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                                                                                                               Department of the Treasury
                                                                                                               Internal Revenue Service
Instructions for Form 

1120-FSC

(Rev. January 2024)
U.S. Income Tax Return of a Foreign Sales Corporation

Section references are to the Internal Revenue Code calculate CAMT if applicable. See the           FSC Repeal and 
unless otherwise noted.                             instructions for Schedule J, line 4.
Contents                                      Page                                                  Extraterritorial Income 
General Instructions .  . . . . . . . . . . . . 1   Photographs of Missing                          Exclusion
Purpose of Form .         . . . . . . . . . . . 1   Children                                        In general, the FSC Repeal and 
FSC Repeal and                                      The Internal Revenue Service is a proud         Extraterritorial Income Exclusion Act of 2000:
Extraterritorial Income                             partner with the National Center for Missing    Repealed the FSC rules;
Exclusion    . . . . . . . . . . . . . . 1          & Exploited Children® (NCMEC).                  Provided taxpayers with an exclusion, 
Pre-Repeal FSC Rules .            . . . . . . . 2   Photographs of missing children selected by     which is figured on Form 8873, 
Who Must File           . . . . . . . . . . . . . 3 the Center may appear on pages that would       Extraterritorial Income Exclusion; and
When To File .          . . . . . . . . . . . . . 3 otherwise be blank. You can help bring these    Provided transition rules for existing 
Where To File .         . . . . . . . . . . . . . 4 children home by looking at the photographs     FSCs. These rules are included in Rules for 
                                                    and calling 1-800-THE-LOST                      Existing FSCs below.
Who Must Sign .         . . . . . . . . . . . . 4   (1-800-843-5678) if you recognize a child.      Note. The American Jobs Creation Act of 
Paid Preparer Authorization .            . . . . 4
Other Forms That May Be                                                                             2004 repealed the extraterritorial income 
Required .   . . . . . . . . . . . . . . 4          The Taxpayer Advocate                           exclusion provisions generally for 
Assembling the Return .           . . . . . . . 4   Service                                         transactions after 2004, subject to a 
Accounting Methods .            . . . . . . . . 4   The Taxpayer Advocate Service (TAS) is an       transition rule. See the Instructions for Form 
Accounting Period .         . . . . . . . . . . 5   independent organization within the IRS         8873 for more information.
Recordkeeping .         . . . . . . . . . . . . 5   that helps taxpayers and protects taxpayer        The Tax Increase Prevention and 
                                                    rights. TAS’s job is to ensure that every       Reconciliation Act of 2005 repealed the FSC 
Tax Payments .          . . . . . . . . . . . . . 5 taxpayer is treated fairly and knows and        binding contract exception. See Binding 
Estimated Tax Payments .            . . . . . . 6   understands their rights under the Taxpayer     contract exception below for details.
Interest and Penalties .        . . . . . . . . 6   Bill of Rights.
Rounding Off to Whole Dollars .       . . . . . 5                                                   Rules for Existing FSCs
Specific Instructions . . . . . . . . . . . . . 6     As a taxpayer, the corporation has rights     In general, a FSC that was in existence on 
                                                    that the IRS must abide by in its dealings      September 30, 2000, and at all times 
FSC Information .         . . . . . . . . . . . 6   with the corporation. TAS can help the          thereafter may continue to use the FSC rules 
Tax and Payments .          . . . . . . . . . . 7   corporation if:                                 for any transaction in the ordinary course of 
Schedule A . . . . . . . . . . . . . . . 7          A problem is causing financial difficulty for business that is (a) before January 1, 2002, 
Additional Information          . . . . . . . . 8   the business.                                   or (b) after December 31, 2001, if such 
Schedule B . . . . . . . . . . . . . . . 8          The business is facing an immediate           transaction is pursuant to a binding contract 
Schedule E . . . . . . . . . . . . . . . 9          threat of adverse action, or                    that meets the requirements described in 
Schedule F . . . . . . . . . . . . . . . 9          The corporation has tried repeatedly to       Binding contract exception below.
                                                    contact the IRS but no one has responded, 
Schedule G . . . . . . . . . . . . . .          10  or the IRS hasn't responded by the date         Binding contract exception.    The binding 
Schedule J   . . . . . . . . . . . . . .        11  promised.                                       contract exception has been repealed for tax 
Schedule L   . . . . . . . . . . . . . .        12                                                  years beginning after May 17, 2006. For tax 
Schedule M-1 .          . . . . . . . . . . . . 12    TAS has offices in every state, the District  years beginning before May 18, 2006, the 
                                                    of Columbia, and Puerto Rico. Local             following rules apply: The transaction must 
                                                    advocates' numbers are in their local           be pursuant to a binding contract between 
Future Developments                                 directories and at                              the FSC (or a person related to the FSC) and 
For the latest information about                    TaxpayerAdvocate.IRS.gov. The corporation       a person other than a related person if that 
developments related to Form 1120-FSC               can also call TAS at 1-877-777-4778.            binding contract was in effect on September 
and its instructions, such as legislation             TAS also works to resolve large-scale or      30, 2000, and has remained in effect. A 
enacted after they were published, go to            systemic problems that affect many              binding contract includes a purchase, 
IRS.gov/Form1120FSC.                                taxpayers. If the corporation knows of one of   renewal, or replacement option that is 
                                                    these broad issues, please report it to TAS     enforceable against a lessor or seller 
What's New                                          through the Systemic Advocacy                   (provided the option is part of a contract that 
                                                    Management System at IRS.gov/SAMS.              is binding and in effect on September 30, 
Increase in penalty for failure to file.      For                                                   2000, and has remained in effect).
tax returns required to be filed in 2024, the         For more information, go to IRS.gov/
minimum penalty for failure to file a return        Advocate.                                         The mere entering into of a single 
that is more than 60 days late has increased                                                        transaction, such as a lease, would not, in 
                                                                                                    and of itself, prevent the transaction from 
to the smaller of the tax due or $485. See          General Instructions                            being in the ordinary course of business.
Penalty for late filing of return, later.
Corporate alternative minimum tax 
(CAMT). For tax years beginning after 2022,         Purpose of Form                                 Election To Apply Exclusion Rules
certain corporations must determine whether         Use Form 1120-FSC to report the income, 
they are subject to the new CAMT and                gains, losses, deductions, credits, and to      Taxpayers may elect to apply the 
                                                    figure the income tax liability of a FSC.       extraterritorial income exclusion rules instead 

Jan 24, 2024                                                        Cat. No. 11532V



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of the FSC rules for transactions occurring       Pre-Repeal FSC Rules                              A small FSC is exempt from the foreign 
during the transition period. The election is:                                                    management and foreign economic process 
Made by checking the box on line 2 of           Definition of a Foreign Sales                   requirements outlined on this page.
Form 8873,
Made on a transaction-by-transaction            Corporation (FSC)                                 $5 million limit. Generally, any foreign 
basis,                                            Under section 922(a), a FSC is defined as a     trading gross receipts of a small FSC for the 
Effective for the tax year for which it is      corporation that has met all of the following   tax year that exceed $5 million are not to be 
made and for all subsequent tax years, and        rules:                                          considered in determining its exempt foreign 
Revocable only with the consent of the            1. It must be a corporation created or        trade income. The $5 million limit is reduced 
IRS.                                              organized under the laws of a qualifying        if the small FSC has a short tax year. It may 
                                                  foreign country or any U.S. possession other    also be reduced if the small FSC is a 
  Taxpayers use Form 8873 to determine            than Puerto Rico.                               member of a controlled group that contains 
                                                                                                  other small FSCs. See Regulations section 
their extraterritorial income exclusion.            Qualifying U.S. possessions include           1.921-2(b) for more information.
Election To Be Treated as a                       Guam, American Samoa, the 
                                                  Commonwealth of the Northern Mariana            Tax Treatment of a FSC
Domestic Corporation                              Islands, and the U.S. Virgin Islands.           A FSC is not taxed on its exempt foreign 
A FSC that was in existence on September            A qualifying foreign country is a foreign     trade income. Section 923 defines foreign 
30, 2000, and at all times thereafter may         country that meets the exchange of              trade income as the gross income of a FSC 
elect to be treated as a domestic corporation     information rules of section 927(e)(3)(A) or    attributable to foreign trading gross receipts 
if substantially all of its gross receipts are    (B). All U.S. possessions other than Puerto     (defined below).
foreign trading gross receipts. A FSC that        Rico are also certified to have met these 
elects to be treated as a domestic                rules.                                            The percentage of foreign trade income 
corporation ceases to be a FSC for any tax                                                        exempt from tax is figured differently for 
year for which the election applies (and for        The following countries are qualifying        income determined under the administrative 
any subsequent tax year).                         foreign countries that have met the exchange    pricing rules (for details, see the Instructions 
                                                  of information rules of section 927(e)(3)(A) or for Schedule P (Form 1120-FSC)) and 
  The election is made by checking the box        927(e)(3)(B): Australia, Austria, Barbados,     income determined without regard to the 
on line 3 of Form 8873. An electing               Belgium, Bermuda, Canada, Costa Rica,           administrative pricing rules. These 
corporation files Form 1120, U.S.                 Cyprus, Denmark, Dominica, the Dominican        percentages are computed on Schedule E, 
Corporation Income Tax Return. Once made,         Republic, Egypt, Finland, France, Germany,      page 4, Form 1120-FSC, and carried over to 
the election applies to the tax year for which    Grenada, Guyana, Honduras, Iceland,             lines 9a and 9b of Schedule B, page 3, Form 
it is made and remains in effect for all          Ireland, Jamaica, Korea, Malta, the Marshall    1120-FSC, to figure taxable income or (loss).
subsequent years unless the election is           Islands, Mexico, Morocco, the Netherlands, 
revoked or terminated. If the election is         New Zealand, Norway, Pakistan, Peru, the          See section 923(a)(4) for a special rule 
revoked or terminated, the corporation would      Philippines, St. Lucia, Sweden, and Trinidad    for foreign trade income allocable to a 
be a foreign corporation that files Form          and Tobago.                                     cooperative. See section 923(a)(5) for a 
1120-F, U.S. Income Tax Return of a Foreign         2. It had no more than 25 shareholders        special rule for military property.
Corporation. Furthermore, the foreign             at any time during the tax year.                Tax treaty benefits. A FSC may not claim 
corporation would not be eligible to reelect to 
be treated as a domestic corporation for 5          3. It had no preferred stock outstanding      any benefits under any income tax treaty 
tax years beginning with the first tax year for   at any time during the tax year.                between the United States and any foreign 
which the original election is not in effect as a   4. During the tax year, the FSC must          country.
result of the revocation or termination.          maintain:                                       Foreign Trading Gross Receipts
Effect of election. For purposes of section       An office in one of the qualifying foreign 
367, a foreign corporation that has elected to    countries or U.S. possessions listed above;     A FSC is treated as having foreign trading 
be a domestic corporation is generally            A set of permanent books of account           gross receipts (defined in section 924) only if 
treated as transferring, as of the first day of   (including invoices) at that office; and        it has met certain foreign management and 
the first tax year to which the election          The books and records required under          foreign economic process requirements.
applies, all of its assets to a domestic          section 6001 at a U.S. location to sufficiently   Foreign trading gross receipts do not 
corporation in an exchange under section          establish the amount of gross income,           include:
354.                                              deductions, credits, or other matters required  Certain excluded receipts (defined in 
                                                  to be shown on its tax return.                  section 924(f)).
FSC Election                                        5. It must have at least one director, at     Receipts attributable to property excluded 
No corporation may elect to be a FSC or a         all times during the tax year, who is not a     from export property under section 927(a)(2).
small FSC (defined below) after September         resident of the United States.                  Investment income (defined in section 
30, 2000.                                           6. It must not be a member, at any time       927(c)).
                                                  during the tax year, of a controlled group of   Carrying charges (defined in section 
Termination of Inactive FSCs                      which a DISC is a member.                       927(d)(1)).
If a FSC has no foreign trade income (see           7. It must have elected to be a FSC or        Note. Computer software licensed for 
definition under Tax Treatment of a FSC,          small FSC, and the election must have been      reproduction abroad is not excluded from 
later) for any 5 consecutive tax years            in effect for the tax year.                     export property under section 927(a)(2). 
beginning after December 31, 2001, the FSC 
                                                                                                  Therefore, receipts attributable to the sale, 
will no longer be treated as a FSC for any tax    Small FSC. Section 922(b) defines a small       lease, or rental of computer software and 
year beginning after that 5-year period.          FSC as a corporation that:                      services related and subsidiary to such 
Additional Information                            Elected small FSC status and has kept the     transactions qualify as foreign trading gross 
                                                  election in effect for the tax year; and        receipts.
For additional information regarding the rules      Is not a member, at any time during the 
discussed above, see Rev. Proc. 2001-37,          
                                                  tax year, of a controlled group that includes a 
2001-1 C.B. 1327.                                 FSC (unless that other FSC is also a            Foreign Management Rules
                                                  small FSC).
                                                                                                  A FSC (other than a small FSC) is treated as 
                                                                                                  having foreign trading gross receipts for the 
                                                                                                  tax year only if the management of the FSC 

