital assets); or
(as defined in section 1353) at the highest corporate tax     2. Losses from the sale or exchange of capital assets 
rate specified in section 11. If the election is made, the    sold or exchanged to obtain funds to meet abnormal 
corporation may generally not claim any loss, deduction,      insurance losses and to provide for the payment of 
or credit with respect to qualifying shipping activities. A   dividends and similar distributions to policyholders.
corporation making this election may also elect to defer 
gain on the disposition of a qualifying vessel.               Subject to the limitations in section 1212(a), a net 
                                                              capital loss can be carried back 3 years and forward 5 
Use Form 8902, Alternative Tax on Qualifying Shipping         years as a short-term capital loss.
Activities, to figure the tax. Include the alternative tax on 
Form 1120-PC, page 1, line 12z.                               Line 8. Certain mutual fire or flood insurance compa-
                                                              ny premiums. A mutual fire or flood insurance company 
Note. In computing the amounts for lines 2, 3, and 4, take    whose principal business is the issuance of policies (1) for 
all interest, dividends, or rents received during the year;   which the premium deposits are the same (regardless of 
add interest, dividends, or rents due and accrued at the      the length of the term the policies are written for), and (2) 
end of the tax year; and deduct interest, dividends, or       under which the unabsorbed portion of such premium 
rents due and accrued at the end of the preceding tax         deposits not required for losses, expenses, or 
year. For rules regarding the accrual of dividends, see       establishment of reserves is returned or credited to the 
Regulations section 1.301-1(b).                               policyholder on cancellation or expiration of the policy, 
                                                              must include in income an amount equal to 2% of the 
Line 3a, column (a). Interest (including tax-exempt 
                                                              premiums earned on insurance contracts during the tax 
interest). Enter the gross amount of interest income, 
                                                              year with respect to such policies after deduction of 
including all tax-exempt interest.
                                                              premium deposits returned or credited during the same 
Line 3b, column (a). Interest exempt under section            tax year.
103. Section 103(a) excludes interest on state or local 
                                                              Line 9. Income on account of special income and de-
bonds from gross income.
                                                              duction accounts. Corporations which write the kinds of 
This exclusion does not apply to any:                         insurance below must maintain the following special 
1. Private activity bond which is not a qualified bond,       accounts. A corporation which writes:
as defined by section 141;                                    1. Mortgage guaranty insurance must maintain a 
2. Arbitrage bond, as defined by section 148; or              mortgage guaranty account,
3. Bonds not meeting the requirements of section 149          2. Lease guaranty insurance must maintain a lease 
(regarding the registration of tax-exempt bonds).             guaranty account, and
                                                              3. Insurance on obligations the interest on which is 
Lines 3a and 3b, column (b). Amortization of premi-
                                                              excludable from gross income under section 103 must 
um.  Enter on line 3a, column (b), the total amortization of 
                                                              maintain an account with respect to insurance on state 
bond premium, including amortization on tax-exempt 
                                                              and local obligations.
bonds. Enter on line 3b, column (b), the amortization of 
bond premium on tax-exempt bonds only.                        Amounts required to be subtracted from these 
                                                              accounts under sections 832(e)(5) and 832(e)(6) must be 
Note. Insurance companies electing to amortize discount       reported as income on line 9. See section 832(e) for more 
for tax purposes must reduce the amortization of premium      information.
by any amortization of discount.
                                                              Line 10. Income from protection against loss ac-
Line 4. Gross rents. Enter gross rents, computed as           count. Although section 1024 of P.L. 99-514 repealed 
indicated under Gross income, earlier. Deduct expenses,       section 824 relating to the protection against loss (PAL) 
such as repairs, interest, taxes, and depreciation, on the    account, PAL account balances are includible in income 
proper lines for deductions.                                  as though section 824 were still in effect. Attach a 
Line 6. Capital gain net income.  Every sale or               statement showing the computation.
exchange of a capital asset must be reported in detail on     Line 11. Mutual interinsurers or reciprocal underwrit-
Schedule D (Form 1120), Capital Gains and Losses, even        ers—decrease in subscriber accounts.     Enter the 
if there is no gain or loss.                                  decrease for the tax year in savings credited to subscriber 
Generally, losses from sales or exchanges of capital          accounts of a mutual insurance company that is an 
assets are only allowed to the extent of gains. However,      interinsurer or a reciprocal underwriter.
corporations taxed under section 831 may claim losses         Line 13. Other income. Enter any other taxable income 
from capital assets sold or exchanged to get funds to         not reported on lines 1 through 11. List the type and 
meet abnormal insurance losses and to pay dividends and       amount of income on an attached statement. If the 
similar distributions to policyholders. Do not include those  corporation has only one item of other income, describe it 
types of losses here; instead, report them on Schedule G.

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in parentheses on line 13. Examples of other income to       the last day of any calendar quarter in which the credit is 
report on line 13 include the following.                     allowed.
Any income under P.L. 115-97, section 13517(c)(3)(B)
(ii) (transitional relief for change in reserve).            Note. A credit is available only if the leave was taken after 
Any amount includible in income from Form 6478,            March 31, 2020, and before October 1, 2021, and only 
Biofuel Producer Credit.                                     after the qualified leave wages were paid, which might, 
Any amount includible in income from Form 8864,            under certain circumstances, not occur until a quarter 
Biodiesel, Renewable Diesel, or Sustainable Aviation         after September 30, 2021, including quarters in 2023.
Fuels Credit.
Refunds of taxes deducted in prior years to the extent     Deductions
they reduced income subject to tax imposed. See section 
111 and the related regulations. Do not offset current-year  Limitations on Deductions
taxes against tax refunds.
                                                             Section 263A uniform capitalization rules.      The 
Ordinary income from trade or business activities of a 
                                                             uniform capitalization rules of section 263A require 
partnership from Schedule K-1 (Form 1065). Do not offset 
                                                             corporations to capitalize certain costs.
ordinary losses against ordinary income. Instead, include 
the losses on line 31. Show the partnership's name,          A small business taxpayer is not required to capitalize 
address, and EIN on a separate statement attached to this    costs under section 263A. A small business taxpayer that 
return. If the amount entered is from more than one          wants to discontinue capitalizing costs under section 
partnership, identify the amount from each partnership.      263A must change its method of accounting. See section 
The transferred loss amount identified as “Section 91      263A(i) and Regulations section 1.263A-1(j). Also, see the 
Transferred Loss Amount.” This amount is required to be      Instructions for Form 3115.
recognized under section 91 resulting from a transfer of     For more information on the uniform capitalization rules, 
substantially all the assets of a foreign branch (within the see Pub. 538. Also, see Regulations sections 1.263A-1 
meaning of section 367(a)(3)(C), as in effect before its     through 1.263A-3.
repeal) to a specified 10%-owned foreign corporation (as 
                                                             Transactions between related taxpayers.     Generally, 
defined in section 245A(b)) with respect to which the 
                                                             an accrual basis taxpayer can only deduct business 
corporation was a U.S. shareholder immediately after the 
                                                             expenses and interest owed to a related party in the year 
transfer as other income. Under section 91(d), transferred 
                                                             the payment is included in the income of the related party. 
loss amounts recognized are treated as derived from 
                                                             See sections 163(e)(3) and 267 for limitations on 
sources within the United States.
                                                             deductions for unpaid interest and expenses.
Part or all of the proceeds received from certain 
corporate-owned life insurance contracts issued after        Limitations on business interest expense.        Business 
August 17, 2006. Corporations that own one or more           interest expense may be limited. See section 163(j) and 
employer-owned life insurance contracts issued after         Form 8990, Limitation on Business Interest Expense 
August 17, 2006, must file Form 8925, Report of              Under Section 163(j). Also, see Limitation on deduction in 
Employer-Owned Life Insurance Contracts. See Form            the instructions for Schedule A, Line 20a and Schedule I, 
8925.                                                        Question 18, later.
One-eighth of any adjustment attributable to the           Section 291 limitations. Corporations may be required 
application of the discount factors published in Rev. Proc.  to adjust certain deductions. See section 291 to determine 
2019-06, 2019-02 I.R.B 284, available at IRS.gov/irb/        the amount of the adjustment.
2019-02_IRB#RP-2019-06, to unpaid losses for the tax 
year preceding the first tax year beginning after December   Golden parachute payments.      A portion of the 
31, 2017.                                                    payments made by a corporation to key personnel that 
The corporation's share of the following income from       exceeds their usual compensation may not be deductible. 
Form 8621, Information Return by a Shareholder of a          This occurs when the corporation has an agreement 
Passive Foreign Investment Company or Qualified              (golden parachute) with these key employees to pay them 
Electing Fund.                                               these excess amounts if control of the corporation 
                                                             changes. See section 280G and Regulations section 
  1. Ordinary earnings of a QEF.
                                                             1.280G-1. Also, see the instructions for line 15.
  2. Gain or loss from marking PFIC stock to market.
                                                             Business start-up and organizational costs.                 A 
  3. Gain or loss from sale or other disposition of section  corporation can elect to deduct a limited amount of 
1296 stock.                                                  start-up and organizational costs it paid or incurred. Any 
  4. Excess distributions from a section 1291 fund           remaining costs must generally be amortized over a 
allocated to the current year and pre-PFIC years, if any.    180-month period. See sections 195 and 248 and the 
  See Form 8621 and its instructions for details.            related regulations.
Any payroll tax credit taken by an employer on its 2023    Time for making an election.    The corporation 
employment tax returns (Forms 941, 943, and 944) for         generally elects to deduct startup or organizational costs 
qualified paid sick leave and qualified paid family leave    by claiming the deduction on its income tax return filed by 
under the FFCRA and the ARP (both the nonrefundable          the due date (including extensions) for the tax year in 
and refundable portions). The corporation must include       which the active trade or business begins. For more 
the full amount of the credit for qualified sick and family  details including special rules for costs paid or incurred 
leave wages in gross income for the tax year that includes 

