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                                                                                       Department of the Treasury
Instructions for Form 8902                                                             Internal Revenue Service

(Rev. September 2017)
Alternative Tax on Qualifying Shipping Activities

Section references are to the Internal  Such vessel is owned by, or              The vessel is used as a qualifying 
Revenue Code unless otherwise noted.    chartered (including a time charter) to, vessel by the person to whom 
                                        the person, or the person provides       ultimately chartered.
Future Developments                     services for such vessel pursuant to 
                                                                                 U.S. foreign trade.  The term “U.S. 
                                        an operating agreement; and
                                                                                 foreign trade” means the 
For the latest information about        Such vessel is in use as a qualifying 
                                                                                 transportation of goods or passengers 
developments related to Form 8902       vessel during such period.
and its instructions, such as                                                    between a place in the United States 
legislation enacted after they were     Qualifying vessel. A self-propelled      and a foreign place or between 
published, go to IRS.gov/Form8902.      (or combination self-propelled and       foreign places.
                                        non-self-propelled) U.S. flag vessel of  See section 1355 for more 
                                        not less than 6,000 deadweight tons 
General Instructions                                                             definitions and special rules that apply 
                                        used exclusively in the U.S. foreign     with respect to the above definitions.
Purpose of Form                         trade during the period the election is 
                                        in effect.
Form 8902 is used by qualifying                                                  Partnerships and Other 
vessel operators (defined below) who    Shipping activity requirement.     A     Pass-Through Entities
are making an alternative tax election  corporation meets this requirement for   In applying these rules to a partner in 
under section 1354(a) or who have       any tax year only if the following       a partnership:
made such an election previously.       requirement is met for each of the 2     Each partner is treated as operating 
The form is used to make such an        preceding tax years: On average          vessels operated by the partnership;
election or report the termination of   during the tax year, at least 25% of the Each partner is treated as 
such an election, to report information aggregate tonnage of qualifying          conducting the activities conducted by 
relating to such an election, and to    vessels used by the corporation was      the partnership; and
compute the alternative tax.            owned by such corporation or             The extent of a partner's ownership, 
                                        chartered to such corporation on         charter, or operating agreement 
Who Must File                           bareboat charter terms (see definition   interest in any vessel operated by the 
Form 8902 must be filed by a            below).                                  partnership will be determined on the 
                                                                                 basis of the partner's interest in the 
qualifying vessel operator (defined     Special rule for first year of 
                                                                                 partnership.
below) who is making an alternative     election. A corporation meets this 
tax election under section 1354(a) or   requirement for the first tax year for   A similar rule applies to other 
who is reporting the termination of     which this election is in effect only if pass-through entities.
such an election. The form must also    this requirement is met for the 
be used by a qualifying vessel          preceding tax year.
operator who has a valid election in                                             Specific Instructions
effect to report information pertaining Controlled groups. A corporation 
to that election and to compute the     that is a member of a controlled group   Part I. Section 1354 
alternative tax.                        meets this requirement only if such      Election or Termination
                                        requirement is met when determined 
How To File                             by treating all members of such group    Item B
File Form 8902 by attaching it to the   as one person.                           A corporation must make the 
corporation's Form 1120 or Form         Bareboat charters. A person is           alternative tax election on or before 
1120-F.                                 treated as operating and using a         the due date (including extensions of 
                                        vessel that it has chartered out on      time to file) of the income tax return for 
Definitions                             bareboat charter terms only if:          the tax year for which the election is 
Qualifying vessel operator.    The      The vessel is (a) temporarily            made.
term “qualifying vessel operator”       surplus to the person's requirements     Election by a member of a control-
means any corporation that operates     and the term of the charter does not     led group.  An election under section 
one or more qualifying vessels and      exceed 3 years, or (b) bareboat          1354(a) by a member of a controlled 
meets the shipping activity             chartered to a member of a controlled    group applies to all qualifying vessel 
requirement. See the definitions of     group which includes such person or      operators that are members of such 
these terms below.                      to an unrelated person who               group.
                                        sub-bareboats or time charters the 
Operating a vessel. Except as           vessel to such a member (including       Item C
provided in the definition of bareboat  the owner of the vessel); and            Generally, a revocation of an election 
charters below, a person is treated as                                           under section 1354(a) made:
operating any vessel during any 
period if:

May 02, 2017                                      Cat. No. 39897X



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On or before the 15th day of the 3rd      not exceed 20% of the gross income        $20 million) on line G(2)(a), and $1 
month of the tax year will be effective   derived by the corporation from its       million (gross income from secondary 
on the 1st day of that tax year.          core qualifying activities.               activities of $5 million less the $4 
After the 15th day of the 3rd month                                                 million limit) on line G(2)(b).
                                          Secondary activities.       The term 
of the tax year will be effective the 1st                                           Example 2.       The same facts as 
                                          "secondary activities" means:
day of the following tax year.                                                      above except the corporation has 
                                          The active management or 
However, if the revocation specifies  operation of vessels other than               gross income from secondary 
a date for revocation that is on or after qualifying vessels in the U.S. foreign    activities of $3 million. The 
the day on which the revocation is        trade;                                    corporation would enter $3 million on 
made, the revocation will be effective    The provision of vessel, barge,           line G(2)(a) and zero on line G(2)(b). 
for tax years beginning on and after      container, or cargo-related facilities or Gross income from secondary 
the date of revocation specified.         services to any person; and               activities of $3 million is less than the 
                                          Other activities of the electing          $4 million limit.
Item D                                    corporation and other members of its      Line G(3). Qualifying Incidental 
An election under section 1354(a) will    electing group that are an integral part 
                                                                                    Activities
be terminated effective on and after      of its business of operating qualifying 
the date the corporation ceases to be     vessels in U.S. foreign trade,            For purposes of this election, the term 
a qualifying vessel operator.             including:                                “qualifying incidental activities” means 
                                                                                    shipping-related activities if:
Election after termination.    If a       1. Ownership or operation of 
qualifying vessel operator made the       barges, containers, chassis, and other    1. They are incidental to the 
election under section 1354(a) and        equipment that are the complement         corporation's core qualifying activities,
subsequently revoked the election         of, or used in connection with, a         2. They are not qualifying 
(Item C) or ceased to be a qualifying     qualifying vessel in U.S. foreign trade;  secondary activities, and
vessel operator (Item D), that operator   2. The inland haulage of cargo            3. The gross income derived by 
(and any successor operator) is not       shipped, or to be shipped, on             the corporation from such activities 
eligible to make another section          qualifying vessels in U.S. foreign        does not exceed 0.1% of the 
1354(a) election for any tax year         trade; and                                corporation's gross income from its 
before the fifth tax year that begins                                               core qualifying activities.
                                          3. The provision of terminal, 
after the first tax year for which the 
                                          maintenance, repair, logistical, or 
termination is effective, unless the IRS                                            Line G(3)(a). Amount included in 
                                          other vessel, barge, container, or 
consents to the election.                                                           the 0.1% limit.  Enter on line G(3)(a) 
                                          cargo-related services that are an 
                                          integral part of operating qualifying     the corporation's gross income from 
Part II. Other Information                vessels in U.S. foreign trade.            incidental activities that does not 
                                                                                    exceed 0.1% of line G(1).
Question E                                The term “secondary activities” 
The term “electing group” means a         does not include any core qualifying      Electing groups. In the case of an 
controlled group of which one or more     activities.                               electing group, the above rules are 
                                                                                    applied as if the group were one 
members is an electing corporation.       Line G(2)(a). Amount included in          entity, and the 0.1% limitation is 
The term “controlled group” means         20% limit.  Enter on line G(2)(a) the     allocated among the corporations in 
any group which would be treated as       corporation's gross income from           the group.
a single employer under section 52(a)     secondary activities that does not 
or (b) if sections 52(a)(1) and (2) did   exceed 20% of line G(1).                  Line G(3)(b). Amount that exceeds 
                                                                                    the 0.1% limit.  Enter on line G(3)(b) 
not apply.                                Electing groups.      In the case of an   the corporation's gross income from 
Line G(1). Core Qualifying                electing group, the above rules are       incidental activities that exceeds 0.1% 
                                          applied as if the group were one 
Activities                                                                          of line G(1).
                                          entity, and the 20% limitation is 
Enter on line G(1) the corporation's      allocated among the corporations in       Attach a schedule showing 
gross income from core qualifying         the group.                                computations for lines G(3)(a) and (b).
activities. Attach a schedule.
                                          Line G(2)(b). Amount that exceeds         Line H. Gross Income From 
For purposes of this election, the        the 20% limit. Enter on line G(2)(b)      Qualifying Shipping Activities 
term “core qualifying activities” means   the corporation's gross income from       Excluded From Gross Income 
activities in operating qualifying        secondary activities that exceeds         on the Corporation's Income 
vessels in U.S. foreign trade.            20% of line G(1).                         Tax Return
Line G(2). Qualifying                     Attach a schedule showing                 Enter on line H the total of lines G(1), 
Secondary Activities                      computations for lines G(2)(a) and (b).   G(2)(a), and G(3)(a). Do not include 
For purposes of this election, the term   Example 1.     The corporation has        this amount in gross income on the 
"qualifying secondary activities"         gross income from core qualifying         corporation's Form 1120 or Form 
means secondary activities (defined       activities of $20 million and gross       1120-F. Furthermore, do not include 
below) but only to the extent that the    income from secondary activities of       on the corporation's Form 1120 or 
gross income derived by the               $5 million. The corporation enters $20    Form 1120-F any item of loss, 
corporation from such activities does     million on line G(1), $4 million (20% of 

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deduction, or credit with respect to     the sum of all columns of Part IV,      Part IV. Notional Shipping 
this line H excluded income.             line 28.
                                                                                 Income
Note. The amounts entered on lines       Line 9. Type of Ownership
                                                                                 Line 21. Ownership Percentage
G(2)(b) and G(3)(b) must be included     Indicate in each column the type of 
                                                                                 Enter the corporation's percentage of 
in gross income on the corporation's     ownership for the vessel. Enter “O” for 
                                                                                 ownership in the vessel. If, for any 
Form 1120 or Form 1120-F.                an owned vessel, “L” for a leased 
                                                                                 period, two or more persons are 
                                         vessel, and “CL” for a capitalized 
                                                                                 operators of a qualifying vessel, the 
Part III. Vessel Information             lease.
                                                                                 notional shipping income from the 
With respect to Parts III and IV,        Line 10. Type of Vessel Use             operation of such vessel for that 
complete a separate column for each                                              period must be allocated among the 
qualifying vessel. If the corporation    Indicate in each column the type of 
has more than four qualifying vessels,   vessel use. Enter “BB” for bareboat     operators on the basis of their 
attach separate sheets for Parts III     charter out, “TC” for time charter out, respective ownership, charter, and 
and IV using the same size and format    and “OI” for operating income.          operating agreement interests in the 
                                                                                 vessel.
as Form 8902. Also, on line 29, enter 

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Instructions for Form 8902 (Rev. 9-2017)                      -3-






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