2                                                                                             Instructions for Form 1120-FSC (Rev. 1-2024)



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during the year takes place outside the          terms of a transaction, including, but not         attributable to activities performed outside 
United States. These management activities       limited to, price, credit terms, quantity, or time the United States. For purposes of the 50% 
include:                                         or manner of delivery.                             test, foreign direct costs are based on the 
Meetings of the board of directors and           3. Making a contract refers to                   direct costs of all activities described in all 
meetings of the shareholders.                    performance by the FSC of any of the               paragraphs of section 924(e). For purposes 
Disbursing cash, dividends, legal and          elements necessary to complete a sale, such        of the 85% test, however, foreign direct costs 
accounting fees, salaries of officers, and       as making or accepting an offer.                   are determined separately for each 
salaries or fees of directors from the principal                                                    paragraph of section 924(e).
bank account (see below).                          Grouping transactions.      Generally, the       For more details, see Regulations section 
Maintaining the principal bank account at      sales activities described above are to be         1.924(d)-1(d).
all times during the tax year.                   applied on a transaction-by-transaction 
                                                 basis. However, a FSC may make an annual           Check the applicable box(es) on line 10b, 
Meetings of directors and meetings of            election to apply any of the sales activities on   Additional Information, on page 2 of the form, 
the shareholders. All meetings of the            the basis of a group. To make the election,        to indicate how the FSC met the foreign 
board of directors of the FSC and all            check the applicable box on line 10a,              direct costs requirement.
meetings of the shareholders of the FSC that     Additional Information, on page 2 of Form          Grouping transactions.      Generally, the 
take place during the tax year must take         1120-FSC. See Regulations section                  foreign direct cost tests under Regulations 
place outside the United States.                 1.924(d)-1(c)(5) for details.                      section 1.924(d)-1(d) are applied on a 
  In addition, all such meetings must                                                               transaction-by-transaction basis. However, 
comply with the local laws of the foreign        Satisfaction of either the 50% or 85% for-
country or U.S. possession in which the FSC      eign direct cost test. To qualify as foreign       the FSC may make an annual election (on 
was created or organized. The local laws         trading gross receipts, the foreign direct         line 10d, Additional Information, on page 2 of 
determine whether a meeting must be held,        costs incurred by the FSC attributable to the      the form) to apply the foreign direct cost tests 
when and where it must be held (if it is held    transaction must equal or exceed 50% of the        on a customer, contract, or product or 
at all), who must be present, quorum             total direct costs incurred by the FSC             product line grouping basis. Any grouping 
requirements, use of proxies, etc.               attributable to the transaction.                   used must be supported by adequate 
                                                                                                    documentation of performance of activities 
                                                   Instead of satisfying the 50% foreign            and costs of activities relating to the grouping 
Principal bank accounts.  See Regulations        direct cost test, the FSC may incur foreign        used. See Regulations section 1.924(d)-1(e) 
section 1.924(c)-1(c) for information            direct costs attributable to activities            for details.
regarding principal bank accounts.               described in each of two of the section 
                                                 924(e) categories. The costs must equal or         Exception for foreign military property. 
Foreign Economic Process Rules                   exceed 85% of the total direct costs incurred      The economic process rules do not apply to 
                                                 by the FSC attributable to the activity            any activities performed in connection with 
A FSC (other than a small FSC) has foreign       described in each of the two categories. If no     foreign military sales except those activities 
trading gross receipts from any transaction      direct costs are incurred by the FSC in a          described in section 924(e). See Regulations 
only if certain economic processes for the       particular category, that category is not taken    section 1.924(d)-1(f) for details.
transaction take place outside the United        into account for purposes of determining 
States. Section 924(d) and Regulations           whether the FSC has met either the 50% or          Section 925(c) Rule
section 1.924(d)-1 set forth the rules for       85% foreign direct cost test.                      To use the administrative pricing rules to 
determining whether a sufficient amount of         Direct costs are costs that:                     determine the FSC's (or small FSC's) profit 
the economic processes of a transaction          Are incident to and necessary for the            on a transaction or group of transactions, the 
takes place outside the United States.           performance of any activity described in           FSC must perform (or contract with another 
                                                 section 924(e);                                    person to perform) all of the economic 
  Generally, a transaction will qualify if the   Include the cost of materials consumed in        process activities relating to the transaction 
FSC satisfies two requirements:                  the performance of the activity and the cost       or group of transactions. All of the direct and 
Participation outside the United States in     of labor that can be identified or associated      indirect expenses relating to the performance 
the sales portion of the transaction and         directly with the performance of the activity      of those activities must be reflected on the 
Satisfaction of either the 50% or the 85%      (but only to the extent of wages, salaries,        books of the FSC and on Form 1120-FSC.
foreign direct cost test.                        fees for professional services, and other 
                                                 amounts paid for services actually rendered,       Under Temporary Regulations section 
                                                 such as bonuses or compensation paid for           1.925(a)-1T(b)(2)(ii), an election may be 
  The activities comprising these economic       services on the basis of a percentage of           made to include on the FSC's books all 
processes may be performed by the FSC or         profits); and                                      expenses, other than cost of goods sold, that 
by any other person acting under contract          Include the allowable depreciation               are necessary to figure combined taxable 
with the FSC.                                    
                                                 deduction for equipment or facilities (or the      income for the transaction or group of 
Participation outside the United States in       rental cost for its use) that can be specifically  transactions. The expenses must be 
the sales portion of the transaction.            identified or associated with the activity, as     identified on Schedule G on the applicable 
Generally, the requirement of section 924(d)     well as the contract price of an activity          line.
(1)(A) is met for the gross receipts of a FSC    performed on behalf of the FSC by a 
derived from any transaction if the FSC has      contractor.                                        Who Must File
participated outside the United States in the      Total direct costs means all of the direct       File Form 1120-FSC if the corporation 
following sales activities relating to the       costs of any transaction attributable to           elected to be treated as a FSC or small FSC, 
transaction: (1) solicitation (other than        activities described in any paragraph of           and the election is still in effect.
advertising), (2) negotiation, and (3) making    section 924(e). For purposes of the 50% test 
a contract.                                      of section 924(d)(1)(B), total direct costs are    Note. A FSC that elects to be treated as a 
  1. Solicitation (other than advertising) is    based on the direct costs of all activities        domestic corporation under section 943(e)
any communication (including, but not limited    described in all paragraphs of section             (1) does not file Form 1120-FSC. Instead, it 
to, telephone, telegraph, mail, or in person)    924(e). For purposes of the 85% test of            files Form 1120.
by the FSC, to a specific, targeted customer     section 924(d)(2), however, the total direct 
or potential customer.                           costs are determined separately for each           When To File
  2. Negotiation is any communication by         paragraph of section 924(e).                       Generally, a corporation must file Form 
the FSC to a customer or potential customer        Foreign direct costs means the portion           1120-FSC by the 15th day of the 4th month 
aimed at an agreement on one or more of the      of the total direct costs of any transaction       after the end of its tax year. A FSC that has 