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before September 9, 2008, see the Instructions for Form      Limitation on tax benefits for remuneration under the 
4562, Depreciation and Amortization.                         Patient Protection and Affordable Care Act.                 The $1 
  If the corporation timely filed its return for the year    million compensation limit is reduced to $500,000 for 
without making an election, it can still make an election by remuneration for services provided by individuals for or on 
filing an amended return within 6 months of the due date     behalf of certain health insurance providers. The 
of the return (excluding extensions). Clearly indicate the   $500,000 limitation applies to remuneration that is 
election on the amended return and enter “Filed pursuant     deductible in the tax year during which the services were 
to Regulations section 301.9100-2” at the top of the         performed and remuneration for services during the year 
amended return. File the amended return at the same          that is deductible in a future tax year (called “deferred 
address the corporation filed its original return. The       deduction remuneration”). The $500,000 limitation is 
election applies when figuring taxable income for the        reduced by any amounts disallowed as excess parachute 
current tax year and all subsequent years.                   payments. See section 162(m)(6) and Regulations section 
  The corporation can choose to forgo the election by        1.162-31 for definitions and other special rules. Also, see 
affirmatively electing to capitalize its start-up or         Notice 2011-2, 2011-2 I.R.B. 260.
organizational costs on its income tax return filed by the   Line 15. Compensation of officers. Enter deductible 
due date (including extensions) for the tax year in which    officers' compensation on line 15. See Employment 
the active trade or business begins.                         credits, later, for employment credits that may reduce your 
                                                             deduction for officers' compensation. Do not include 
Note. The election to either amortize or capitalize start-up compensation deductible elsewhere on the return, such 
costs is irrevocable and applies to all start-up costs that  as elective contributions to a section 401(k) cash or 
are related to the trade or business.                        deferred arrangement, or amounts contributed under a 
  Report the deductible amount of such costs and any         salary reduction SEP agreement or a SIMPLE IRA plan.
amortization on Schedule A, line 31. For amortization that     Include only the deductible part of each officer's 
begins during the current tax year, complete and attach      compensation on line 15. (See    Disallowance of deduction 
Form 4562.                                                   for employee compensation in excess of $1 million, later). 
Reducing certain expenses for which credits are al-          Attach a statement for all officers using the following 
lowable.  If the corporation claims certain credits, it may  columns.
need to reduce allowable deductions for expenses used to       1. Name of officer.
figure the credit. This applies to credits such as the 
                                                               2. Social security number.
following.
Employment credits. See Employment credits, later.           3. Percentage of time devoted to business.
Credit for increasing research activities (Form 6765).       4. Amount of compensation.
Orphan drug credit (Form 8820).
                                                               If a consolidated return is filed, each member of an 
Disabled access credit (Form 8826).
                                                             affiliated group must furnish this information.
Employer credit for social security and Medicare taxes 
paid on certain employee tips (Form 8846).                   Disallowance of deduction for employee compensa-
Credit for small employer pension plan start-up costs      tion in excess of $1 million.    Publicly held corporations 
(Form 8881).                                                 cannot deduct compensation to a “covered employee” to 
Credit for employer-provided childcare facilities and      the extent that the compensation exceeds $1 million. 
services (Form 8882).                                        Generally, a covered employee is:
Credit for small employer health insurance premiums        The principal executive officer of the corporation (or an 
(Form 8941).                                                 individual acting in that capacity) as of the end of the tax 
  If the corporation has any of these credits, figure the    year, or
current year credit before figuring the deduction for        An employee whose total compensation must be 
expenses on which the credit is based. If the corporation    reported to shareholders under the Securities Exchange 
capitalized any costs on which it figured the credit, it may Act of 1934 because the employee is among the three 
need to reduce the amount capitalized by the credit          highest compensated officers for that tax year (other than 
attributable to these costs.                                 the principal executive officer).
  See the instructions for the form used to figure the         For this purpose, compensation does not include the 
applicable credit for more details.                          following.
                                                             Income from certain employee trusts, annuity plans, or 
Limitations on deductions related to property leased         pensions.
to tax-exempt entities. If a corporation leases property     Any benefit paid to an employee that is excluded from 
to a governmental or other tax-exempt entity, the            the employee's income.
corporation cannot claim deductions related to the 
                                                               The deduction limit does not apply to:
property to the extent that they exceed the corporation's 
income from the lease payments. This disallowed              Commissions based on individual performance;
tax-exempt use loss can be carried over to the next tax      Qualified performance-based compensation; and
year and treated as a deduction with respect to the          Income payable under a written, binding contract in 
                                                             effect on February 17, 1993.
property for that tax year. See section 470(d) for 
exceptions.                                                    The $1 million limit is reduced by amounts disallowed 
                                                             as excess parachute payments under section 280G.

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  See section 162(m) and Regulations section 1.162-27.                                                      And the vehicle's FMV on the 
Also, see Notice 2007-49, 2007-25 I.R.B. 1429.                       The lease term began:                  first day of the lease exceeded:
Limitations on tax benefits for executive compensa-          Cars (excluding trucks and vans)
tion under the Treasury Troubled Asset Relief Pro-           After 12/31/22 but before 1/1/2024 . . . . . .                   $60,000
                                                             After 12/31/21 but before 1/1/23 . . . . . . .                   $56,000
gram (TARP).   The $1 million compensation limit is 
                                                             After 12/31/20 but before 1/1/22 . . . . . . .                   $51,000
reduced to $500,000 for executive remuneration and 
                                                             After 12/31/17 but before 1/1/21 . . . . . . .                   $50,000
deferred deduction executive remuneration paid to                                             . . . . . . .                   $19,000
                                                             After 12/31/12 but before 1/1/18
covered executives by any entity that receives or has        Trucks and Vans
received financial assistance under the TARP. The limit      After 12/31/22 but before 1/1/24 . . . . . . .                   $60,000
applies for each period in which obligations arising from    After 12/31/21 but before 1/1/23 . . . . . . .                   $56,000
financial assistance under the TARP remain outstanding.      After 12/31/20 but before 1/1/22 . . . . . . .                   $51,000
The $500,000 is reduced by any amounts disallowed as         After 12/31/17 but before 1/1/21 . . . . . . .                   $50,000
excess parachute payments. See section 162(m)(5) for         After 12/31/13 but before 1/1/18 . . . . . . .                   $19,500
definitions and other special rules. Also, see Notice        After 12/31/09 but before 1/1/14 . . . . . . .                   $19,000
2008-94, 2008-44 I.R.B. 1070, for additional guidance.
  In addition, a portion of any parachute payments made 
to a covered executive by an applicable employer               See Pub. 463, Travel, Gift, and Car Expenses, for 
participating in a TARP is not deductible as compensation    instructions on figuring the inclusion amount.
if the payments are made because of a severance from 
employment during an applicable tax year. For this           Note. The inclusion amount for lease terms beginning in 
purpose, a parachute payment is any payment to a senior      2024 will be published in the Internal Revenue Bulletin in 
executive officer for departure from a company for any       early 2024.
reason, except for payments for services performed or        Line 19. Taxes and licenses.                 Enter taxes paid or 
benefits accrued. These limits do not apply to a payment     accrued during the tax year, but do not include the 
already treated as a parachute payment. See section          following.
280G(e) and Notice 2008-94.                                  Federal income taxes.
Line 16. Salaries and wages.  Enter the total salaries       Foreign or U.S. territories income taxes if a tax credit is 
and wages paid for the tax year. Do not include salaries     claimed.
and wages deductible elsewhere on the return, such as        Taxes not imposed on the corporation.
amounts included in officers' compensation, elective         Taxes, including state or local sales taxes, that are paid 
contributions to a section 401(k) cash or deferred           or incurred in connection with an acquisition or disposition 
arrangement, or amounts contributed under a salary           of property (these taxes must be treated as a part of the 
reduction SEP agreement or a SIMPLE IRA plan.                cost of the acquired property or, in the case of a 
                                                             disposition, as a reduction in the amount realized on the 
  If the corporation provided taxable fringe benefits to its disposition).
employees, such as the personal use of a car, do not           Taxes assessed against local benefits that increase the 
                                                             
deduct as wages the amount allocated for depreciation        value of the property assessed (such as for paving, etc.).
and other expenses that are claimed elsewhere on the           Taxes deducted elsewhere on the return.
                                                             
return (for example, on Schedule A, line 22 or line 31).
                                                               See section 164(d) for information on the 
        If the corporation claims a credit for any wages     apportionment of taxes on real property between a seller 
  !     paid or incurred, it may need to reduce any          and a purchaser.
CAUTION corresponding deduction for salaries and wages. 
See Employment credits below.                                Note. Section 9010 of the Patient Protection and 
                                                             Affordable Care Act imposes a fee on each covered entity 
Employment credits. If the corporation claims a credit       engaged in the business of providing health insurance for 
on any of the forms below, it may need to reduce its         U.S. health risks. The fee is treated as a tax described in 
deduction for officers’ compensation and salaries and        section 275 relating to taxes for which no deduction is 
wages. See the applicable form for details.                  allowed. For more information, see the final regulations 
Form 5884, Work Opportunity Credit.                        and Rev. Rul. 2013-27.
Form 8844, Empowerment Zone Employment Credit.
Form 8932, Credit for Employer Differential Wage                   Do not reduce the corporation's deduction for 
Payments.                                                      !     social security and Medicare taxes by the 
Form 8994, Employer Credit for Paid Family and             CAUTION nonrefundable and refundable portions of any 
Medical Leave.                                               FFCRA and ARP credits for qualified sick and family leave 
                                                             wages claimed on its employment tax returns. Instead, 
Line 18. Rents. If the corporation rented or leased a        report this amount as income on line 13.
vehicle, enter the total annual rent or lease expense paid 
or incurred during the year. Also, complete Form 4562,       Line 20a. Interest. 
Part V. If the corporation leased a vehicle for a term of 30 
days or more, the deduction for the vehicle lease expense    Note. Do not offset interest income against interest 
may have to be reduced by an amount includible in            expense.
income called the inclusion amount. The corporation may        The corporation must allocate the interest expense if 
have an inclusion amount if:                                 the proceeds of a loan were used for more than one 

