Userid: CPM Schema: instrx Leadpct: 100% Pt. size: 8.5 Draft Ok to Print AH XSL/XML Fileid: … i1120fsc/202401/a/xml/cycle07/source (Init. & Date) _______ Page 1 of 14 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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Extraterritorial Income Exclusion Act of 2000: Extraterritorial Income partner with the National Center for Missing • Repealed the FSC rules; Exclusion .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 . 4 Other Forms That May Be 2004 repealed the extraterritorial income Required .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 |
Page 2 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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) |
Page 3 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 |
Page 4 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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) |
Page 5 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. • 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 |
Page 6 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 6 Instructions for Form 1120-FSC (Rev. 1-2024) |
Page 7 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 |
Page 8 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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) |
Page 9 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 |
Page 10 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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) |
Page 11 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 |
Page 12 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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) |
Page 13 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 |
Page 14 of 14 Fileid: … i1120fsc/202401/a/xml/cycle07/source 16:55 - 24-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 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 14 |