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                        3



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dissolved must generally file by the 15th day   Include their Preparer Tax Identification       See the Instructions for Form 5471 for 
of the 4th month after the date it dissolved.   Number (PTIN), and                              more information.
   However, a FSC with a fiscal tax year        Give a copy of the return to the taxpayer.    Form 5472, Information Return of a 25% 
                                                                                                Foreign-Owned U.S. Corporation or a 
ending June 30 must file by the 15th day of     Note. A paid preparer may sign original or      Foreign Corporation Engaged in a U.S. Trade 
the 3rd month after the end of its tax year. A  amended returns by rubber stamp,                or Business. This form is filed by or for a 
FSC with a short tax year ending anytime in     mechanical device, or computer software         foreign corporation engaged in a U.S. trade 
June will be treated as if the short year       program.                                        or business that had reportable transactions 
ended on June 30, and must file by the 15th                                                     with a related party. See the Instructions for 
day of the 3rd month after the end of its tax                                                   Form 5472 for filing instructions and 
year.                                           Paid Preparer 
                                                                                                information about penalties.
   If the due date falls on a Saturday,         Authorization                                   Form 5713, International Boycott Report. 
Sunday, or legal holiday, the corporation can   If the FSC wants to allow the IRS to discuss    FSCs that had operations in, or related to, 
file on the next business day.                  its tax return with the paid preparer who       certain “boycotting” countries file
                                                signed it, check the “Yes” box in the signature Form 5713.
Private delivery services.   FSCs can use       area of the return. This authorization applies  Form 8275, Disclosure Statement, and 
certain private delivery services (PDS)         only to the individual whose signature          Form 8275-R, Regulation Disclosure 
designated by the IRS to meet the “timely       appears in the “Paid Preparer Use Only”         Statement. Use these forms to disclose 
mailing as timely filing” rule for tax returns. section of the return. It does not apply to the items or positions taken on a tax return that 
Go to IRS.gov/PDS. The PDS can tell you         firm, if any, shown in that section.            are not otherwise adequately disclosed on a 
how to get written proof of the mailing date.                                                   tax return or that are contrary to Treasury 
                                                  If the “Yes” box is checked, the FSC is 
   For the IRS mailing address to use if        authorizing the IRS to call the paid preparer   regulations (to avoid parts of the 
you’re using PDS, go to IRS.gov/                to answer any questions that may arise          accuracy-related penalty or certain preparer 
PDSstreetAddresses.                             during the processing of its return. The FSC    penalties).
        Private delivery services cannot        is also authorizing the paid preparer to:       Form 8300, Report of Cash Payments 
  !     deliver items to P.O. boxes. You must   Give the IRS any information that is          Over $10,000 Received in a Trade or 
CAUTION use the U.S. Postal Service to mail     missing from the return;                        Business. Use this form to report the receipt 
any item to an IRS P.O. box address.            Call the IRS for information about the        of more than $10,000 in cash or foreign 
                                                processing of the return or the status of any   currency in one transaction or a series of 
Extension of time to file.   A FSC must File    related refund or payment(s); and               related transactions.
Form 7004, Application for Automatic            Respond to certain IRS notices about 
Extension of Time To File Certain Business      math errors, offsets, and return preparation.   Assembling the Return
Income Tax, Information, and Other Returns,       The FSC is not authorizing the paid           To ensure that the FSC's tax return is 
by the return due date specified earlier, to    preparer to receive any refund check, bind      correctly processed, attach all schedules 
request an extension of time to file. See the   the FSC to anything (including any additional   and other forms after page 6 of Form 
Instructions for Form 7004 for additional       tax liability), or otherwise represent the FSC  1120-FSC, in the following order:
information.                                    before the IRS.                                   1. Form 4136.
                                                  The authorization will automatically end        2. Additional schedules in alphabetical 
Where To File                                   no later than the due date (excluding           order.
File Form 1120-FSC with the:                    extensions) for filing the FSC's tax return. If   3. Additional forms in numerical order.
Internal Revenue Service Center                 the FSC wants to expand the paid preparer's 
P.O. Box 409101                                 authorization or revoke the authorization         4. Supporting statements and 
Ogden, UT 84409                                 before it ends, see Pub. 947, Practice Before   attachments.
                                                the IRS and Power of Attorney.
Who Must Sign                                                                                     Complete every applicable entry space 
The return must be signed and dated by:         Other Forms That May Be                         on Form 1120-FSC. Do not enter “See 
The president, vice president, treasurer,                                                     Attached” or “Available Upon Request” 
assistant treasurer, chief accounting officer;  Required                                        instead of completing the entry spaces. If 
or                                              The FSC may have to file some of the forms      more space is needed on the forms or 
Any other corporate officer (such as tax      listed below. See the form for more             schedules, attach separate sheets using the 
officer) authorized to sign.                    information.                                    same size and format as the printed forms.
   If a return is filed on behalf of a FSC by a   For a list of additional forms the FSC may 
receiver, trustee, or assignee, the fiduciary   need to file (most notably, forms pertaining to   If there are supporting statements and 
must sign the return, instead of the corporate  the reporting of various types of income, and   attachments, arrange them in the same order 
officer. Returns and forms signed by a          any related withholding, to U.S. persons,       as the schedules or forms they support and 
receiver or trustee in bankruptcy on behalf of  foreign persons, and the IRS), see Pub. 542,    attach them last. Show the totals on the 
a FSC must be accompanied by a copy of          Corporations.                                   printed forms. Enter the FSC's name and EIN 
the order or instructions of the court          Form 5471, Information Return of U.S.         on each supporting statement or attachment.
authorizing signing of the return or form.      Persons With Respect to Certain Foreign 
                                                Corporations. This form may have to be filed    Accounting Methods
Paid Preparer Use Only section.    If an        by certain U.S. officers, directors, or         In general, figure taxable income using the 
employee of the FSC completes Form              shareholders of a FSC to report changes in      method of accounting used in keeping the 
1120-FSC, the paid preparer section should      ownership (see sections 6046 and the            FSC's books and records. In all cases, the 
remain blank. Anyone who prepares Form          related regulations).                           method used must clearly show taxable 
1120-FSC but does not charge the FSC              If a Form 1120-FSC is filed, Form 5471 is     income. Permissible overall methods of 
should not complete that section. Generally,    not required to be filed to satisfy the         accounting include cash, accrual, or any 
anyone who is paid to prepare the return        requirements of section 6038 (see               other method authorized by the Internal 
must sign and complete the section.             Temporary Regulations section 1.921-1T(b)       Revenue Code.
   The paid preparer must complete the          (3)). However, certain U.S. shareholders may 
required preparer information and:              be required to file Form 5471 and the             Generally, the following rules apply. For 
Sign the return in the space provided for     applicable schedules to report subpart F        more information, see Pub. 538, Accounting 
the preparer's signature.                       income.                                         Periods and Methods.

4                                                                                         Instructions for Form 1120-FSC (Rev. 1-2024)