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purpose (for example, to purchase a portfolio investment      For other special rules that apply to corporations, see Pub. 
and to acquire an interest in a passive activity). See        542.
Temporary Regulations section 1.163-8T for the interest 
                                                              Line 22. Depreciation. Include on line 22 depreciation 
allocation rules.
                                                              and the cost of certain property that the corporation 
  Do not deduct the following interest.                       elected to expense under section 179. See Form 4562 
Interest on indebtedness incurred or continued to           and the Instructions for Form 4562.
purchase or carry obligations if the interest is wholly 
exempt from income tax. See section 265(b) for special        Line 23. Depletion. If the corporation has an economic 
rules and exceptions for financial institutions. Also, see    interest in mineral property or standing timber, it can take 
section 265(b)(7) for a temporary de minimis exception for    a deduction for depletion. In the case of leased property, 
financial institutions for certain tax-exempt bonds issued in the depletion deduction is divided between the lessor and 
2009 and 2010.                                                the lessee.
Interest and carrying charges on straddles. Generally,      See sections 613 and 613A for percentage depletion 
these amounts must be capitalized. See section 263(g).        rates applicable to natural deposits. Also, see section 291 
Interest on debt allocable to the production of             for the limitation on the depletion deduction for iron ore 
designated property by a corporation for its own use or for   and coal (including lignite).
sale. The corporation must capitalize this interest. Also,    Attach Form T (Timber), Forest Activities Schedule, if a 
capitalize any interest on debt allocable to an asset used    deduction for depletion of timber is taken.
to produce the property. See section 263A(f) and              There are special rules for intangible drilling and 
Regulations sections 1.263A-8 through 1.263A-15 for           development costs incurred outside the United States. 
definitions and more information.                             See section 263(i).
Interest on unpaid taxes attributable to nondisclosed 
reportable transactions. See section 163(m).                  Line 24. Pension, profit-sharing, etc., plans.             Enter the 
  Limitation on deduction. Under section 163(j),              deduction for contributions to qualified pension, 
business interest expense is generally limited to the sum     profit-sharing, or other funded deferred compensation 
of business interest income, 30% of the adjusted taxable      plans.
income, and floor plan financing interest. The amount of 
any business interest expense that is not allowed as a        Note. Employers who maintain a plan are generally 
deduction for the tax year is carried forward to the          required to file Form 5500, Form 5500-SF, or Form 
following year. If section 163(j) applies, use Form 8990 to   5500-EZ. Go to www.EFAST.dol.gov and IRS.gov/
figure the amount of business interest expense the            Form5500EZ for more information.
corporation can deduct for the current tax year and the       Line 25. Employee benefit programs.      Enter 
amount that can be carried forward to the next year. See      contributions to employee benefit programs not claimed 
the Instructions for Form 8990. Also see Schedule I,          elsewhere on the return (for example, insurance, health 
Question 18, later.                                           and welfare programs, etc.) that are not an incidental part 
  Special rules apply to the following.                       of a pension, profit-sharing, etc., plan included on line 24.
Forgone interest on certain below-market-rate loans         Line 29. Dividends to policyholders.     Enter the total 
(see section 7872).                                           dividends and similar distributions paid or declared to 
Original issue discount (OID) on certain high-yield         policyholders, as policyholders, except in the case of a 
discount obligations. See section 163(e)(5) to determine      mutual fire insurance company exclusively issuing 
the disqualified amount of the deduction for OID that is      perpetual policies. Whether dividends have been paid or 
deferred and the amount that is disallowed on a high-yield    declared should be determined according to the method 
discount obligation. The rules under section 163(e)(5) do     of accounting employed by the insurance company.
not apply to certain high-yield discount obligations issued 
before January 1, 2011. See section 163(e)(5)(F), and         Dividends and similar distributions.     Include amounts 
Notice 2010-11, 2010-4 I.R.B. 326.                            returned or credited to policyholders on cancellation or 
Interest which is allocable to unborrowed policy cash       expiration of policies issued by a mutual fire or flood 
values of life insurance, endowment, or annuity contracts     insurance company:
issued after June 8, 1997. See section 264(f). Attach a       1. Where the premium deposits for the policy are the 
statement showing the computation of the deduction.           same (regardless of the length of the policy); and
Line 20b. Less tax-exempt interest expense.       Enter       2. The unabsorbed portion of the premium deposits 
interest paid or accrued during the tax year on               not required for losses, expenses, or establishment of 
indebtedness incurred or continued to purchase or carry       reserves is returned or credited to the policyholder on 
obligations if the interest is wholly exempt from income      cancellation or expiration of the policy.
tax. See section 265.                                         In the case of a qualified group self-insurers fund, the 
Line 21. Charitable contributions.   Include charitable       fund's deduction for policyholder dividends is allowed no 
contributions, as provided in section 170. See section 170    earlier than the date the state regulatory authority 
and its regulations for limitations, carryover, exclusions,   determines the amount of the policyholder dividend that 
requirements, substantiation, and other rules.                may be paid. See section 6076 of the Technical and 
  For more information on charitable contributions,           Miscellaneous Revenue Act of 1988.
including substantiation and recordkeeping requirements,      Line 30. Mutual interinsurers or reciprocal underwrit-
see section 170 and the related regulations and Pub. 526.     ers—increase in subscriber accounts.       A mutual 

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insurance company that is an interinsurer or reciprocal       Lobbying expenses. However, see the exceptions 
underwriter may deduct the increase in savings credited       discussed later.
to subscriber accounts for the tax year.                      Amounts paid or incurred for any settlement, payout, or 
  Savings credited to subscriber accounts means the           attorney fees related to sexual harassment or sexual 
surplus credited to the individual accounts of subscribers    abuse, if such payments are subject to a nondisclosure 
before the 16th day of the 3rd month following the close of   agreement. See section 162(q).
the tax year. This is true only if the corporation would be   Travel, meals, and entertainment.    Subject to limitations 
required to pay this amount promptly to a subscriber if the   and restrictions discussed below, a corporation can 
subscriber ended the contract when the corporation's tax      deduct ordinary and necessary travel, meals, and 
year ends.                                                    non-entertainment expenses paid or incurred in its trade 
Line 31. Other deductions.     Attach a statement listing by  or business. Generally, entertainment expenses, 
type and amount all allowable deductions under sections       membership dues, and facilities used in connection with 
832(c)(1) and (10) (net of the annual statement change in     these activities cannot be deducted. In addition, no 
undiscounted unpaid loss adjustment expenses) that are        deduction is generally allowed for qualified transportation 
not deductible on lines 15 through 30.                        fringe benefits. Also, special rules apply to deductions for 
                                                              gifts, luxury water travel, and convention expenses. See 
  Examples of other deductions may include the 
                                                              section 274 and Pub. 463 for details.
following.
                                                                Travel.  The corporation cannot deduct travel expenses 
Any deduction under P.L. 115-97, section 13517(c)(3)
                                                              of any individual accompanying a corporate officer or 
(B)(i) (transitional relief for change in reserve).
                                                              employee, including a spouse or dependent of the officer 
Any energy efficient commercial buildings deduction for 
                                                              or employee, unless:
property placed in service during the tax year. Complete 
and attach Form 7205.                                         That individual is an employee of the corporation, and
Certain business startup and organizational costs           That individual’s travel is for a bona fide business 
                                                              purpose and would otherwise be deductible by that 
(discussed earlier under Limitations on Deductions).
                                                              individual.
Legal and professional fees.
Supplies used and consumed in the business.                   Meals.   Generally, the corporation can deduct only 50% 
Travel, meals, and entertainment expenses. Special          of the amount otherwise allowable for 
rules apply (discussed later).                                non-entertainment-related meal expenses paid or incurred 
Utilities.                                                  in its trade or business. Meals not separately stated from 
Ordinary losses from trade or business activities of a      entertainment are generally not deductible.
partnership from Schedule K-1 (Form 1065). Do not offset        In addition (subject to exceptions under section 274(k)
ordinary income against ordinary losses. Instead, include     (2)):
the income on line 13. Show the partnership's name,           Meals must not be lavish or extravagant, and
address, and EIN on a separate statement attached to this     An employee of the corporation must be present at the 
return. If the amount entered is from more than one           meal.
partnership, identify the amount from each partnership.         Membership dues.     The corporation can deduct 
Any extraterritorial income exclusion from Form 8873,       amounts paid or incurred for membership dues in civic or 
Extraterritorial Income Exclusion.                            public service organizations, professional organizations 
Dividends paid in cash on stock held by an employee         (such as bar and medical associations), business 
stock ownership plan (ESOP). However, a deduction may         leagues, trade associations, chambers of commerce, 
only be taken for the dividends above if, according to the    boards of trade, and real estate boards. However, no 
plan, the dividends are:                                      deduction is allowed if a principal purpose of the 
  1. Paid in cash directly to the plan participants or        organization is to entertain or provide entertainment 
beneficiaries;                                                facilities for members or their guests. This includes 
                                                              country clubs, golf and athletic clubs, airline and hotel 
  2. Paid to the plan, which distributes them in cash to 
                                                              clubs, and clubs operated to provide meals under 
the plan participants or their beneficiaries no later than 90 
                                                              conditions favorable to business discussion.
days after the end of the plan year in which the dividends 
                                                                Qualified transportation fringes (QTFs).  Generally, 
are paid;
                                                              no deduction is allowed under section 274(a)(4) for QTFs 
  3. At the election of the participants or their             provided by employers to their employees. QTFs are 
beneficiaries (a) payable as provided under (1) or (2)        defined in section 132(f)(1) and include:
above, or (b) paid to the plan and reinvested in qualifying   Transportation in a commuter highway vehicle between 
employer securities; or                                       the employee’s residence and place of employment,
  4. Used to make payments on a loan described in             Any transit pass, and
section 404(a)(9).                                            Qualified parking.
  See section 404(k) for more details and the limitation        See section 274; Pub. 15-B, Employer’s Tax Guide to 
on certain dividends.                                         Fringe Benefits, for details.
  Do not deduct expenses such as the following.                 Entertainment facilities.  Generally, the corporation 
Amounts paid to, or at the direction of, a government or    cannot deduct an expense paid or incurred for a facility 
specified nongovernmental entity for the violation, or        (such as a yacht or hunting lodge) used for an activity 
investigation or inquiry, of a law. However, see the          usually considered entertainment, amusement, or 
exceptions discussed later.                                   recreation.

