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Tax Reform Guidance for 1120 filers -- 09-APR-2018

For 1120-L filers

Section 245A DRD - Enter the foreign source portion of dividends received from specified 10-percent owned foreign corporations for which a deduction is allowed under section 245A (including amounts treated as dividends under section 964(e)(4), but excluding hybrid dividends defined in section 245A(e)(4)) on Form 1120-L, Schedule A, Line 13, column (a), and the same amount in column (c), without regard to whether the foreign subsidiary is an affiliated group member.  

For 1120-PC filers

Section 245A DRD - Enter the foreign source portion of dividends received from specified 10-percent owned foreign corporations for which a deduction is allowed under section 245A (including amounts treated as dividends under section 964(e)(4), but excluding hybrid dividends defined in section 245A(e)(4)) on Form 1120-PC, Schedule C, Line 13, without regard to whether the foreign subsidiary is an affiliated group member. Include the 245A amount in the total on line 25.

For all 1120 filers

Section 245A DRD - Enter the foreign source portion of dividends received from specified 10-percent owned foreign corporations for which a deduction is allowed under section 245A (including subpart F inclusions treated as dividends under section 964(e)(4), but excluding hybrid dividends defined in section 245A(e)(4)) on Form 1120, Schedule C, Line 11, without regard to whether the foreign subsidiary is an affiliated group member.

Section 245A(e) Hybrid Dividend Subpart F Inclusion - Enter subpart F inclusions attributable to hybrid dividends from tiered corporations under section 245A(e)(2) as other income and attach a statement explaining the amount of the inclusion. For Form 1120 filers, enter the amount on Page 1, Line 10. No credit or deduction with respect to foreign taxes paid or accrued is allowed pursuant to section 245A(e)(3). The statement should also identify the relevant controlled foreign corporations and the amount of income reported as other income that otherwise would be reported as subpart F income on Schedule C, Line 14 (for a Form 1120 filer).

Section 904 - Treatment of Dividends for Which Section 245A Deduction Allowed - Enter the adjustments to total taxable income required by section 904(b)(5) in respect of section 245A dividends paid in 2018 on Form 1118, Schedule B, Part II, line 8b, and the section 904 numerator adjustment to foreign source taxable income should be reflected on Schedule A, line 9d (other definitely allocable deductions). 

Section 91 Transferred Branch Loss Recapture - Enter the transferred loss amount required to be recognized under section 91 resulting from a transfer of substantially all the assets of a foreign branch (within the meaning of section 367(a)(3)(C), as in effect before its repeal) to a foreign corporation with respect to which you were a United States shareholder immediately after the transfer as other income on the applicable Form 1120 (for Form 1120 filers, Page 1, Line 10, Other Income) and attach a statement of the calculation of the income required to be recognized pursuant to section 91. Under section 91(d), transferred loss amounts recognized are treated as derived from sources within the United States.    
 
Section 961(d) Disallowance of Loss Attributable to Section 245A DRD - Enter code L in column (f) of Form 8949 and indicate the disallowed portion of the loss in column (g) in the appropriate table to report any basis adjustment under section 961(d) on the disposition of stock of a specified 10-percent owned foreign corporation from which you previously received a dividend for which a deduction was allowed under section 245A.