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A FSC cannot use the cash method of             If the net section 481(a) adjustment is          FSCs that do not maintain an office or 
accounting unless it is a small business          positive, report the ratable portion on Form     place of business in the United States can 
taxpayer (defined later). A tax shelter           1120-FSC, page 4, Schedule F, line 16, as        use the Electronic Federal Tax Payment 
(defined in section 448(d)(3)) may never use      other income. If the net section 481(a)          System (EFTPS) to pay the tax due provided 
the cash method. See sections 448(a)(1)           adjustment is negative, report the ratable       the FSC has a U.S. bank account. If the FSC 
through (a)(3). However, see Nonaccrual           portion on Form 1120-FSC, page 4,                does not have a U.S. bank account, it may 
experience method for service providers,          Schedule F, line 18, as a deduction.             arrange for a financial institution to initiate a 
later.                                                                                             same-day payment on its behalf or it can 
Unless it is a small business taxpayer          Accounting Period                                arrange for a qualified intermediary, tax 
(defined below), a FSC must use an accrual        A FSC must figure its taxable income on the      professional, payroll service, or other trusted 
method for sales and purchases of inventory       basis of a tax year. A tax year is the annual    third party to make a deposit on its behalf 
items. See the instructions for Form 1125-A.      accounting period a FSC uses to keep its         using a master account. In addition, the FSC 
A corporation engaged in farming must           records and report its income and expenses.      still has the option to pay by check or money 
use an accrual method. For exceptions, see        Generally, FSCs may use a calendar year or       order, payable to “United States Treasury.” To 
section 447 and Pub. 225.                         a fiscal year. Personal service corporations,    help ensure proper crediting, write the FSC's 
Special rules apply to long-term contracts.     however, must generally use a calendar year.     EIN, “Form 1120-FSC,” and the tax period to 
See section 460.                                                                                   which the payment applies on the check or 
Small business taxpayer.    For tax years         Note. The tax year of a FSC must be the          money order. Enclose the payment when 
beginning in 2023, a FSC qualifies as a small     same as the tax year of the principal            Form 1120-FSC is filed.
business taxpayer if (a) it has average annual    shareholder which, at the beginning of the       FSCs that do maintain an office or place 
gross receipts of $29 million or less for the 3   FSC tax year, has the highest percentage of      of business in the United States must pay the 
prior tax years, and (b) is not a tax shelter (as voting power. If two or more shareholders        tax due by electronic funds transfer. The FSC 
defined in section 448(d)(3)).                    have the highest percentage of voting power,     can pay the tax using EFTPS or it can 
  A small business taxpayer can account           the FSC must have a tax year that conforms       arrange for its tax professional, financial 
for inventory by (a) treating the inventory as    to the tax year of any such shareholder. See     institution, payroll service, or other trusted 
non-incidental materials and supplies, or (b)     section 441(h).                                  third party to make deposits on its behalf. In 
conforming to its treatment of inventory in an                                                     addition, the FSC also has the option to 
applicable financial statement (as defined in     Rounding Off to Whole                            arrange for its financial institution to initiate a 
                                                                                                   same-day payment.
section 451(b)(3)). If it does not have an        Dollars
applicable financial statement, it can use the    The FSC may enter decimal points and cents       Note. If the due date falls on a Saturday, 
method of accounting used in its books and        when completing its return. However, the         Sunday, or legal holiday, the payment is due 
records prepared according to its accounting      corporation should round off cents to whole      on the next day that isn't a Saturday, Sunday, 
procedures.                                       dollars on its return, forms, and schedules to   or legal holiday.
Change in accounting method.    Generally,        make completing its return easier. The 
an FSC must get IRS consent to change             corporation must either round off all amounts    Electronic Deposit Requirement
either an overall method of accounting or the     on its return to whole dollars or use cents for  FSCs with an office or place of business in 
accounting treatment of any material item for     all amounts. To round, drop amounts under        the United States must use electronic funds 
income tax purposes. To obtain consent, the       50 cents and increase amounts from 50 to 99      transfers to make all federal tax deposits 
corporation must generally file Form 3115,        cents to the next dollar. For example, $8.40     (such as deposits of employment and 
Application for Change in Accounting              rounds to $8 and $8.50 rounds to $9.             corporate income tax). Generally, electronic 
Method, during the tax year for which the                                                          funds transfers are made using EFTPS. 
change is requested. See the Instructions for     If two or more amounts must be added to          However, if the corporation does not want to 
Form 3115 and Pub. 538 for more                   figure the amount to enter on a line, include    use EFTPS, it can arrange for its tax 
information and exceptions. Also see the          cents when adding the amounts and round          professional, financial institution, payroll 
Instructions for Form 3115 for procedures         off only the total.                              service, or other trusted third party to make 
that may apply for obtaining automatic                                                             deposits on its behalf. Also, it can arrange for 
consent to change certain methods of              Recordkeeping                                    its financial institution to submit a same-day 
accounting, non-automatic change                  Keep the FSC's records for as long as they       payment (discussed below) on its behalf. 
procedures, and reduced Form 3115 filing          may be needed for the administration of any      EFTPS is a free service provided by the 
requirements.                                     provision of the Internal Revenue Code.          Department of the Treasury. Services 
  Section 481(a) adjustment.   If the             Usually, records that support an item of         provided by a tax professional, financial 
FSC’s taxable income for the current tax year     income, deduction, or credit on the return       institution, payroll service, or other third party 
is figured under a method of accounting           must be kept for 3 years from the date the       may have a fee.
different from the method used in the             return is due or filed, whichever is later. Keep For more information about EFTPS or to 
preceding tax year, the corporation may have      records that verify the FSC's basis in           enroll in EFTPS, visit EFTPS.gov, or call 
to make an adjustment under section 481(a)        property for as long as they are needed to       1-800-555-4477 (TTY/TDD 
to prevent amounts of income or expense           figure the basis of the original or replacement  1-800-733-4829).
from being duplicated or omitted. The             property.
                                                                                                   Depositing on time.    For any deposit made 
section 481(a) adjustment period is generally     The FSC should keep copies of all filed          by EFTPS to be on time, the FSC must 
1 year for a net negative adjustment and 4        returns. They help in preparing future and       submit the deposit by 8 p.m. Eastern time the 
years for a net positive adjustment. See the      amended returns and in the calculation of        day before the date the deposit is due. If the 
Instructions for Form 3115.                       earnings and profits.                            FSC uses a third party to make deposits on 
  Exceptions to the general section 481(a)                                                         its behalf, they may have different cutoff 
adjustment period may apply. Also, in some        Tax Payments                                     times.
cases, a corporation can elect to modify the      The FSC must pay any tax due in full no later    Same-day wire payment option.   If the 
section 481(a) adjustment period. The             than the due date for filing Form 1120-FSC       FSC fails to submit a deposit transaction on 
corporation may have to complete the              (not including extensions). See When To          EFTPS by 8 p.m. Eastern time the day before 
appropriate lines of Form 3115 to make an         File, earlier, for this due date. The method for the date a deposit is due, it can still make the 
election. See the Instructions for Form 3115      payment of the tax due depends upon              deposit on time by using the Federal Tax 
for more information and exceptions.              whether the FSC has an office or place of        Collection Service (FTCS). To use the 
                                                  business in the United States.                   same-day wire payment option, the FSC will 

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                         5



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need to make arrangements with its financial      show that the failure to file on time was due    street address and the FSC has a P.O. box, 
institution ahead of time regarding               to reasonable cause.                             show the box number instead.
availability, deadlines, and costs. Financial                                                        If the FSC receives its mail in care of a 
institutions may charge a fee for payments                If you believe that reasonable cause 
                                                                                                   third party (such as an accountant or an 
information the FSC will need to provide to its   CAUTION when you file Form 1120-FSC. 
made this way. To learn more about the              !     exists, do not attach an explanation     attorney), enter “C/O” on the street address 
financial institution to make a same-day wire     Instead, if the FSC receives a penalty notice    line followed by the third party's name and 
payment, go to IRS.gov/SameDayWire.               after the return is filed, send the IRS an       street address or P.O. box.
                                                  explanation at that time and the IRS will        Item A. Foreign country or U.S. posses-
                                                  determine if the FSC meets                       sion of incorporation. See Definition of a 
Estimated Tax Payments                            reasonable-cause criteria.                       Foreign Sales Corporation (FSC), earlier.
Generally, the following rules apply to the 
FSC's payments of estimated tax.                  Penalty for late payment of tax.  A FSC          Item E. Total assets. Enter the FSC's total 
                                                  that does not pay the tax when due generally     assets (as determined by the accounting 
The FSC must make installment payments          may be penalized  /  of 1% of the unpaid tax 1 2 method regularly used in keeping the FSC's 
of estimated tax if it expects its total tax for  for each month or part of a month the tax is     books and records) at the end of the tax year 
the year (less applicable credits) to be $500     not paid, up to a maximum of 25% of the          from Form 1120-FSC, page 6, Schedule L, 
or more.                                          unpaid tax. The penalty will not be imposed if   column (d), line 15. If there are no assets at 
The installments are due by the 15th day        the FSC can show that the failure to pay on      the end of the tax year, enter -0-.
of the 4th, 6th, 9th, and 12th months of the      time was due to reasonable cause. See            Item F. Final return, name change, ad-
tax year. If any date falls on a Saturday,        Caution, above.                                  dress change, or amended return. 
Sunday, or legal holiday, the installment is                                                         If this is the FSC's final return and it will no 
due on the next regular business day.             Trust fund recovery penalty. This penalty        
If the FSC maintains an office or place of      may apply if certain income, social security,    longer exist, check the “Final return” box.
business in the United States, it must use        and Medicare taxes that must be collected or     If the FSC changed its name since it last 
electronic funds transfer to make installment     withheld are not collected or withheld, or       filed a return, check the box for “Name 
payments of estimated tax.                        these taxes are not paid. These taxes are        change.” Generally, a FSC must also have 
If the FSC does not maintain an office or       generally reported on Form 941, Employer's       amended its articles of incorporation and 
place of business in the United States, it can    QUARTERLY Federal Tax Return, or Form            filed the amendment with the jurisdiction in 
pay the estimated tax by EFTPS, providing it      945, Annual Return of Withheld Federal           which it was incorporated.
has a U.S. bank account. The FSC can also         Income Tax.                                      If the FSC has changed its address since 
arrange for its financial institution to submit a   The trust fund recovery penalty may be         it last filed a return (including a change to an 
same-day payment on its behalf or can             imposed on all persons who are determined        “in care of” address), check the box for 
arrange for its qualified intermediary, tax       by the IRS to have been responsible for          “Address change.”
professional, payroll service, or other trusted   collecting, accounting for, or paying over       Note. If a change of address or responsible 
third party to make a deposit on its behalf       these taxes, and who acted willfully in not      party occurs after the return is filed, use 
using a master account. In addition, the FSC      doing so. The penalty is equal to the full       Form 8822-B, Change of Address or 
still has the option to pay the estimated tax     amount of the unpaid trust fund tax. See Pub.    Responsible Party - Business, to notify the 
due by check or money order.                      15 (Circular E), Employer's Tax Guide, for       IRS. See the instructions for Form 8822-B for 
Penalties may apply if the corporation          details, including the definition of responsible details.
does not make required estimated tax              persons.                                           If the FSC is amending its return, check 
                                                                                                   
payment deposits. See line 3, Estimated tax       Other penalties. Other penalties may be          the box for “Amended return.”
penalty, later.                                   imposed for negligence, substantial 
If the FSC overpaid estimated tax, it may       understatement of tax, reportable transaction    FSC Information
be able to get a quick refund by filing Form      understatements, and fraud. See sections 
4466, Corporation Application for Quick           6662, 6662A, and 6663.                           Line 1. Principal shareholder.     Complete 
Refund of Overpayment of Estimated Tax.                                                            lines 1a through 1h for the shareholder 
                                                    A FSC may also be subject to a penalty 
  See section 6655 for more information on        (under section 6686) of:                         (individual, corporation, partnership, trust, or 
how to figure estimated taxes.                    $100 for each failure to supply                estate) that was the principal shareholder at 
                                                  information, up to $25,000 during the            the beginning of the FSC's tax year. See the 
                                                  calendar year.                                   Note under Accounting Period, earlier.
                                                  
Interest and Penalties                              $1,000 for not filing a return.                  Foreign address.    Enter the information 
Interest. Interest is charged on taxes paid         The section 6686 penalties will not apply      in the following order: city or town, state or 
late even if an extension of time to file is      if the FSC can show that the failure was due     province, country, and foreign postal code. 
granted. Interest is also charged on penalties    to reasonable cause. However, see Caution,       Follow the country's practice for entering the 
imposed for failure to file, negligence, fraud,   above.                                           name of the state or province and postal 
substantial valuation misstatements,                                                               code. Do not abbreviate the country name.
substantial understatements of tax, and 
                                                                                                   Line 2. Parent-subsidiary controlled 
reportable transaction understatements from       Specific Instructions                            group.  If the FSC is a subsidiary in a 
the due date (including extensions) to the 
date of payment. The interest charge is           Period covered.  Enter the FSC ‘s tax year       parent-subsidiary controlled group and the 
figured at a rate determined under section        in the space provided at the top of the form.    principal shareholder is not the common 
6621.                                             See Accounting Period, earlier.                  parent of the group, complete lines 2a 
                                                                                                   through 2g for the common parent. Enter the 
Penalty for late filing of return. A FSC          Name.   Print or type the FSC's true name (as    consolidated total assets on line 2d for a 
that does not file its tax return by the due      set forth in the charter or other legal          group that files a consolidated return; 
date, including extensions, may be penalized      document creating it).                           otherwise, enter only the common parent's 
5% of the unpaid tax for each month or part       Address. Enter the U.S. address where the        total assets.
of a month the return is late, up to a            FSC maintains the records required under 
maximum of 25% of the unpaid tax. The             section 6001. Include the suite, room, or        Note. Check the “Yes” box on line 2 if the 
minimum penalty for a tax return required to      other unit number after the street address. If   FSC is a subsidiary in a parent-subsidiary 
be filed in 2024 that is more than 60 days late   the post office does not deliver mail to the     controlled group. This applies even if the 
is the smaller of the tax due or $485. The 
penalty will not be imposed if the FSC can 