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  Amounts treated as compensation.        Generally, the        Line 36b. Net operating loss deduction. Section 172 
corporation may be able to deduct otherwise                     provides for an NOL deduction, limitation, carryovers, and 
nondeductible entertainment, amusement, or recreation           carrybacks. Attach a statement showing the computation 
expenses if the amounts are treated as compensation to          of the NOL deduction.
the recipient and reported on Form W-2 for an employee 
                                                                  The following special rules apply.
or on Form 1099-NEC for an independent contractor.
                                                                Section 382 provides a limitation on NOL carryforwards 
  However, if the recipient is an officer, director, beneficial and certain built-in losses following ownership change.
owner (directly or indirectly), or other “specified individual” If a corporation acquires control of another corporation 
(as defined in section 274(e)(2)(B) and Regulations             (or acquires its assets in a reorganization), the amount of 
section 1.274-9(b)), special rules apply.                       pre-acquisition losses that may offset recognized built-in 
Fines and penalties.  Generally, no deduction is allowed        gain may be limited (see section 384).
for fines or similar penalties paid or incurred to, or at the   If a corporation elects the alternative tax on qualifying 
direction of, a government or governmental entity for           shipping activities under section 1354, no deduction is 
violating any law, or for the investigation or inquiry into the allowed for an NOL attributable to the qualifying shipping 
potential violation of a law, except:                           activities to the extent that the loss is carried forward from 
Amounts that constitute restitution,                          a tax year preceding the first tax year for which the 
Amounts paid to come into compliance with the law,            alternative tax election was made. See section 1358(b)(2).
Amounts paid or incurred as the result of certain court       Section 831(b)(3) provides for a limitation on use of 
orders or agreements in which no government or                  NOLs.
governmental entity is a party, and                               For more details on the NOL deduction, see section 
Amounts paid or incurred for taxes due. No deduction is       172 and the Instructions for Form 1139, Corporation 
allowed unless the amounts are specifically identified in       Application for Tentative Refund.
the order or agreement and the corporation establishes 
                                                                Line 37. Taxable income. If line 37 (figured without 
that the amounts were paid for that purpose. Also, any 
                                                                regard to the items listed under Minimum taxable income 
amount paid or incurred as reimbursement to the 
                                                                below) is zero or less, the corporation may have an NOL 
government for the costs of any investigation or litigation 
                                                                that can be carried back or forward as a deduction to other 
are not eligible for the exceptions and are nondeductible. 
                                                                tax years.
See section 162(f).
                                                                Minimum taxable income.  The corporation's taxable 
Lobbying expenses.    Generally, lobbying expenses are 
                                                                income cannot be less than the largest of the following 
not deductible. These expenses include:
                                                                amounts.
Amounts paid or incurred in connection with influencing 
federal, state, or local legislation (but not amounts paid or   The inversion gain of the corporation for the tax year, if 
                                                                the corporation is an expatriated entity or a partner in an 
incurred before December 22, 2017, in connection with 
                                                                expatriated entity. See section 7874(a).
local legislation); or
Amounts paid or incurred in connection with any               The sum of the corporation's excess inclusions from its 
                                                                residual interest in a real estate mortgage investment 
communication with certain federal executive branch 
                                                                conduit (REMIC) from Schedules Q (Form 1066), line 2c, 
officials in an attempt to influence the official actions or 
                                                                and the corporation's taxable income determined solely 
positions of the officials. See Regulations section 1.162-
                                                                with respect to its ownership and high-yield interests in 
29 for the definition of “influencing legislation.”
                                                                financial asset securitization investment trusts (FASITs). 
  Dues and other similar amounts paid to certain tax-           See section 860E(a).
exempt organizations may not be deductible. If certain in-
house lobbying expenditures do not exceed $2,000, they          Net operating loss. Only certain losses can be carried 
are deductible.                                                 back. The carryback period for these losses is 2 years. 
                                                                For NOLs that can be carried back, the corporation can 
Line 32. Total deductions. Section 848 (capitalization of       elect to waive the carryback period and instead carry the 
certain policy acquisition expenses) requires insurance         NOL forward to future tax years.
companies to capitalize specified policy acquisition 
                                                                  See the Instructions for Form 1139. See the 
expenses and deduct them ratably over time. Attach a 
                                                                instructions for Schedule I, Item 10 for information on 
statement showing all computations. See section 848 and 
                                                                making the election to waive the entire carryback period.
its regulations.
                                                                  The NOL deduction for tax year 2023 generally cannot 
Line 34b. Deduction on account of the special in-               exceed the aggregate amount of NOLs arising in tax years 
come and deduction accounts.          Enter the total of the    beginning before January 1, 2018, carried to such year 
amounts required to be added under sections 832(e)(4)           plus the lesser of:
and (6). However, no deduction is permitted unless tax 
and loss bonds are purchased in an amount equal to the            1. The aggregate amount of NOLs arising in tax years 
tax benefit of the deduction. See section 832(e).               beginning after December 31, 2017, carried to such tax 
                                                                year; or
Note. The deduction on account of the special income              2. 80% of the excess, if any, of taxable income 
and deduction accounts is limited to taxable income for         determined without any NOL deduction, section 199A 
the tax year (computed without regard to this deduction or      deduction, or section 250 deduction, over any NOL 
to any carryback of a net operating loss (NOL)).                carryover to the tax year from tax years beginning before 
                                                                January 1, 2018.

Instructions for Form 1120-PC (2023)                                                                                      17



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An exception applies for NOLs of insurance companies         Deductions
other than life insurance companies. The 80% taxable 
income limit does not apply to these entities. See sections  Line 9. Real estate taxes. Enter taxes paid or accrued 
172(b) and (f).                                              on real estate owned by the corporation and deductible 
                                                             under section 164.
See the Instructions for Form 1139 for other special 
rules and elections.                                         Line 10. Other real estate expenses. Enter all ordinary 
                                                             and necessary real estate expenses, such as fire 
                                                             insurance, heat, light, and labor. Also, enter the cost of 
Schedule B, Part I—Taxable                                   incidental repairs, such as labor and supplies, that do not 
Investment Income of Electing Small                          add to the property's value or appreciably prolong its life. 
                                                             Do not include any amount paid for new buildings or for 
Companies                                                    permanent improvements or betterments made to 
                                                             increase the value of any property. Do not include any 
Note. (1) Once an election under section 831(b) is made 
                                                             amount spent on foreclosed property before the property 
to be taxed only on investment income, it can only be 
                                                             is held for rent.
revoked with the consent of the Secretary; and (2) a 
corporation making this election must include on             Line 11. Depreciation. Enter depreciation on assets 
Schedule B, line 8, any amount subtracted from a PAL         only to the extent that the assets are used to produce 
account.                                                     gross investment income reported on Schedule B, lines 1 
                                                             through 7. For more information, see the instructions for 
Income                                                       Schedule A, line 22.

Line 1a, column (a). Interest (including tax-exempt          Note. See section 834(d)(1) regarding the limitation of 
interest). Enter the gross amount of interest income,        expenses on real estate owned and occupied in part or in 
including all tax-exempt interest income.                    whole by a mutual insurance company.
Line 1b, column (a). Interest exempt under section           Line 12. Depletion. Enter any allowable depletion on 
103. Enter the amount of interest on state and local         royalty income reported on Schedule B, line 4. See the 
bonds that is exempt from taxation under section 103. See    instructions for Schedule A, line 23 for more information.
the instructions for Schedule A, line 3b, column (a), for 
more information.                                            Line 13. Trade or business deductions. Enter the total 
                                                             deductions related to any trade or business income 
Lines 1a and 1b, column (b). Amortization of premi-          included in gross investment income under section 834(b)
um.  Enter on line 1a, column (b), the total amortization of (2). Do not include deductions for any insurance business. 
bond premium, including amortization on tax-exempt           Do not include losses from sales or exchanges of capital 
bonds.                                                       assets or property used in the business, or from the 
Enter on line 1b, column (b), the amortization of bond       compulsory or involuntary conversion of property used in 
premium on tax-exempt bonds.                                 the trade or business.
Note. Insurance companies electing to amortize discount      Line 14. Interest. See the instructions for Schedule A, 
for tax purposes must reduce the amortization of premium     lines 20a and 20b.
by any amortization of discount.                             Line 17. Investment expenses. Enter expenses that are 
Line 3. Rents.  Enter the gross rents received or accrued    properly chargeable as investment expenses. If general 
during the tax year. Deduct rental expenses such as          expenses are allocated to investment expenses, the total 
repairs, interest, taxes, and depreciation on the proper     deduction cannot be more than the amount on 
lines in the Deductions section.                             Schedule B, Part II, line 39. Attach a statement showing 
                                                             the kind and amount of general expenses. Minor items 
Line 5. Gross income from a trade or business, other         may be grouped together.
than an insurance business, and from Form 4797. 
Enter the gross income from a trade or business, other       See section 267 for the limitation on deductions for 
than an insurance business, carried on by the insurance      unpaid expenses and interest in transactions between 
company or by a partnership of which the insurance           related taxpayers.
company is a partner. Include section 1245 and section 
1250 gains (as modified by section 291) and other gains      Schedule B, Part II—Invested Assets 
from Form 4797, on investment assets only.
                                                             Book Values
Line 6. Income from leases described in sections             Use Schedule B, Part II, to compute the limitation on 
834(b)(1)(B) and 834(b)(1)(C).   Enter gross income          investment expenses under section 834(c)(2) when any 
from entering into, changing, or ending any lease,           general expenses are in part assigned to, or included in, 
mortgage, or other instrument or agreement from which        the investment expenses deducted on Schedule B, Part I, 
the company earns interest, rents, or royalties.             line 17.
Line 8. Gross investment income. If gross investment 
income includes an amount subtracted from the PAL 
account, enter on the dotted line next to line 8, “PAL” and 
the amount.

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                                                             subject to income tax and that are subject to the 65% 
Schedule C—Dividends, Inclusions,                            deduction under section 243(c), and
                                                             Taxable distributions from an interest charge domestic 
Dividends-Received Deduction, and                            international sales corporation (IC-DISC) or former 
Other Special Deductions                                     domestic international sales corporation (DISC) that are 
                                                             considered eligible for the 65% deduction.
Definitions                                                  Line 3. Enter the following.
Prorated amounts. Prorated amounts mean tax-exempt           Dividends received on certain debt-financed stock 
interest and dividends for which a deduction is allowable    acquired after July 18, 1984, from domestic and foreign 
under section 243, 244 (as affected by P.L. 113-295, Div.    corporations subject to income tax that would otherwise 
A, section 221(a)(41)(A), December 19, 2014, 128 Stat.       be subject to the dividends-received deduction under 
4043), or 245 (other than 100% dividends).                   section 243(a)(1), 243(c), or 245(a). Generally, 
                                                             debt-financed stock is stock that the corporation acquired 
100% dividend. 100% dividend means any dividend if 
                                                             by incurring a debt (for example, it borrowed money to buy 
the percentage used for purposes of determining the 
                                                             the stock).
deduction allowable under section 243, 244 (as affected 
by P.L. 113-295, Div. A, section 221(a)(41)(A), December     Dividends received from a regulated investment 
                                                             company (RIC) on certain debt-financed stock. The 
19, 2014, 128 Stat. 4043), or 245(b) is 100%. See section 
                                                             amount of dividends eligible for the dividends-received 
243, section 244 as affected by P.L. 113-295, and section 
                                                             deduction is limited by section 854(b). The corporation 
245.
                                                             should receive a notice from the RIC specifying the 
                                                             amount of dividends that qualify for the deduction.
Lines 1 Through 25
                                                             Line 4. Enter dividends received on preferred stock of a 
For purposes of the 20% ownership test on lines 1 through    less-than-20%-owned public utility that is subject to 
7, the percentage of stock owned by the corporation is       income tax and is allowed the deduction provided in 
based on voting power and value of the stock. Preferred      section 247 (as affected by P.L. 113-295, Div. A, section 
stock described in section 1504(a)(4) is not taken into      221(a)(41)(A), December 19, 2014, 128 Stat. 4043) for 
account.                                                     dividends paid.
Consolidated returns.    Corporations filing consolidated    Line 5. Enter dividends received on preferred stock of a 
returns should see Regulations sections 1.1502-13,           20%-or-more-owned public utility that is subject to income 
1.1502-26, and 1.1502-27 before completing Schedule C.       tax and is allowed the deduction provided in section 247 
                                                             (as affected by P.L. 113-295, Div. A, section 221(a)(41)(A), 
Lines 1 through 9, column (a). Enter in column (a) of        December 19, 2014, 128 Stat. 4043) for dividends paid.
the appropriate line those dividends that are subject to the 
provisions of section 832(b)(5)(B).This will include:        Line 6. Enter the U.S.-source portion of dividends that:
                                                             Are received from less-than-20%-owned foreign 
  1. All dividends (other than 100% dividends) received      corporations, and
on stock acquired after August 7, 1986; and                    Qualify for the 50% deduction under section 245(a). To 
                                                             
