Clarification Concerning Completion of Tax Year 2020 Form 1118, Schedule D


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

While multiple line entries may be necessary for Schedule D, Part I, because such lines are completed for each CFC, in general, only one line will be completed in Schedule D, Part II, because the domestic corporation filing Form 1118 only has one section 951A inclusion. However, there is an exception if Form 1118 is completed by an individual (or by an estate or trust) that has made an election under section 962 ("section 962 elector") and the section 962 elector is a shareholder of an S corporation that has made an election to treat the S corporation as an entity (rather than as an aggregate of its owners), as provided in Notice 2020-69, 2020-39 I.R.B. 604, on a timely (including extensions) filed original Form 1120-S with respect to the first tax year ending on or after September 1, 2020. In this case, the section 962 elector may have more than one section 951A inclusion that will be reported on separate lines on Schedule D, Part II. There might be multiple lines as a result of (1) the section 962 elector's section 951A inclusion and (2) the section 962 elector's share of the section 951A inclusion of the S corporation. There also could be multiple lines if the section 962 elector has an interest in more than one S corporation.