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FSC is a subsidiary member of one group          administrative pricing rules. For details on      section 263A costs paid or incurred during 
and the parent corporation of another.           the administrative pricing rules, see the         the tax year not includible on lines 2, 3, and 
  A “parent-subsidiary controlled group” is      Instructions for Schedule P (Form                 5.
one or more chains of corporations               1120-FSC).
                                                                                                   Line 5. Other costs. Enter on line 5 any 
connected through stock ownership                If the FSC acts as another person's               costs paid or incurred during the tax year not 
(sections 927(d)(4) and 1563(a)(1)). Both of     commission agent on a sale, do not enter          entered on lines 2 through 4. Attach a 
the following requirements must be met:          any amount on Schedule A for the sale.            statement listing details of the costs.
  1. More than 50% of the total combined                                                           Line 7. Inventory at end of year. See 
voting power of all classes of stock entitled to Small FSCs will have to make two 
vote or more than 50% of the total value of all  separate computations for cost of goods sold      Regulations sections 1.263A-1 through 
classes of stock of each corporation in the      if their foreign trading gross receipts exceed    1.263A-3 for details on determining the 
group (except the parent) must be owned by       the limitation amount on line 6e of               amount of additional section 263A costs to 
one or more of the other corporations in the     Schedule B. In this case, a deduction for cost    be included in ending inventory.
group.                                           of goods sold will be figured separately for      Lines 9a through 9f. Inventory valuation 
                                                 the income on line 6h of Schedule B, and          methods. Inventories may be valued at:
  2. The common parent must own more             separately for the income on line 7 of            Cost,
than 50% of the total combined voting power      Schedule F.                                       Cost or market value (whichever is lower), 
of all classes of stock entitled to vote or more 
than 50% of the total value of all classes of    Inventories                                       or
                                                                                                   Any other method approved by the IRS 
stock of at least one of the other corporations  Generally, unless you are a small business        that conforms to the requirements of the 
in the group.                                    taxpayer, inventories are required at the         applicable regulations.
  Stock owned directly by other members          beginning and end of each tax year if the 
of the group is not counted when computing       purchase or sale of merchandise is an               FSCs that use erroneous valuation 
the voting power or value.                       income-producing factor. See Regulations          methods must change to a method permitted 
                                                 section 1.471-1. Additionally, if inventories     for federal income tax purposes. To make 
  See sections 927(d)(4) and 1563(d)(1) for      are required, you generally must use an           this change, use Form 3115. See the 
the definition of “stock” for purposes of        overall accrual method of accounting.             Instructions for Form 3115. Also see Pub. 
determining stock ownership above.                                                                 538.
                                                 If a FSC is a small business taxpayer 
Tax and Payments                                 (defined below), it may adopt or change its       Line 9a. Method of valuing closing inven-
                                                 accounting method to account for inventories      tory.  On line 9a, check the method(s) used 
Line 2h. Backup withholding.      If the FSC     in the same manner as materials and               for valuing inventories. Under lower of cost or 
had income tax withheld from any payments        supplies that are non-incidental, or conform      market, the term “market” (for normal goods) 
it received due to backup withholding,           to the FSC's treatment of inventories in an       means the current bid price prevailing on the 
include the amount withheld in the total for     applicable financial statement (as defined in     inventory valuation date for the particular 
line 2h. Show the amount withheld in the         section 451(b)(3)), or if the FSC does not        merchandise in the volume usually 
blank space in the right-hand column             have an applicable financial statement, the       purchased by the taxpayer. If section 263A 
between lines 1 and 2h, and write “backup        method of accounting used in the FSC's            applies to the taxpayer, the basic elements of 
withholding.”                                    books and records prepared in accordance          cost must reflect the current bid price of all 
                                                 with the FSC's accounting procedures.             direct costs and all indirect costs properly 
Note. Do not include backup withholding          Changing an accounting method generally           allocable to goods on hand at the inventory 
amounts on line 2g. Include on line 2g only      requires IRS consent. See the Change in           date.
amounts withheld under Chapter 3 or 4 of the     accounting method section, earlier.                 Inventory may be valued below cost when 
Code.                                                                                              the merchandise is unsalable at normal 
                                                 Small business taxpayer.    For tax years         prices or unusable in the normal way 
Line 3. Estimated tax penalty.    A FSC that     beginning in 2023, a FSC qualifies as a small     because the goods are subnormal due to 
does not make estimated tax payments             business taxpayer if (a) it has average annual    damage, imperfections, shop wear, etc. The 
when due may be subject to an                    gross receipts of $29 million or less for the 3   goods may be valued at the bona fide selling 
underpayment penalty for the period of           prior tax years, and (b) is not a tax shelter (as price, minus direct cost of disposition (but 
underpayment. Generally, a FSC is subject to     defined in section 448(d)(3)).                    not less than scrap value). Bona fide selling 
the penalty if its tax liability is $500 or more 
and it did not timely pay at least the smaller   All FSCs should see Section 263A                  price means actual offering of goods during a 
of:                                              uniform capitalization rules in the instructions  period ending not later than 30 days after 
Its tax liability for the current year, or     for Schedule G, later. See those instructions     inventory date.
Its prior year's tax.                          before completing Schedule A.                     Lines 9c and 9d. LIFO method.     If this is 
  Use Form 2220, Underpayment of                 If the FSC uses intercompany pricing              the first year the Last-in, First-out (LIFO) 
Estimated Tax by Corporations, to see if the     rules (for purchases from a related supplier),    inventory method was either adopted or 
FSC owes a penalty and to figure the amount      use the transfer price figured in Part II of      extended to inventory goods not previously 
of the penalty. If Form 2220 is completed,       Schedule P (Form 1120-FSC).                       valued under the LIFO method provided in 
enter the penalty on line 3, Estimated tax                                                         section 472, attach Form 970, Application To 
penalty.                                         Line 1. Inventory at beginning of year.      If   Use LIFO Inventory Method, or a statement 
                                                 the FSC is changing its method of                 with the information required by Form 970. 
                                                 accounting for the current tax year, it must      Also check the LIFO box on line 9c. On 
Schedule A                                       refigure last year's closing inventory using its  line 9d, enter the amount of total closing 
Complete Schedule A only for the cost of         new method of accounting and enter the            inventories computed under section 472. 
goods sold deduction related to foreign          result on line 1. If there is a difference        Estimates are acceptable.
trading gross receipts reported on lines 1       between last year's closing inventory and the 
through 5 of Schedule B.                         refigured amount, attach an explanation and         If the FSC changed or extended its 
                                                 take it into account when figuring the FSC's      inventory method to LIFO and had to write up 
  Complete column (a) to show the cost of        section 481(a) adjustment (explained              the opening inventory to cost in the year of 
goods sold for inventory acquired in             earlier).                                         election, report the effect of the write-up as 
transactions using the administrative pricing                                                      other income (as appropriate on Form 
rules. Complete column (b) to show the cost      Line 4. Additional section 263A costs.       If   1120-FSC, Schedule F, line 16), 
of goods sold for inventory acquired in          the FSC has elected a simplified method of        proportionately over a 3-year period that 
transactions that did not use the                accounting, enter on line 4 the balance of        begins with the year of the LIFO election.