  2. 100% dividends received on stock acquired after         qualify for the 50% deduction, the corporation must own at 
August 7, 1986, to the extent that such dividends are        least 10% of the stock of the foreign corporation by vote 
attributable to prorated amounts (see definition earlier).   and value.
  In the case of an insurance company that files a             Also, include dividends received from a 
consolidated return, the determination with respect to any   less-than-20%-owned foreign sales corporation (FSC) 
dividend paid by a member to another member of the           that:
affiliated group is made as if no consolidated return was    Are attributable to income treated as effectively 
filed. See section 832(g).                                   connected with the conduct of a trade or business within 
                                                             the United States (excluding foreign trade income), and
Line 1. Enter dividends (except those received on certain      Qualify for the 50% deduction under section 245(c)(1)
                                                             
debt-financed stock acquired after July 18, 1984 (see        (B).
section 246A)) that are:
Received from less-than-20%-owned domestic                 Line 7. Enter the U.S.-source portion of dividends that:
corporations subject to income tax, and                      Are received from 20%-or-more-owned foreign 
Qualified for the 50% deduction under section 243(a)       corporations, and
(1).                                                         Qualify for the 65% deduction under sections 245(a) 
  See section 246 and section 854 for limitations and        and 242 by reference.
exclusions.                                                    Also, include dividends received from a 
  Report so-called dividends or earnings received from       20%-or-more-owned FSC that:
mutual savings banks, etc., as interest. Do not treat them   Are attributable to income treated as effectively 
as dividends.                                                connected with the conduct of a trade or business within 
                                                             the United States (excluding foreign trade income), and
Line 2. Enter on line 2:                                     Qualify for the 65% deduction provided in section 
Dividends (except those received on certain                245(c)(1)(B).
debt-financed stock acquired after July 18, 1984) that are 
received from 20%-or-more-owned domestic corporations 

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Line 8. Enter dividends received from wholly owned             should equal the sum of the amounts reported by the U.S. 
foreign subsidiaries that are eligible for the 100%            shareholder on Form(s) 5471, Schedule I, line 1b.
deduction under section 245(b).                                Line 12c, column (b). Enter all other amounts included 
  In general, the deduction under section 245(b) applies       in income under section 951, other than amounts on 
to dividends paid out of the earnings and profits of a         line 15. This should equal the sum of the amounts 
foreign corporation for a tax year during which:               reported by the U.S. shareholder on Form(s) 5471, 
All of its outstanding stock is directly or indirectly owned Schedule I, lines 1c–1h, 2, and 4.
by the domestic corporation receiving the dividends, and       Line 13, column (b). Enter amounts included in income 
All of its gross income from all sources is effectively      under the section 951. See Form 8992, Part II, line 5; and 
connected with the conduct of a trade or business within       the Instructions for Form 8992. If you also have a Form 
the United States.                                             5471 reporting requirement, attach Form 5471.
  Also, include on line 8 dividends from FSCs that are 
                                                               Line 15, column (b). Reserved for future use.
attributable to foreign trade income and that are eligible for 
the 100% deduction provided in section 245(c)(1)(A).           Line 16, column (b). Include the following.
Line 9. Enter only those dividends that qualify under          1. Dividends (other than capital gain distributions 
section 243(b) for the 100% dividends-received deduction       reported on Schedule D (Form 1120) and exempt-interest 
described in section 243(a)(3).                                dividends) that are received from RICs and that are not 
                                                               subject to the 50% deduction.
  The 100% deduction does not apply to affiliated group 
members that are joining in the filing of a consolidated       2. Dividends from tax-exempt organizations.
return.                                                        3. Dividends (other than capital gain distributions) 
Line 10, column (b).  Enter the foreign-source portion of      received from a real estate investment trust (REIT) that, 
dividends that:                                                for the tax year of the trust in which the dividends are paid, 
Are received from specified 10%-owned foreign                qualifies under sections 856 through 860.
corporations (as defined in section 245A(b)), including, for   4. Dividends not eligible for a dividends-received 
example, gain from the sale of stock of a foreign              deduction, which include the following.
corporation that is treated as a dividend under sections       a. Dividends received on any share of stock held for 
1248(a) and (j); and                                           less than 46 days during the 91-day period beginning 45 
Qualify for the 100% deduction under section 245A(a)         days before the ex-dividend date. When counting the 
(excluding any hybrid dividends; see the instructions for      number of days the corporation held the stock, you cannot 
line 11 below).                                                count certain days during which the corporation's risk of 
Line 11, column (b).  Enter the foreign dividends not          loss was diminished. See section 246(c)(4) and 
reportable on line 3, 6, 7, 8, or 10 of column (b).            Regulations section 1.246-5 for more details.
  Include on line 11 the foreign-source portion of any         b. Dividends received on any share of preferred stock 
dividend that does not qualify for the section 245A            which are attributable to periods totaling more than 366 
deduction (for example, hybrid dividends within the            days, if such stock was held for less than 91 days during 
meaning of section 245A(e), ineligible amounts of              the 181-day period that began 90 days before the 
dividends within the meaning of Regulations section            ex-dividend date. When counting the number of days the 
1.245A-5(b), dividends that fail to meet the holding period    corporation held the stock, you cannot count certain days 
requirement under section 246(c)(5), etc.).                    during which the corporation's risk of loss was diminished. 
                                                               See section 246(c)(4) and Regulations section 1.246-5 for 
  Also, include on line 11 the corporation's share of 
                                                               more details. Preferred dividends attributable to periods 
distributions from a section 1291 fund from Form 8621, to 
                                                               totaling less than 367 days are subject to the 46-day 
the extent that the amounts are taxed as dividends under       holding period rule above.
section 301. See Form 8621 and its instructions.
                                                               c. Dividends on any share of stock to the extent the 
  Attach a statement identifying the amount of each 
                                                               corporation is under an obligation (including a short sale) 
dividend reported on line 11 and the provision pursuant to 
                                                               to make related payments with respect to positions in 
which a deduction is not allowed with respect to such 
                                                               substantially similar or related property.
dividend.
                                                               5. Any other taxable dividend income not properly 
Line 12a, column (b). Enter the foreign-source portion         reported elsewhere on Schedule C.
of any subpart F inclusions attributable to the sale or 
exchange by a CFC of stock in another foreign corporation      Line 20. Dividends received on certain debt-financed 
described in section 964(e)(4). This should equal the sum      stock acquired after July 18, 1984, are not entitled to the 
of the amounts reported by the U.S. shareholder on             full 50% or 65% dividends-received deduction. The 50% 
Form(s) 5471, Schedule I, line 1a. (Do not include on          or 65% deduction is reduced by a percentage that is 
line 12a any portion of such subpart F inclusion that is not   related to the amount of debt incurred to acquire the 
eligible for the section 245A deduction pursuant to            stock. See section 246A. Also, see section 245(a) before 
Regulations section 1.245A-5(g)(2). Include such               making this computation for an additional limitation that 
amounts on line 12c.)                                          applies to dividends received from foreign corporations. 
Line 12b, column (b). Enter the total subpart F                Attach a statement showing how the amount on line 20 
inclusions attributable to tiered hybrid dividends. This       was figured.

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            Worksheet for Schedule C, Line 26                                                Keep for Your Records
1. Refigure the amount from Schedule A, line 35, or Schedule B, line 19, whichever applies, without 
    any adjustment under section 1059, and without any capital loss carryback to the tax year under 
    section 1212(a)(1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
2. Enter the sum of the amounts from line 25, column (b) (without regard to wholly owned foreign 
    subsidiary dividends), and line 9, column (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                 
3. Subtract line 2 from line 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      
4. Multiply line 3 by 65% (0.65) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        
5. Add lines 19, 22, 24, and 25, column (b) (without regard to FSC dividends), and the portion of the 
    deduction on line 20, column (b), that is attributable to dividends received from 
    20%-or-more-owned corporations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                
6. Enter the smaller of line 4 or line 5. If line 5 is greater than line 4, stop here; enter the amount from 
    line 6 on line 26, column (b), and do not complete the rest of this worksheet . . . . . . . . . . . . . . . . . . .                                     
7. Enter the total amount of dividends received from 20%-or-more-owned corporations that are 
    included on lines 2, 3, 5, 7, and 8, column (b) (without regard to FSC dividends) . . . . . . . . . . . . . . .                                         
8. Subtract line 7 from line 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .      
9. Multiply line 8 by 50% (0.50) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        
10. Subtract line 5 from line 26, column (b) (without regard to FSC dividends) . . . . . . . . . . . . . . . . . . . . .                                    
11. Enter the smaller of line 9 or line 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .          
12. Dividends-received deduction after limitation (section 246(b)). Add lines 6 and 11. Enter the 
    result here and on line 26, column (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .              

