Consent To Extend the Time To Assess the Branch Profits 
Form  8848                                                                                                           OMB No. 1545-0123
(Rev. September 2017)          Tax Under Regulations Sections 1.884-2(a) and (c)
Department of the Treasury                 ▶ Attach to the corporation's income tax return. 
Internal Revenue Service              ▶ Go to www.irs.gov/Form8848 for the latest information.
Name of consenting corporation                                                       Employer identification number

Check the box in item A or B below to indicate the reason for filing Form 8848.

  A   If the foreign corporation is filing this form because it has completely terminated all of its U.S. trade or business during the 
      tax year, check here  .   . .   . .  . .          . . . . . . . . . .     . .  . .    . .    .   . . . .     . .  . .     .  ▶

  • Enter the year of complete termination ▶
  B   If the domestic transferee corporation is filing this form because U.S. assets have been transferred to it from a foreign 
      corporation in a section 381(a) transaction during the tax year, check here  . . .    . .    .   . . . .     . .  . .     .  ▶

  • Enter the name, address, and employer identification number of the foreign transferor

  • Enter the date of transfer ▶

The corporation named above and the IRS, pursuant to the regulations under section 884, consent and agree to the following.

1 Any branch profits tax due (relating to the complete termination described in item A above, or the section 381(a) transaction 
  described in item B above) on any income tax return made by or for the above taxpayer for the tax year ended
                            ,     , may be assessed at any time on or before                         ,               (expiration date).

  Note: You must consent to extend the time to assess the tax to a date not earlier than the close of the 6th tax year following the 
  tax year during which the complete termination or section 381(a) transaction occurred.
2 This consent establishes an extended period for assessing the branch profits tax. The expiration of the extended period may be 
  suspended or otherwise affected by the operation of law in the same manner as the original period. For example, if a notice of 
  deficiency in tax covered by this consent is issued, the period for assessing tax will not end prior to the end of the suspension 
  period provided for by section 6503(a), plus any time that remains in the assessment period, as extended, at the time the 
  suspension takes effect. Under no circumstances will this consent reduce the period of time otherwise provided by law for making 
  an assessment.
3 The consenting taxpayer may file a claim for credit or refund for the tax assessed because of this consent within 6 months after 
  the period ends for assessing tax established by this consent.
4 Any  deficiency  assessment  covered  by  this  consent  will  be  limited  to  any  branch  profits  tax  due  relating  to  the  complete 
  termination described in     item A above or the section 381(a) transaction described in  item B above, including any consequential 
  changes to other items based on that adjustment.
5 Complete only for domestic transferee corporations filing Form 8848 under item B above.

  Note: Completing this item satisfies the requirement to attach Form 2045 outlined in Regulations section 1.884-2(c)(2)(iii).
  In consideration of the Commissioner of Internal Revenue not issuing a notice of deficiency to and making an assessment against 
  the above-named foreign transferor, the undersigned, as transferee of assets received from the above-named foreign transferor, 
  assumes and agrees to pay the amounts of any and all federal income or profits taxes finally determined or adjudged as due and 
  payable by such transferor for the tax years ended                                                                                   ,
  to the extent of the liability at law or in equity as transferee within the meaning of section 6901 of the Internal Revenue Code and 
  corresponding provisions of Internal Revenue laws.
      Further: The undersigned agrees, in the absence of prior written consent of the Commissioner of Internal Revenue, not to sell, 
  transfer, or assign without adequate consideration, all or any substantial portion of its assets; and
      Further: The undersigned has, by resolution of its board of directors, been authorized to enter into this agreement and there is 
  attached a copy of the minutes of its board of directors evidencing the authorization and that the terms of this agreement have
  been included in its corporate minutes.
Under penalties of perjury, I declare that I have examined this consent, including accompanying statements and schedules, and to the best of my 
knowledge and belief, it is true, correct, and complete.
Corporate 
Officer’s 
               ▶
Signature
                                                                                     (Title)                         (Date signed)
For Paperwork Reduction Act Notice, see instructions.                     Cat. No. 16321K                          Form 8848 (Rev. 9-2017)

Form 8848 (Rev. 9-2017)                                                                                                  Page 2

Section references are to the Internal Revenue Code unless     Attach Form 8848 to the amended return and write “Filed 
otherwise noted.                                               pursuant to section 301.9100-2” at the top of Form 8848. 
                                                               File the amended return at the same address the original 
Future Developments                                            return was filed.
For the latest information about developments related to 
Form 8848 and its instructions, such as legislation enacted    Specific Instructions
after they were published, go to www.irs.gov/Form8848.
                                                               Signature
General Instructions                                           Form 8848 must be signed by the person authorized to sign 
                                                               the income tax returns for the corporation (including an 
Who Must File                                                  agent authorized to do so under a general or specific power 
• A foreign corporation must file Form 8848 if it has          of attorney). If an agent signs for the corporation, include a 
completely terminated all of its U.S. trade or business        copy of the power of attorney with Form 8848.
according to Temporary Regulations section 1.884-2T(a) 
during the tax year.                                           Paperwork Reduction Act Notice. We ask for the 
• A domestic transferee corporation must file Form 8848 if     information on this form to carry out the Internal Revenue 
U.S. assets have been transferred to it from a foreign         laws of the United States. You are required to give us the 
corporation in a transaction described in section 381(a), if   information. We need it to ensure that you are complying 
the foreign corporation was engaged (or deemed engaged)        with these laws and to allow us to figure and collect the right 
in the conduct of a U.S. trade or business immediately prior   amount of tax.
to the section 381(a) transaction. See Regulations section     You are not required to provide the information requested 
1.884-2(c) and Temporary Regulations section 1.884-2T(c).      on a form that is subject to the Paperwork Reduction Act 
                                                               unless the form displays a valid OMB control number. Books 
When To File                                                   or records relating to a form or its instructions must be 
Form 8848 must be filed on or before the due date (including   retained as long as their contents may become material in 
extensions) prescribed for filing the corporation’s income tax the administration of any Internal Revenue law. Generally, 
return. Attach Form 8848 to the corporation’s return for the   tax returns and return information are confidential, as 
tax year during which the complete termination or section      required by section 6103.
381(a) transaction occurred.                                   The time needed to complete and file this form will vary 
If the corporation timely filed its return for the tax year    depending on individual circumstances. The estimated 
during which the complete termination or section 381(a)        burden for business taxpayers filing this form is approved 
transaction occurred without executing a consent to extend     under OMB control number 1545-0123.
the time to assess the branch profits tax under Regulations    If you have comments concerning the accuracy of these 
sections 1.884-2(a) and (c), the corporation may still execute time estimates or suggestions for making this form simpler, 
the consent by filing an amended return within 6 months of     we would be happy to hear from you. See the instructions 
the due date of the original return (excluding extensions).    for the tax return with which this form is filed.