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                      7



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  For more information on inventory              Line 10. All FSCs (except small FSCs) must     Schedule B.
valuation methods, see Pub. 538. For more        answer these questions. On line 10b,           Lines 6b through 6h.    See section 924(b)
information on changes in the method of          indicate how the FSC met the foreign direct    (2)(B) for the rules regarding the limitation on 
accounting for inventory, see Form 3115 and      costs requirement of section 924(d) for all    the amount of foreign trading gross receipts 
the Instructions for Form 3115.                  transactions that generated foreign trading    that a small FSC can take into account in 
                                                 gross receipts reported on lines 1 through 5   determining its exempt foreign trade income.
Additional Information                           of Schedule B. Also, complete line 10a
                                                 and/or line 10d to make an election to use     Line 6d. Temporary Regulations section 
Line 2.  Enter any tax-exempt interest           either of the annual grouping election(s)      1.921-1T(b)(5) indicates that, in the case of a 
received or accrued. Include any                 indicated. See Foreign Economic Process        small FSC having a short tax year, the dollar 
exempt-interest dividends received as a          Rules, earlier, for details.                   limitation reported on line 6b or 6c is to be 
shareholder in a mutual fund or other                                                           prorated on a daily basis. A small FSC 
regulated investment company. Also include                                                      having a short tax year must divide the 
this amount on Schedule M-1, line 7a.            Schedule B                                     number of days in its short tax year by the 
                                                 Use Schedule B to compute taxable income       number of days that would have made up a 
Line 5.  If the FSC owned at least a 10%         from all sources.                              full tax year and enter the resulting fraction 
interest, directly or indirectly, in any foreign 
partnership, attach a statement listing the      Part I                                         on line 6d as a decimal less than 1.00000.
following information for each foreign           Use Part I to compute net income attributable     Example. For its 2023 calendar year tax 
partnership. For this purpose, a foreign         to nonexempt foreign trade income. Income      year, a small FSC has a short tax year of 73 
partnership includes an entity treated as a      and expenses on lines 1 through 15 are         days. The FSC enters 0.20 (73/365) on
foreign partnership under Regulations            reported in column (a) if the administrative   line 6d.
section 301.7701-2 or 301.7701-3.                pricing rules were used in the transaction     Line 6f. If commission income is reported in 
  1. Name and EIN (if any) of the foreign        that produced the income.                      the total for line 6a of Schedule B, total 
partnership;                                                                                    receipts for purposes of line 6f are figured as 
  2. Identify which, if any, of the following      Report in column (b) all foreign trade       follows:
forms the foreign partnership filed for its tax  income from all transactions in which the 
year ending with or within the FSC's tax year:   administrative pricing rules were not used. 
Form 1042, 1065, or 8804;                        Attach a statement that shows the              1. Enter total of columns (a) and 
                                                 computation of the taxable and nontaxable         (b), line 6a, Schedule B . . . .   1.        
  3. Name of the partnership                     income included on line 15, column (b).        2. Enter total commission income 
representative (if any); and                     Include only the taxable amount on line 16.       reported on line 1 and line 2, 
                                                                                                   Schedule B . . . . . . . . . . .   2.        
  4. Beginning and ending dates of the           Nonaccrual experience method for serv-
foreign partnership's tax year.                  ice providers. Accrual method FSCs are         3. Subtract line 2 from line 1. . .   3.        
Line 6.  Generally, if the FSC has a net         not required to accrue certain amounts to be   4. With respect to the commission 
operating loss (NOL) for the current tax year,   received from the performance of services         income reported on line 2 above, 
it can elect to waive the entire carryback       that, based on their experience, will not be      enter total gross receipts on the 
period for the NOL and instead carry the         collected, if:                                    sale, lease, or rental of property 
NOL forward to future tax years. To do so,       The services are in the fields of health,       on which the commission income 
check the box on line 6 and file the tax return  law, engineering, architecture, accounting,       arose (section 927(b)(2)) . . .    4.        
by its due date, including extensions. Do not    actuarial science, performing arts, or 
attach the statement described in Temporary      consulting; or                                 5. Add lines 3 and 4. Enter here and 
Regulations section 301.9100-12T. Generally      The FSC meets the section 448(c) gross          on line 6f, Schedule B . . . . .   5.        
once made, the election is irrevocable.          receipts test for all prior years.
  If the FSC timely filed its return for the       This provision does not apply to any 
loss year without making the election, it can    amount if interest is required to be paid on   Line 6h. When making the line 6h 
make the election on an amended return filed     the amount or if there is any penalty for      allocation, allocate only the commission 
within 6 months of the due date of the loss      failure to timely pay the amount. See          income from the gross receipts on line 4 
year return (excluding extensions). Attach the   Regulations section 1.448-3 for more           above. If the small FSC's foreign trading 
election to the amended return and write         information on the nonaccrual experience       gross receipts for the tax year (line 6f, 
"Filed pursuant to section 301.9100-2" on        method, including information on safe harbor   Schedule B) exceed its allowable limitation 
the election statement. See the Instructions     methods.                                       (line 6e, Schedule B), the small FSC may 
for Form 1139.                                     FSCs that qualify to use the nonaccrual      select the gross receipts to which the 
                                                 experience method should attach a              limitation is allocated. In such a case, 
Line 7.  Enter the amount of the NOL             statement showing total gross receipts, the    allocate the amount on line 6g between 
carryover to the tax year from prior years,      amount not accrued because of the              columns (a) and (b) on line 6h based on 
even if some of the loss is used to offset       application of section 448(d)(5), and the net  whether the administrative pricing rules were 
income on this return. The amount to enter is    amount accrued. Enter the net amount on        used for the gross receipts selected. See 
the total of all NOLs generated in prior years   the applicable line of Schedule B.             Regulations section 1.921-2(b), Q&A-4.
but not used to offset income (either as a                                                      Part II
carryback or carryover) to a tax year prior to   Lines 1 through 5. Enter the foreign trading 
the current tax year. Do not reduce the          gross receipts requested on lines 1 through    Line 19a. Net operating loss deduction. 
amount by any NOL deduction reported on          5. See section 924 and Foreign Trading         A FSC may use the NOL incurred in one tax 
line 19a, Part II, of Schedule B.                Gross Receipts, earlier, for receipts that are year to reduce its taxable income in another 
                                                 excluded and other details. Report             tax year. Enter on line 19a the total NOL 
Lines 8c and 9b(2). See Definition of a          commission income on line 1 or line 2 based    carryovers from other tax years, but do not 
Foreign Sales Corporation (FSC), earlier, for    on the sale, lease, or rental of property on   enter more than the FSC's taxable income 
definitions of qualifying foreign country and    which that commission arose.                   (after the dividends-received deduction). 
U.S. possession.
                                                 Line 5. If the 50% gross receipts test of      Attach a statement showing the computation 
Line 9.  All FSCs (except small FSCs) must       section 924(a)(5) is not met, report the FSC's of the NOL deduction. Also complete line 7 
answer these questions. For more                 gross receipts that would have otherwise       in Additional Information on page 2 of the 
information, see Foreign Management Rules,       qualified under that section on line 16,       form.
earlier.                                         Schedule F, instead of line 5,

8                                                                                           Instructions for Form 1120-FSC (Rev. 1-2024)



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For more details on the NOL deduction,           Part II                                           should receive a notice from the RIC 
see section 172 and the Instructions for Form                                                      specifying the amount of dividends that 
1139.                                            Enter the taxable portion of gross income of      qualify for the deduction.
                                                 the FSC that was not derived from foreign 
Line 19b. Dividends-received deduction.          trading gross receipts. This type of income         Report so-called dividends or earnings 
A FSC may be entitled to a deduction for         includes:                                         received from mutual savings banks, etc., as 
dividends it receives from other corporations.   Small FSCs only. Amounts specifically           interest. Do not treat them as dividends.
Complete the worksheet on page 12 using          excluded from foreign trade income because 
the Instructions for Dividends and               of the small FSC limitation (the amount by 
Dividends-Received Deduction Worksheet,          which line 6f of Schedule B exceeds line 6e       Line 2, Column (a)
later. Attach the completed worksheet to         of Schedule B). (Enter the excess, if any, on 
Form 1120-FSC.                                   line 7 of Schedule F.)                            Enter dividends (except those received on 
Line 20. Taxable income or (loss).  If           Investment type income. (Enter on lines 8       certain debt-financed stock acquired after 
line 20 is zero or less, the FSC may have an     through 12 of Schedule F.)                        July 18, 1984) that are received from 
NOL that may be carried back or forward as       Income from property that is subsidized,        20%-or-more-owned domestic corporations 
a deduction to other tax years.                  deemed in short supply, or destined for use       subject to income tax and that are subject to 
                                                 in the United States. (Enter on lines 13 and      the 65% deduction under section 243(c).
Only farming losses can be carried back.         14 of Schedule F.)
The carryback period for these losses is 2       Amounts from transactions that did not          Line 3, Column (a)
years. For NOLs that can be carried back,        meet the foreign economic process 
the FSC can elect to waive the carryback         requirements. (Enter on line 15 of
period and instead carry the NOL forward to      Schedule F.)                                      Enter the following.
future tax years.                                Other nonforeign trade income. (Enter on        Dividends received on certain 
See the instructions for Additional              line 16 of Schedule F.)                           debt-financed stock acquired after July 18, 
                                                                                                   1984, from domestic and foreign 
Information, line 6, earlier, for information on   For more details, see sections 924(f) and       corporations subject to income tax that 
making the election to waive the entire          927(a)(2) and (3).                                would otherwise be subject to the 
carryback period for farming losses. See the                                                       dividends-received deduction under section 
Instructions for Form 1139 for other special     Line 9. See the Dividends and                     243(a)(1), 243(c), or 245(a). Generally, 
rules and elections.                             Dividends-Received Deduction Worksheet,           debt-financed stock is stock that the FSC 
See section 172 for additional                   later, to figure the total dividends to report on acquired by incurring a debt (for example, it 
information.                                     line 9. Attach the completed worksheet to         borrowed money to buy the stock).
                                                 Form 1120-FSC.                                      Dividends received from a RIC on 
                                                                                                   
Schedule E                                       Line 18. Enter the deductions allocated or        debt-financed stock. The amount of 
For purposes of the Note at the top of           apportioned to line 17 income. Attach to          dividends eligible for the dividends-received 
Schedule E, a C corporation is a corporation     Form 1120-FSC a statement listing each            deduction is limited by section 854(b). The 
other than an S corporation. Shareholders,       type of deduction. Show deductions related        FSC should receive a notice from the RIC 
other than C corporations, are individuals,      to cost of goods sold separately. See the         specifying the amount of dividends that 
partnerships, S corporations, trusts, and        instructions for Schedule A, earlier, before      qualify for the deduction.
estates.                                         completing this line.
Use lines 2a through 2d to figure the            Passive activity limitations. Section 469         Line 3, Columns (b) and (c)
exemption percentage for foreign trade           generally limits the deduction of passive 
income determined by not using the               activity losses for closely held FSCs and         Dividends received on certain debt-financed 
administrative pricing rules. See section        FSCs that are personal service corporations.      stock acquired after July 18, 1984, are not 
923(a)(2).                                       See section 469 and the Instructions for          entitled to the full 50% or 65% 
                                                 Form 8810 for details.                            dividends-received deduction under section 
Use lines 3a through 3d to figure the                                                              243 or 245(a). The 50% or 65% deduction is 
exemption percentage for foreign trade           Instructions for Dividends                        reduced by a percentage that is related to 
income that was determined by using the          and Dividends-Received                            the amount of debt incurred to acquire the 
administrative pricing rules (see section        Deduction Worksheet                               stock. See section 246A. Also, see section 
923(a)(3)). If a qualified cooperative is a                                                        245(a) before making this computation for an 
shareholder of the FSC, see section 923(a)       For purposes of the 20% ownership test on         additional limitation that applies to certain 
(4).                                             lines 1 through 7, the percentage of stock        dividends received from foreign corporations. 
                                                 owned by the FSC is based on voting power         Attach a statement to Form 1120-FSC 
                                                 and value of the stock.
Schedule F                                                                                         showing how the amount on line 3, column 
                                                                                                   (c), was computed.
Part I                                           Line 1, Column (a)
Enter net income from nonexempt foreign                                                            Line 4, Column (a)
trade income and related expenses in Part I.     Enter dividends (except those received on 
                                                 certain debt-financed stock acquired after        Enter dividends received on the preferred 
Line 2. Enter FSC income that resulted from      July 18, 1984–see section 246A) that:             stock of a less-than-20%-owned public utility 
the FSC's cooperation with an international      Are received from less-than-20%-owned           that is subject to income tax and is allowed 
boycott. See section 927(e)(2) and Form          domestic corporations subject to income tax,      the 23.3% deduction provided in sections 
5713 and related schedules and instructions.     and                                               244 and 247 (as affected by P.L. 113-295, 
Line 3. Enter the amount, if any, of illegal     Qualify for the 50% deduction under             Div. A, section 221(a)(41)(A), Dec. 19, 2014, 
payments, bribes, or kickbacks that the FSC      section 243(a)(1).                                128 Stat. 4043) for dividends paid.
paid, directly or indirectly, to government 
officials, employees, or agents. See section       Also include on line 1 dividends (except 
927(e)(2).                                       those received on certain debt-financed           Line 5, Column (a)
                                                 stock acquired after July 18, 1984) from a 
Line 5. See the instructions for Schedule A      regulated investment company (RIC). The           Enter dividends received on preferred stock 
before completing this line.                     amount of dividends eligible for the              of a 20%-or-more-owned public utility that is 
                                                 dividends-received deduction under section        subject to income tax and is allowed the 
                                                 243 is limited by section 854(b). The FSC         26.7% deduction provided in sections 244 