Line 26, column (b). Generally, line 26, column (b),        and Blue Shield organizations described in section 833(c)
cannot exceed the amount from the Worksheet for             (2), and other organizations described in section 833(c)
Schedule C, Line 26, above. However, in a year in which     (3), to those with an MLR of 85% or more. Organizations 
an NOL occurs, this limitation does not apply even if the   with an MLR less than 85% are allowed to deduct only 
loss is created by the dividends-received deduction. See    80% of unearned premiums. See section 833(c)(5) and 
sections 172(d) and 246(b).                                 Regulations section 1.833-1.
Line 28, column (b). Enter the section 250 deduction        Line 1. Enter gross premiums written on insurance 
claimed for foreign-derived intangible income (FDII) and    contracts during the tax year, less return premiums and 
global intangible low-taxed income (GILTI). This should     premiums paid for reinsurance. See Regulations section 
equal the sum of Form 8993, Part III, lines 28 and 29.      1.832-4.
Line 29.  Reserved for future use.                          Lines 2a and 4a.          Include on lines 2a and 4a the 
                                                            following.
Schedule E—Premiums Earned                                  1. All life insurance reserves, as defined in section 
                                                            816(b) (but determined under section 807).
Definitions                                                 2. Generally, all section 833 organizations with an 
                                                            MLR of 85% or more (discussed earlier) are permitted to 
Undiscounted unearned premiums.      Undiscounted 
                                                            enter 100% of unearned premiums on lines 2a and 4a. 
unearned premiums means the unearned premiums 
                                                            Section 833 organizations with an MLR of less than 85% 
shown in the annual statement filed for the year ending 
                                                            must change to an 80% Unearned Premium Reserve. For 
with or within the tax year.
                                                            more information, see Change in accounting method, 
Applicable interest rate.   Applicable interest rate means  earlier.
the annual rate determined under section 846(c)(2) for the 
calendar year the premiums are received.                    Lines 2b and 4b.          Include on lines 2b and 4b 90% of 
                                                            unearned premiums for insurance against default in the 
Applicable statutory premium recognition pattern.           payment of principal or interest on securities described in 
Applicable statutory premium recognition pattern means      section 165(g)(2)(C) (relating to worthless securities) with 
the statutory premium recognition pattern in effect for the maturities of more than 5 years. See section 832(b)(7)(B).
calendar year the premiums are received, and is based on 
the statutory premium recognition pattern which applies to  Lines 2c and 4c.          The amount of discounted unearned 
premiums received by the corporation in that calendar       premiums at the end of any tax year must be the present 
year. For purposes of the preceding sentence, premiums      value of those premiums (as of such time and separately 
received during any calendar year will be treated as        with respect to premiums received in each calendar year) 
received in the middle of such year.                        determined by using:
Medical loss ratio (MLR).   Section 833(c)(5) limits the    1. The amount of the undiscounted unearned 
100% deduction of unearned premiums by Blue Cross           premiums at such time,

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2. The applicable interest rate, and                         annual statement (as defined by section 846(e)(3)) filed 
3. The applicable statutory premium recognition              for the calendar year ending with or within the tax year. 
pattern.                                                     See section 1.832-4(b) relating to the determination of 
                                                             unpaid losses.
Lines 2d and 4d. Include on lines 2d and 4d 80% of the       Section 832(b)(5)(A) provides rules for figuring losses 
total of all unearned premiums not reported on lines 2a      incurred. Section 832(b)(5)(B) provides rules for reducing 
through 2c, or 4a through 4c, respectively.                  the deduction figured in section 832(b)(5)(A).
A reciprocal or interinsurer required under state law to     Rev. Proc. 2023-41, 2023-52, I.R.B. 1607, available at 
reflect unearned premiums on its annual statement net of     IRS.gov/irb/2023-52_IRB#REV-PROC-2023-41, 
premium acquisition expenses should increase its             prescribes discount factors for the 2023 accident year for 
unearned premiums by the amount of such acquisition          use by insurance companies in computing discounted 
expenses prior to making the computation on lines 2d and     unpaid losses under section 846 and discounted 
4d. See section 832(b)(7)(E).                                estimated salvage recoverable under section 832. Rev. 
Line 6.  Transitional adjustments apply to companies         Proc. 2023-41 also provides, for convenience, discount 
which become taxable under section 831(a). See section       factors for losses incurred in earlier accident years for use 
832(b)(7)(D).                                                in tax years beginning in 2023. The discount factors set 
                                                             forth in Rev. Proc. 2023-41 are determined under section 
                                                             846 and Regulations section 1.846-1.
Schedule F—Losses Incurred
Line 1. Losses paid. Enter the total losses paid on          Note. P.L. 115-97, section 13523, modified discounting 
insurance contracts during the tax year less salvage and     rules for property and casualty insurance companies, 
reinsurance recovered during the tax year. Attach a          modified the rate of interest used to discount unpaid 
statement that reconciles the amount entered on line 1 to    losses, modified computational rules for loss payment 
the amount reported on the corporation's annual              patterns, and repealed the historical payment pattern 
statement.                                                   election. These amendments apply to tax years beginning 
                                                             after 2017. An 8-year transition rule also applies. See 
Lines 2a and 4a. Unpaid losses on life insurance con-        section 846 of the Internal Revenue Code, as modified by 
tracts. Unpaid losses must be adjusted for recoveries of     P.L. 115-97, section 13523.
reinsurance. The amounts of expected recoveries should 
be estimated based on the facts in each case and the         Note. There is a special application of the “fresh start” 
corporation's experience with similar cases. See             provision for an insurance company that is not subject to 
Regulations section 1.832-4(b).                              tax under section 831(a) for its first tax year beginning 
                                                             after December 31, 1986, because (1) it is described in 
Lines 2b and 4b. Discounted unpaid losses outstand-
                                                             section 501(c), or (2) it is subject to tax under section 
ing. Enter all discounted unpaid losses, as defined in 
                                                             831(b) on its investment income.
section 846.
                                                             If the insurance company later becomes subject to tax 
Section 846 provides that the amount of discounted 
                                                             under section 831(a), the rules relating to the fresh start 
unpaid losses must be figured separately by each line of 
                                                             under the discounting provisions are applied by treating 
business (multiple peril lines must be treated as a single 
                                                             the last tax year before the year in which the insurance 
line of business) and by each accident year and must be 
                                                             company becomes subject to tax under section 831(a) as 
equal to the present value of those losses determined by 
                                                             the insurance company's last tax year beginning before 
using the:
                                                             1987. See section 1010(e) of the Technical and 
1. Amount of the undiscounted unpaid losses,                 Miscellaneous Revenue Act of 1988 and Notice 88-100, 
2. Applicable interest rate, and                             1988-2 C.B. 439.
3. Applicable loss payment pattern.                          Lines 6 and 7. Estimated salvage and reinsurance re-
Section 846(e)(6) provides that any determination            coverable. Enter on lines 6 and 7 the amount of 
under section 846(a) (discounted losses determined) with     estimated salvage and reinsurance recoverable. See Rev. 
respect to unpaid losses relating to accident and health     Proc. 2023-41 for the latest information and guidance.
insurance lines of businesses (other than credit disability  Line 9. Tax-exempt interest subject to section 832(b)
insurance) must be made (a) in the case of unpaid losses     (5)(B). Enter the amount of tax-exempt interest received 
relating to disability income, by using the general rules    or accrued during the tax year on investments made after 
prescribed under section 807(d) applicable to                August 7, 1986. For information regarding the 
noncancelable accident and health insurance contracts        determination of the acquisition date of an investment, see 
and using a mortality or morbidity table reflecting the      the instructions for Schedule C.
taxpayer’s experience, except that the limitation of section 
                                                             Line 13. Reduction of deduction under section 832(b)
846(a)(3) (Limitation on amount of discounted losses) will 
                                                             (5)(B). Multiply line 12 by the applicable percentage, 
apply; and (b) in all other cases, by using an assumption 
                                                             which is 25% (5.25% divided by the highest corporate tax 
(in lieu of a loss payment pattern) that unpaid losses are 
                                                             rate).
paid in the middle of the year following the accident year.
A separate series of discount factors are computed for, 
and applied to, undiscounted unpaid losses attributable to 
each accident year of each line of business shown on the 

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                                                            Note. Any determination under section 833(b) must be 
Schedule G—Other Capital Losses                             made by only taking into account items from the 
Capital assets are considered sold or exchanged to          health-related business of the corporation.
provide funds to meet abnormal insurance losses and to      Line 8a. Adjusted tax-exempt income.   Reduce the 
pay dividends and make similar distributions to             total tax-exempt interest received or accrued during the 
policyholders to the extent that the gross receipts from    tax year by any amount (not otherwise deductible) which 
their sale or exchange are not more than the amount by      would have been allowable as a deduction for the tax year 
which the sum of dividends and similar distributions paid   if such interest were not tax exempt. Enter the result on 
to policyholders, losses paid, and expenses paid for the    line 8a.
tax year is more than the total on Schedule G, line 9.
                                                            Line 8b. Adjusted dividends-received deduction. 
Total gross receipts from sales of capital assets           Reduce the total amount allowed as a deduction under 
(line 12, column (c)) must not be more than line 10. If     sections 243, 244 (as affected by P.L. 113-295, Div. A, 
necessary, the corporation may report part of the gross     section 221(a)(41)(A), December 19, 2014, 128 Stat. 
receipts from a particular sale of a capital asset on this  4043), and 245 by the amount of any decrease in 
schedule and the rest on Schedule D (Form 1120).            deductions allowable for the tax year because of section 
Otherwise, do not include on Schedule D (Form 1120) any     832(b)(5)(B) when the decrease is caused by the 
sales reported on this schedule.                            deductions under sections 243, 244 (as affected by P.L. 
                                                            113-295, Div. A, section 221(a)(41)(A), December 19, 
Schedule H—Special Deduction and                            2014, 128 Stat. 4043), and 245. Enter the result on 
                                                            line 8b.
Ending Adjusted Surplus for Section 
833 Organizations                                           Schedule I—Other Information
Section 833(c)(5) provides that section 833(a)(2) and       Complete all items that apply to the corporation.
section 833(a)(3) do not apply to any organization with an 
MLR of less than 85%. See section 833(c)(5). Also, see      Question 4
Medical loss ratio, earlier.                                Check the “Yes” box if:
Line 5. Beginning adjusted surplus.     If the corporation  The corporation is a subsidiary in an affiliated group 
was a section 833 organization in 2022, it should enter the (defined later), but is not filing a consolidated return for the 
amount from its 2022 Form 1120-PC, Schedule H, line 10.     tax year with that group; or
                                                            The corporation is a subsidiary in a parent-subsidiary 
Generally, the adjusted surplus as of the beginning of      controlled group. For a definition of parent-subsidiary 
any tax year is an amount equal to the adjusted surplus as  controlled group, see the Instructions for Schedule O 
of the beginning of the preceding tax year:                 (Form 1120).
1. Increased by the amount of any adjusted taxable 
income for the preceding tax year, or                         Any corporation that meets either of the requirements 
2. Decreased by the amount of any adjusted NOL for          above should check the “Yes” box. This applies even if the 
the preceding tax year.                                     corporation is a subsidiary member of one group and the 
                                                            parent corporation of another.
If 2023 is the first tax year the taxpayer qualifies as a 
section 833 organization, see section 833(c)(3)(C) to       Note. If the corporation is an “excluded member” of a 
determine the adjusted surplus as of the beginning of the   controlled group (see the definition in the Instructions for 
2023 tax year.                                              Schedule O (Form 1120)), it is still considered a member 
For purposes of the computation of the adjusted             of a controlled group for this purpose.
surplus, the terms “adjusted taxable income” and            Affiliated group. An affiliated group is one or more 
“adjusted net operating loss” mean the taxable income or    chains of includible corporations (as defined in section 
the NOL, respectively, determined with the following        1504(b)) connected through stock ownership with a 
modifications.                                              common parent corporation. See section 1504(a). The 
1. Without regard to the deduction determined under         common parent must be an includible corporation and the 
section 833(b)(1).                                          following requirements must be met.
2. Without regard to any carryover or carryback to that       1. The common parent must own directly stock that 
tax year.                                                   represents at least 80% of the total voting power and at 
3. By increasing gross income by an amount equal to         least 80% of the total value of the stock of at least one of 
the net exempt income for the tax year.                     the other includible corporations.
                                                              2. Stock that represents at least 80% of the total voting 
Line 6. Special deduction.   The special deduction under    power and at least 80% of the total value of the stock of 
section 833(b) cannot be taken if the MLR is less than      each of the other corporations (except for the common 
85%. If the MLR is less than 85%, enter zero on line 6 and  parent) must be owned directly by one or more of the 
Schedule A, line 34a.                                       other includible corporations.
Note. The deduction for any tax year is limited to taxable    For this purpose, the term “stock” generally does not 
income for that tax year determined without regard to this  include any stock that (a) is nonvoting, (b) is 
deduction.                                                  nonconvertible, (c) is limited and preferred as to dividends 