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                     9



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and 247 (as affected by P.L. 113-295, Div. A,  1. Refigure line 18, Part II,                   246(c)(4) and Regulations section 1.246-5 
section 221(a)(41)(A), Dec. 19, 2014, 128          Schedule B (page 3 of Form                  for more details.
Stat. 4043) for dividends paid.                    1120-FSC) without any                         b. Dividends received on any share of 
                                                   adjustment under section 1059               preferred stock that are attributable to 
Line 6, Column (a)                                 and without any capital loss                periods totaling more than 366 days if such 
                                                   carryback to the tax year under             stock was held for less than 91 days during 
Enter the U.S.-source portion of dividends         section 1212(a)(1) . . . . . . .    1.      the 181-day period that began 90 days 
that:                                          2. Multiply line 1 by 65%                       before the ex-dividend date. When counting 
Are received from less-than-20%-owned            (0.65) . . . . . . . . . . . . . .  2.      the number of days the FSC held the stock, 
                                                                                               you may not count certain days during which 
foreign corporations, and                      3. Add lines 2, 5, and 7, column (c),           the FSC's risk of loss was diminished. See 
Qualify for the 50% deduction under              and the part of the deduction on            section 246(c)(4) and Regulations section 
section 245(a). To qualify for the 50%             line 3, column (c), that is                 1.246-5 for more details. Preferred dividends 
deduction, the FSC must own at least 10% of        attributable to dividends from              attributable to periods totaling less than 367 
the stock of the foreign corporation by vote       20%-or-more-owned                           days are subject to the 46-day holding period 
and value.                                         corporations  . . . . . . . . . .   3.      
                                                                                               rule discussed above.
                                               4. Enter the smaller of line 2 or 
Line 7, Column (a)                                 line 3. If line 3 is greater than             c. Dividends on any share of stock to 
                                                   line 2, stop here; enter the                the extent the FSC is under an obligation 
Enter the U.S.-source portion of dividends         amount from line 4 on line 8,               (including a short sale) to make related 
that are received from 20%-or-more-owned           column (c), and do not complete             payments with respect to positions in 
foreign corporations and that qualify for the      lines 5–10 below . . . . . . . .    4.      substantially similar or related property.
65% deduction under sections 243 and           5. Enter the total amount of                      5. Any other taxable dividend income 
245(a).                                            dividends from                              not properly reported elsewhere on the 
                                                   20%-or-more-owned                           Dividends and Dividends-Received 
Line 8, Column (c)                                 corporations that are included on           Deduction Worksheet.
                                                   lines 2, 3, 5, and 7, column                  If patronage dividends or per-unit retain 
Limitation on dividends-received deduc-            (a) . . . . . . . . . . . . . . . . 5.      allocations are included on line 10, identify 
tion. Generally, line 8, column (c), may not   6. Subtract line 5 from line 1  . . .   6.      the total of these amounts in a statement 
exceed the amount on line 10 of the                                                            attached to Form 1120-FSC.
worksheet below. However, in a year in which   7. Multiply line 6 by 50% 
an NOL occurs, this limitation does not apply,     (0.50) . . . . . . . . . . . . . .  7.      
                                                                                               Schedule G
even if the loss is created by the             8. Subtract line 3 above from line 8, 
dividends-received deduction. See sections         column (c)  . . . . . . . . . . .   8.      Limitations on Deductions
172(d) and 246(b).
                                               9. Enter the smaller of line 7 or               Section 263A uniform capitalization 
                                                   line 8. . . . . . . . . . . . . . . 9.      rules. The uniform capitalization rules of 
                                               10. Dividends-received deduction                section 263A require FSCs to capitalize 
                                                   after limitation (sec. 246(b)).             certain costs to inventory or other property.
                                                   Add lines 4 and 9. Enter the                  In general, FSCs subject to the section 
                                                   result here and on line 8, column           263A uniform capitalization rules are 
                                                   (c) . . . . . . . . . . . . . . . . 10.     required to capitalize:
                                                                                                 1. Direct costs of property produced or 
                                                                                               acquired for resale, and
                                                                                                 2. Certain indirect costs (including 
                                               Line 10, Column (a)                             taxes) that are properly allocable to property 
                                                                                               produced or property acquired for resale.
                                               Include the following.
                                                                                                 Indirect costs properly allocable to 
                                               1. Dividends (other than capital gain           property acquired for resale are generally 
                                               distributions reported on Schedule D (Form      those costs in the following categories:
                                               1120) and exempt-interest dividends) that       Off-site storage or warehousing.
                                               are received from RICs and that are not         Purchasing.
                                               subject to the 50% deduction.                   Handling, such as processing, 
                                               2. Dividends from tax-exempt                    assembling, repackaging, and transporting.
                                               organizations.                                  General and administrative costs (mixed 
                                               3. Dividends (other than capital gain           service costs).
                                               distributions) received from a real estate      For details, see Regulations section 
                                               investment trust that, for the tax year of the  1.263A-3(d).
                                               trust in which the dividends are paid,            In general, the FSC cannot deduct the 
                                               qualifies under sections 856 through 860.       costs required to be capitalized under 
                                               4. Dividends not eligible for a                 section 263A until it sells, uses, or otherwise 
                                               dividends-received deduction, which include     disposes of the property (to which the costs 
                                               the following.                                  relate). The FSC recovers these costs 
                                               a. Dividends received on any share of           through depreciation, amortization, or costs 
                                               stock held for less than 46 days during the     of goods sold.
                                               91-day period beginning 45 days before the 
                                               ex-dividend date. When counting the number        A small business taxpayer (defined 
                                               of days the FSC held the stock, you may not     earlier) is not required to capitalize costs 
                                               count certain days during which the FSC's       under section 263A. A small business 
                                               risk of loss was diminished. See section        taxpayer that wants to discontinue 
                                                                                               capitalizing costs under section 263A must 
                                                                                               change its method of accounting. See 

10                                                                                         Instructions for Form 1120-FSC (Rev. 1-2024)



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section 263A(i) and Regulations section          contributed under a salary reduction SEP        Group. See Schedule O and the Instructions 
1.263A-1(j). Also, see the Instructions for      agreement or a SIMPLE IRA plan. See the         for Schedule O for more information.
Form 3115.                                       Instructions for Form 1125-E for more 
For more information on the uniform              information on officers' compensation,          Line 2
capitalization rules, see Pub. 538. Also, see    including any special rules and limitations     FSCs, including FSCs that are qualified 
Regulations sections 1.263A-1 through            that may apply. You are not required to         personal service corporations (as defined in 
1.263A-3.                                        complete Form 1125-E or attach it to Form       section 448(d)(2)), figure their tax by 
                                                 1120-FSC.                                       multiplying taxable income (Schedule B, 
Transactions between related taxpayers.                                                          line 20) by 21%. Enter this amount on line 2.
Generally, an accrual basis taxpayer may         Line 14. Other.   Attach a statement, listing 
only deduct business expenses and interest       by type and amount, all allowable deductions    Line 3
owed to a related party in the year the          that are not deductible elsewhere on Form       If the corporation had gross receipts of at 
payment is included in the income of the         1120-FSC. Enter the total on line 14.           least $500 million in any 1 of the 3 tax years 
related party. See sections 163(e)(3) and          Examples of other deductions include:         preceding the current tax year, complete and 
267(a)(2) for limitations on deductions for      Amortization. See Part VI of Form 4562.       attach Form 8991. Enter on line 3 the base 
unpaid interest and expenses.                    Insurance premiums.                           erosion minimum tax from Form 8991, Part 
Limitations on business interest ex-             Legal and professional fees.                  IV, line 5e. See section 59A and the 
pense.  Business interest expense may be         Supplies used and consumed in the             Instructions for Form 8991.
                                                 business.
limited. See section 163(j) and Form 8990.         Utilities.                                    Line 4
                                                 