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and does not participate significantly in corporate growth,    tax years. To do so, check the box on line 10 and file the 
and (d) has redemption and liquidation rights that do not      tax return by its due date, including extensions. Do not 
exceed the issue price of the stock (except for a              attach the statement described in Temporary Regulations 
reasonable redemption or liquidation premium).                 section 301.9100-12T. Generally, once made, the election 
                                                               is irrevocable.
Question 6
                                                                 If the corporation timely filed its return for the loss year 
Check the “Yes” box if one foreign person owned at least       without making the election, it can make the election on an 
25% of the total voting power of all classes of stock of the   amended return filed within 6 months of the due date of 
corporation entitled to vote, or at least 25% of the total     the loss year return (excluding extensions). Attach the 
value of all classes of stock of the corporation.              election to the amended return and enter "Filed pursuant 
  The constructive ownership rules of section 318 apply        to section 301.9100-2" on the election statement. See the 
in determining if a corporation is foreign owned. See          Instructions for Form 1139.
section 6038A(c)(5) and the related regulations.                 Corporations filing a consolidated return that elect to 
  Enter on line 6a the percentage owned by the foreign         waive the entire carryback period for the group must also 
person specified in question 6. On line 6b, enter the name     attach the statement required by Regulations section 
of the owner's country.                                        1.1502-21(b)(3) or the election will not be valid.

Note. If there is more than one 25%-or-more foreign            Item 11
owner, complete lines 6a and 6b for the foreign person         Enter the amount of the NOL carryover to this tax year 
with the highest percentage of ownership.                      from prior years, even if some of the loss is used to offset 
                                                               income on this return. The amount to enter is the total of 
Foreign person. The term “foreign person” means:               all NOLs generated in prior years but not used to offset 
An individual who is not a citizen or resident of the        income (either as a carryback or carryover) in a tax year 
United States;                                                 prior to 2023. Do not reduce the amount by any NOL 
An individual who is a citizen or resident of a U.S.         deduction reported on Schedule A, line 36b.
territory who is not otherwise a citizen or resident of the 
United States;                                                 Question 12
Any partnership, association, company, or corporation        Schedule UTP (Form 1120) asks for information about tax 
that is not created or organized in the United States;         positions that affect the U.S. federal income tax liabilities 
Any foreign estate or trust within the meaning of section    of certain corporations that issue or are included in 
7701(a)(31); or                                                audited financial statements and have assets that equal or 
A foreign government (or one of its agencies or              exceed $10 million. For details, see the Instructions for 
instrumentalities) to the extent that it is engaged in the     Schedule UTP.
conduct of a commercial activity, as described in section 
892.                                                             Attach Schedule UTP to the corporation's income tax 
  However, the term “foreign person” does not include          return. Do not file it separately. A taxpayer that files a 
any foreign person who consents to the filing of a joint       protective Form 1120-PC must also file Schedule UTP if it 
income tax return.                                             satisfies the requirements set forth above.

Owner's country.   For individuals, the term “owner's          Question 13
country” means the country of residence. For all others, it    Section 833(c)(5) provides that section 833(a)(2) and 
is the country where incorporated, organized, created, or      section 833(a)(3) do not apply to a Blue Cross or Blue 
administered.                                                  Shield organization described in section 833(c)(2), or 
Requirement to file Form 5472. If the corporation              other organization described in section 833(c)(3), unless it 
checked “Yes,” it may have to file Form 5472. Generally, a     has an MLR of 85% or more for the tax year.
25% foreign-owned corporation that had a reportable              For purposes of section 833(c)(5), the MLR is equal to 
transaction with a foreign or domestic related party during    the amount expended on reimbursement for clinical 
the tax year must file Form 5472. See the Instructions for     services provided to enrollees (as defined in 45 C.F.R. 
Form 5472 for filing instructions and penalties for failure to 158.140) and for activities that improve health care quality 
file.                                                          (as defined in 45 C.F.R. 158.150) under its policies during 
                                                               the tax year (section 833(c)(5) MLR numerator) divided by 
Item 9                                                         the total premium revenue (section 833(c)(5) MLR 
Show any tax-exempt interest received or accrued.              denominator). See section 833(c)(5) and Regulations 
Include any exempt-interest dividends received as a            section 1.833-1. Also, see Medical loss ratio, earlier.
shareholder in a mutual fund or other RIC. Also, if 
required, include the same amount on Schedule M-1,               Check the “Yes” box if the corporation is a Blue Cross 
line 7 (or Schedule M-3 (Form 1120-PC), Part II, line 13, if   or Blue Shield organization described in section 833(c)(2), 
applicable).                                                   or other organization described in section 833(c)(3), that 
                                                               has satisfied the MLR requirements of section 833(c)(5).
Item 10                                                          If you checked “Yes,” you must enter:
Generally, if the corporation has an NOL for tax year 2023,    The section 833(c)(5) MLR numerator on line 13(a),
it can generally elect to waive the entire carryback period    The section 833(c)(5) MLR denominator on line 13(b), 
for the NOL and instead carry the NOL forward to future        and

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The section 833(c)(5) percentage on line 13(c).             Question 16
  If you checked “No,” enter zero on Schedule H, line 6,      If the corporation paid or accrued any interest or royalty for 
and Schedule A, line 34a. You cannot take the special         which a deduction is not allowed under section 267A, 
deduction. See the instructions for Schedule H.               check "Yes" and enter the total amount of interest and 
                                                              royalty paid or accrued by the corporation (including the 
  Also, if you checked “No,” your deduction of unearned       corporation's allocable share through a partnership) for 
premiums is limited. See the instructions for Schedule E      which a deduction is not allowed.
for more information.
                                                              Payments to which section 267A applies.   Interest or 
Question 14                                                   royalty paid or accrued by a domestic corporation 
Only a corporation that qualifies as a small company          (including, in the case of a domestic corporation that is a 
under section 831(b)(2) is eligible to elect to be taxed on   partner in a partnership, the domestic corporation's 
taxable investment income under section 831(b) in lieu of     allocable share of interest or royalty paid or accrued by the 
the tax otherwise applicable under section 831(a). See        partnership) is subject to section 267A. Section 267A 
section 831(b)(2)(A)(iii). Section 831(b)(2)(A)(ii) provides  generally applies to interest or royalty paid or accrued 
that a corporation must meet the diversification              according to a hybrid arrangement (such as, for example, 
requirements in section 831(b)(2)(B) to qualify as a small    a payment according to a hybrid instrument, or a payment 
company. A corporation meets the diversification              to a reverse hybrid), provided that the payment or accrual 
requirements if under section 831(b)(2)(B)(i)(I) no more      is to a related party (or according to a structured 
than 20% of the net written premiums (or, if greater, direct  arrangement). In addition, under an imported mismatch 
written premiums) of such corporation for the tax year is     rule, section 267A generally applies to interest or royalties 
attributable to any one policyholder. However, a              paid or accrued according to a non-hybrid arrangement 
corporation that does not meet this 20% test can meet the     where the income attributable to that payment or accrual 
diversification requirement under section 831(b)(2)(B) if     is directly or indirectly offset by certain deductions 
no person who holds (directly or indirectly) an interest in   involving hybridity incurred by a related party or according 
such insurance company is a specified holder who holds        to a structured arrangement. However, section 267A does 
(directly or indirectly) aggregate interest in such insurance not apply if a de minimis exception is satisfied. See 
company which constitutes a percentage of the entire          Regulations section 1.267A-1(c). For purposes of section 
interests in such insurance company which is more than        267A, interest and royalties are defined broadly. For 
2% higher than the percentage of interests in the specified   additional information about arrangements subject to 
assets with respect to such insurance company held            section 267A, see Regulations sections 1.267A-2 and 
(directly or indirectly) by such specified holder under       1.267A-4. Also, see the anti-avoidance rule under 
section 831(b)(2)(B)(i)(II).                                  Regulations section 1.267A-5(b)(6).
                                                              Extent to which deduction is disallowed.  When 
  A corporation making an election under section 831(b)       section 267A applies to interest or royalties paid or 
(2)(A)(iii) must complete question 14 to indicate whether it  accrued pursuant to a hybrid arrangement, it generally 
qualifies as a small company, and, therefore, is eligible to  disallows a deduction for the amount to the extent that, 
make the election to be taxed on taxable investment           under the foreign tax law, there is not a corresponding 
income because it meets the diversification requirements      income inclusion (including long-term deferral). However, 
of the 20% test in section 831(b)(2)(B)(i)(I). If the         the deduction is not disallowed to the extent the amount is 
corporation answers “No” for question 14(a), then the         directly or indirectly included in income in the United 
corporation must satisfy the specified holder/specified       States, such as if the amount is taken into account with 
asset test in section 831(b)(2)(B)(i)(II) to qualify to make  respect to a U.S. shareholder under section 951(a) or 
the section 831(b)(2)(A)(iii) election to be taxed on taxable section 951A. For additional information, see Regulations 
investment income. If the corporation satisfies the           sections 1.267A-2 through 1.267A-4. For examples 
specified holder/specified asset test in section 831(b)(2)    illustrating the application of section 267A, see 
(B)(i)(II), the corporation should answer “Yes” for question  Regulations section 1.267A-6.
14(b). If the corporation does not satisfy either the 
diversification requirements of section 831(b)(2)(B)(i)(I) or Question 17
section 831(b)(2)(B)(i)(II) for the tax year (answering “No” 
                                                              Check “Yes” if the corporation has an election in effect to 
for both questions), the corporation is not a small 
                                                              exclude a real property trade or business or a farming 
company and, therefore, is not eligible to be taxed on 
                                                              business from section 163(j). For more information, see 
taxable investment income under section 831(b) in lieu of 
                                                              section 163(j) and the Instructions for Form 8990.
the tax otherwise applicable under section 831(a).
                                                              Question 18
Question 15
                                                              Generally, a taxpayer with a trade or business must file 
If the corporation had gross receipts of at least $500 
                                                              Form 8990 to claim a deduction for business interest. In 
million in any 1 of the 3 preceding tax years, complete 
                                                              addition, Form 8990 must be filed by any taxpayer that 
Form 8991 and attach it to this return. For this purpose, 
                                                              owns an interest in a partnership with current-year, or 
the corporation's gross receipts include the gross receipts 
                                                              prior-year carryover, excess business interest expense 
of all persons aggregated with the corporation, as 
                                                              allocated from the partnership.
specified in section 59A(e)(3). See the Instructions for 
Form 8991 to determine if the corporation is subject to the   Exclusions from filing.  A taxpayer is not required to file 
base erosion minimum tax.                                     Form 8990 if the taxpayer is a small business taxpayer 