Line 1. Enter only foreign direct costs on         Do not deduct:                                A FSC generally enters on line 4 the sum of 
lines 1a through 1e. See section 924(e) and      Amounts paid or incurred to, or at the        Schedule J, lines 2 and 3. However, if the 
Regulations sections 1.924(e)-1(a) through       direction of, a government or governmental      FSC is an applicable corporation under 
(e) for definitions and rules on direct activity entity for the violation, or investigation or   section 59(k) and is subject to the corporate 
costs related to foreign trade income.           inquiry into the potential violation, of a law. alternative minimum tax (CAMT), complete 
Line 5. Salaries and wages. Enter the total      However, see section 162(f) for exceptions to   Form 4626 and attach it to Form 1120-FSC. 
salaries and wages paid for the tax year. Do     the general rule.                               Enter on line 4 the sum of (a) the amount 
not include salaries and wages deductible        Any amount that is allocable to a class of    from Form 1120-FSC, Schedule J, lines 2 
elsewhere on the return, such as amounts         exempt income. See section 265(b) for           and 3, and (b) the amount from Form 4626, 
included in officers' compensation, cost of      exceptions.                                     Part II, line 13.
goods sold, elective contributions to a            See Pub. 542 and the Instructions for         Line 5
section 401(k) cash or deferred                  Form 1120 for details on other deductions 
arrangement, or amounts contributed under        that may apply to corporations.                 Foreign tax credit. Generally, a FSC may 
a salary reduction SEP agreement or a                                                            not claim a foreign tax credit. It may, 
                                                                                                 however, claim a foreign tax credit for any 
SIMPLE IRA plan.                                 Schedule J                                      foreign taxes imposed on foreign source 
Line 10. Compensation of officers.      Enter                                                    taxable nonforeign trade income 
deductible officers' compensation on line 10.    Line 1
                                                                                                 (Schedule F, Part II) that is treated as 
Do not include compensation deductible           If the FSC is a member of a controlled group,   effectively connected with a U.S. trade or 
elsewhere on the return, such as amounts         as defined in section 927(d)(4), it must check  business. See Temporary Regulations 
included in cost of goods sold, elective         the box on line 1 and complete Schedule O       section 1.921-3T(d)(2) for more details.
contributions to a section 401(k) cash or        (Form 1120),Consent Plan and 
deferred arrangement, or amounts                 Apportionment Schedule for a Controlled 

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                 11



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Dividends and Dividends-Received Deduction Worksheet                                                                                  Keep for Your Records
(See Instructions for Dividends and Dividends-Received Deduction Worksheet, earlier.)                                                                    (c) 
                                                                                                                        (a) Dividends             Dividends-received 
                                                                                                                        received       (b) %      deduction: (a) (b) x 
   1 Dividends from less-than-20%-owned domestic corporations (other than 
     debt-financed stock)    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                           50
   2 Dividends from 20%-or-more-owned domestic corporations (other than 
     debt-financed stock)    . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                           65
   3 Dividends on certain debt-financed stock of domestic and foreign corporations 
     (section 246A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                        See Inst.
   4 Dividends on certain preferred stock of less-than-20%-owned public 
     utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                 23.3
   5 Dividends on certain preferred stock of 20%-or-more-owned public 
     utilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .                 26.7
   6 Dividends from less-than-20%-owned foreign corporations . . . . . . . . . . . . . . . .                                               50
   7 Dividends from 20%-or-more-owned foreign corporations      . . . . . . . . . . . . . . . .                                            65
   8 Total dividends-received deduction. Add lines 1 through 7. See instructions for 
     limitation. Enter here and on Schedule B, line 19b . . . . . . . . . . . . . . . . . . . . . .                    
  9  Other dividends from foreign corporations not included on line 3, 6, or 7 . . . . . . .
  10 Other dividends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
  11 Total dividends. Add lines 1 through 10. Enter here and on 
     Schedule F, line 9 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .        

Schedule L                                       If the total adjustment to be entered on                                  the value is over $400 ($1,600 if part of a 
                                               line 27 is a negative amount, enter the                                     qualified plan).
The balance sheet should agree with the        amount in parentheses.                                                      The cost of skyboxes.
FSC's books and records. Include                                                                                             Nondeductible club dues.
certificates of deposit as cash on line 1,                                                                                 
Schedule L.                                    Schedule M-1                                                                The part of luxury water travel expenses 
                                                                                                                           not deductible under section 274(m).
Line 5. Tax-exempt securities. Include on      Line 5c. Travel and entertainment.                                          Expenses for travel as a form of 
this line:                                     Include on line 5c any of the following.                                    education.
State and local government obligations,      Entertainment expenses not deductible                                     Other nondeductible travel and 
the interest on which is excludible from gross under section 274(a).                                                       entertainment expenses.
income under section 103(a), and               Meal expenses not deductible under 
Stock in a mutual fund or other regulated    section 274(n).                                                             Line 7a. Tax-exempt interest. Report any 
investment company that distributed            Expenses for the use of an entertainment                                  tax-exempt interest received or accrued, 
exempt-interest dividends during the tax year  facility.                                                                   including any exempt-interest dividends 
of the FSC.                                    The part of business gifts over $25.                                      received as a shareholder in a mutual fund or 
                                               Expenses of an individual over $2,000,                                    other regulated investment company. Also 
Line 27. Adjustments to shareholders'          that are allocable to conventions on cruise                                 report this same amount on line 2, Additional 
equity. Some examples of adjustments to        ships.                                                                      Information, on page 2 of the form.
report on this line include:                   Employee achievement awards of 
Foreign currency translation adjustments.    nontangible property or of tangible property if 
The excess of additional pension liability 
over unrecognized prior service cost.

12                                                                                                                      Instructions for Form 1120-FSC (Rev. 1-2024)



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Paperwork Reduction Act Notice.    We ask for the information on this form to carry out the Internal Revenue laws of the United States. You 
are required to give us the information. We need it to ensure that you are complying with these laws and to allow us to figure and collect the 
right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form displays 
a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents may become 
material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential, as required by Internal 
Revenue Code section 6103.
The estimated burden for taxpayers filing this form is approved under OMB control number 1545-0123.
If you have comments concerning the accuracy of these time estimates or suggestions for making this form and related schedule simpler, 
we would be happy to hear from you. You can send us comments through IRS.gov/FormComments. Or you can write to the Internal Revenue 
Service, Tax Forms and Publications Division, 1111 Constitution Ave. NW, IR-6526, Washington, DC 20224. Do not send the tax form to this 
address. Instead, see Where To File, earlier, near the beginning of the instructions.

Instructions for Form 1120-FSC (Rev. 1-2024)                                                                                                   13



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Forms 1120-FSC                                                              Using the list of activities and codes below, determine     Once the principal business activity is determined, 
                                                                 from which activity the FSC derives the largest percentage         entries must be made on Form 1120-FSC, page 2, 
Principal Business Activity Codes                                of its “total receipts.” Total receipts is defined as the sum of   Additional Information, lines 1a, 1b, and 1c. For the 
                                                                 the foreign trading gross receipts on Form 1120-FSC,               business activity code number, enter the six digit code 
This list of principal business activities and their associated  page 3, Schedule B, line 6a, and the total income on               selected from the list below. On line 1b, enter a brief 
codes is designed to classify an enterprise by the type of       page 4, Schedule F, lines 4 and 17. If the FSC's largest           description of the FSC's business activity. Finally, enter a 
activity in which it is engaged to facilitate the administration percentage of its total receipts is derived from the               description of the principal product or service of the FSC on 
of the Internal Revenue Code. These principal business           wholesale trading of durable goods, the FSC must use one           line 1c.
activity codes are based on the North American Industry          of the corresponding codes from the list below 
Classification System.                                           (423100-423990).
Wholesale Trade                           424300                 Apparel, Piece Goods, & Notions     513210 Software Publishers                 532210  Consumer Electronics & 
Merchant Wholesalers, Durable Goods       424400                 Grocery & Related Products          Motion Picture and Sound Recording                 Appliances Rental
423100 Motor Vehicle & Motor Vehicle      424500                 Farm Product Raw Materials          Industries                                 532281  Formal Wear & Costume Rental
       Parts & Supplies                   424600                 Chemical & Allied Products          512100 Motion Picture & Video Industries   532282  Video Tape & Disc Rental
423200 Furniture & Home Furnishings       424700                 Petroleum & Petroleum Products             (except video rental)               532283  Home Health Equipment Rental
423300 Lumber & Other Construction        424800                 Beer, Wine, & Distilled Alcoholic   512200 Sound Recording Industries          532284  Recreational Goods Rental
       Materials                                                 Beverages                           Broadcasting, Content Providers, and       532289  All Other Consumer Goods Rental
423400 Professional & Commercial          424910                 Farm Supplies                       Telecommunications                         532310  General Rental Centers
       Equipment & Supplies               424920                 Book, Periodical, & Newspapers      516100 Radio & Television Broadcasting     532400  Commercial & Industrial Machinery 
423500 Metal & Mineral (except Petroleum) 424930                 Flower, Nursery Stock, & Florists'  516210 Media Streaming, Social Networks,           & Equipment Rental & Leasing
423600 Household Appliances and                                  Supplies                                   & Other Content Providers
       Electrical & Electronic Goods      424940                 Tobacco Products & Electronic       517000 Telecommunications (including       Professional Services
423700 Hardware & Plumbing & Heating                             Cigarettes                                 Wired, Wireless, Satellite, Cable & Architectural, Engineering, and Related 
                                                                                                            Other Program Distribution, 
       Equipment & Supplies               424950                 Paint, Varnish, & Supplies                 Resellers, Agents, Other            Services
423800 Machinery, Equipment, & Supplies   424990                 Other Miscellaneous Nondurable             Telecommunications, & Internet      541310  Architectural Services
423910 Sporting & Recreational Goods &                           Goods                                      Service Providers)                  541320  Landscape Architecture Services
       Supplies                           Wholesale Electronic Markets and Agents                    Data Processing Services                   541330  Engineering Services
423920 Toy & Hobby Goods & Supplies       and Brokers                                                518210 Computing Infrastructure            541340  Drafting Services
423930 Recyclable Materials               425120                 Wholesale Trade Agents & Brokers           Providers, Data Processing, Web     541350  Building Inspection Services
                                                                                                            Hosting, & Related Services
423940 Jewelry, Watch, Precious Stone, &  Information                                                519200 Web Search, Rentals, Libraries,     541360  Geophysical Surveying & Mapping 
       Precious Metals                    Publishing Industries (except Internet)                           Archives, & Other Info. Services            Services
                                                                                                                                                541370  Surveying & Mapping (except 
423990 Other Miscellaneous Durable        513110                 Newspaper Publishers                Rental and Leasing                                 Geophysical) Services
       Goods
Merchant Wholesalers, Nondurable          513120                 Periodical Publishers               Rental and Leasing Services                541380  Testing Laboratories
Goods                                     513130                 Book Publishers                     532100 Automotive Equipment Rental &       Other Professional Services
424100 Paper & Paper Products             513140                 Directory & Mailing List Publishers        Leasing                             541600  Management, Scientific, & 
424210 Drugs & Druggists' Sundries        513190                 Other Publishers                                                                       Technical Consulting Services

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