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(defined below) and does not have excess business            Line 5. Tax-exempt securities.  Include on this line:
interest expense from a partnership. A taxpayer is also not  State and local government obligations, the interest on 
required to file Form 8990 if the taxpayer only has          which is excludable from gross income under section 
business interest expense from the following excepted        103(a); and
trades or businesses.                                        Stock in a mutual fund or other RIC that distributed 
An electing real property trade or business.               exempt-interest dividends during the tax year of the 
An electing farming business.                              corporation.
Certain utility businesses.
                                                             Line 18. Insurance liabilities. Include on this line:
Small business taxpayer.     A small business taxpayer is    Undiscounted unpaid losses,
not subject to the business interest expense limitation and  Loss adjustment expenses, and
is not required to file Form 8990. A small business          Unearned premiums.
taxpayer is a taxpayer that (a) is not a tax shelter (as 
                                                               See section 846 for more information.
defined in section 448(d)(3)); and (b) meets the gross 
receipts test of section 448(c), discussed next.             Line 27. Adjustments to shareholders' equity.               Some 
                                                             examples of adjustments to report on this line include:
Gross receipts test.  For tax years beginning in 2023, a 
taxpayer meets the gross receipts test if the taxpayer has   Unrealized gains and losses on securities held 
                                                             “available for sale,”
average annual gross receipts of $29 million or less for the 
3 prior tax years. See section 448(c) and the Instructions   Foreign currency translation adjustments,
for Form 8990 for additional information.                    The excess of additional pension liability over 
                                                             unrecognized prior service cost,
Question 19                                                  Guarantees of ESOP debt, and
If the corporation is a member of a controlled group, check  Compensation related to employee stock award plans.
the “Yes” box. Complete and attach Schedule O (Form            If the total adjustment to be entered on line 27 is a 
1120), Consent Plan and Apportionment Schedule for a         negative amount, enter the amount in parentheses.
Controlled Group. Component members of a controlled 
group must use Schedule O to report the apportionment        Schedule M-1— Reconciliation of 
of certain tax benefits between the members of the group. 
See Schedule O and the Instructions for Schedule O for       Income (Loss) per Books With 
more information.                                            Income (Loss) per Return
                                                             In completing Schedule M-1, the following apply.
Question 20
Check the appropriate boxes to indicate if the corporation   All insurance companies required to file Form 1120-PC 
is required to file Form 4626. If the corporation does not   with total assets (nonconsolidated or consolidated for all 
meet the requirements of the safe harbor method, as          corporations included within the tax consolidation group) 
provided under section 59(k)(3)(A) and Notice 2023-7,        of $10 million or more on the last day of the tax year must 
2023-3 I.R.B. 390, available at IRS.gov/irb/                 file Schedule M-3 (Form 1120-PC) instead of 
2023-03_IRB#NOT-2023-7, complete and attach Form             Schedule M-1. See Schedule M-3 (Form 1120-PC), 
4626 to the corporation's return. See the Instructions for   earlier.
Form 4626.                                                   A corporation filing Form 1120-PC that is not required to 
                                                             file Schedule M-3 (Form 1120-PC) may voluntarily file 
                                                             Schedule M-3 (Form 1120-PC) instead of Schedule M-1. 
Schedule L—Balance Sheets per                                See the Instructions for Schedule M-3 (Form 1120-PC) for 
Books                                                        more information.
                                                             Line 5c. Travel and entertainment.    Include on line 5c 
Note. All insurance companies required to file Form 
                                                             any of the following.
1120-PC must complete Schedule L.
                                                             Entertainment expenses not deductible under section 
  The balance sheets should agree with the corporation's     274(a).
books and records.                                             Meal expenses not deductible under section 274(n).
                                                             
  If filing a consolidated return, report total consolidated Expenses for the use of an entertainment facility.
assets, liabilities, and shareholders’ equity for all        The part of business gifts over $25.
corporations joining in the return. See Consolidated         Expenses of an individual over $2,000, allocable to 
returns, earlier.                                            conventions on cruise ships.
                                                             Employee achievement awards of nontangible or 
  Corporations with total assets (nonconsolidated or         tangible property over $400 ($1,600 if part of a qualified 
consolidated for all corporations included within the tax    plan).
consolidation group) of $10 million or more on the last day  The cost of skyboxes.
of the tax year must file Schedule M-3 (Form 1120-PC)        Nondeductible club dues.
instead of Schedule M-1. See the separate Instructions for   The part of luxury water travel expenses not deductible 
Schedule M-3 (Form 1120-PC) for provisions that also         under section 274(m).
affect Schedule L.                                           Expenses for travel as a form of education.
                                                             Other nondeductible travel and entertainment 
Line 1. Cash. Include certificates of deposit as cash on 
                                                             expenses.
this line.

26                                                                                Instructions for Form 1120-PC (2023)



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Line 7a. Tax-exempt interest.    Report any tax-exempt     The time needed to complete and file this form will vary 
interest received or accrued, including any                depending on individual circumstances. The estimated 
exempt-interest dividends received as a shareholder in a   burden for business taxpayers filing this form is approved 
mutual fund or other RIC. Also, report this same amount    under OMB control number 1545-0123 and is included in 
on Schedule I, item 10.                                    the estimates shown in the instructions for their business 
                                                           income tax return.
Paperwork Reduction Act Notice.      We ask for the        If you have comments or suggestions for making this 
information on these forms to carry out the Internal       form and related schedules simpler, we would be happy to 
Revenue laws of the United States. You are required to     hear from you. You can send us comments through 
give us the information. We need it to ensure that you are IRS.gov/FormComments. Or you can write to:
complying with these laws and to allow us to figure and 
collect the right amount of tax.                           Internal Revenue Service
You are not required to provide the information            Tax Forms and Publications
requested on a form that is subject to the Paperwork       1111 Constitution Ave. NW, IR-6526
Reduction Act unless the form displays a valid OMB         Washington, DC 20224
control number. Books or records relating to a form or its 
instructions must be retained as long as their contents    Do not send the tax form to this address. Instead, see 
may become material in the administration of any Internal  Where To File, earlier.
Revenue law. Generally, tax returns and return information 
are confidential, as required by section 6103.

Instructions for Form 1120-PC (2023)                                                                                     27



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Index
 
                                       Estimated tax:                        Pension, profit-sharing, etc. plans            15
A                                        Payments   4                        Period covered 6
Accounting methods     5                 Penalty 5 10,                       Personal holding company tax                  9
Accounting methods, change in     5    Extension of time to file   3         Private delivery services 3
Accounting period (tax year)  6
Address change    8                    F                                     R
Adjustments to shareholders'           Final return 8                        Recordkeeping  6
  equity 26                            Foreign corporations     9            Related party transactions                  12
Affiliated group  23                   Foreign person  24
Amended return    8                    Foreign tax credit 9                  S
Amortization 12                        Form 3800 10                          Schedule:
Assembling the return   4              Forms and publications, how to get  2  A 10
                                                                              B, Part I 18
B                                      G                                      B, Part II 18
Backup withholding   10                General business credit     9          C 19
Base erosion minimum tax   9           Golden parachute payments       12     E 21
Blue Cross or Blue Shield  21 24,                                             F 22
Business start-up expenses    12       I                                      G 23
                                       Insurance liabilities 26               H 23
C                                      Interest due on late payment of tax 5  I 23
CAMT 9                                                                        L 26
Charitable contributions   15          L                                      M-1 26
                                                                              M-3 7
Consolidated return  7                 Limitation on dividends-received 
Corporate alternative minimum tax   9    deduction  21                       Section 953 election 8
                                       Limitations on deductions     12
D                                      Lobbying expenses     17              T
Deductions  12                                                               Tax and payments 8
Definitions 19                         M                                     Tax issues, unresolved  2
  100% dividend   19                   Medical loss ratio 5 21 23 24, , ,    Tax rate 8
  Applicable interest rate 21          Medical loss ratio (MLR)    21        Tax-exempt securities 26
  Applicable statutory premium         Minimum tax:                          Travel, meals, and entertainment               16
  recognition pattern   21               Prior year, credit for 9
  Prorated amounts   19                                                      U
  Undiscounted unearned premiums    21 N                                     Uncertain tax positions 24
Depository methods of tax 
  payment   4                          NAIC annual statement      4
Disclosure statement   6               Name change    8                      W
                                       Net operating loss 17                 When to file, extension 3
E                                                                            Where to file 3
                                       O                                     Who must file:
Elective payment election  10                                                 Exceptions   2
Electronic deposit of tax refund of $1 Other deductions   16
  million or more   10                 Owner's country  24                    Life insurance companies  2
Electronic federal tax payment                                               Who must sign  3
  system (EFTPS)     4                 P                                     Worksheet for Schedule C   21
Electronic filing 2                    Paid preparer authorization     3
Employer identification number         Penalties 5 10, 
  (EIN) 8

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