Worksheet A--Foreign Base Company Income and Insurance Income and Summary of U.S. Shareholder's Pro Rata Share of Subpart F Income of a C.F.C.

Worksheet A--Foreign Base Company Income and Insurance Income and Summary of U.S. Shareholder's Pro Rata Share of Subpart F Income of a C.F.C.

Summary: This is an example of worksheet A, which is used to determine the shareholder's share of Subpart F income. The line items to be completed are:

"1. Gross foreign personal holding company income:"
"1a. Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A)) (excluding amounts described in sections 954(c)(2) and (3))" field
"1b. Excess of gains over losses from certain property transactions (section 954(c)(1)(B))" field
"1c. Excess of gains over losses from commodity transactions (section 954(c)(1)(C))" field
"1d. Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D))" field
"1e. Income equivalent to interest (section 954(c)(1)(E))" field
"1f. Net income from a notional principal contract (section 954(c)(1)(F))" field
"1g. Payments in lieu of dividends (section 954(c)(1)(G))" field
"1h. Certain amounts received for services under personal service contracts (see section 954(c)(1)(H)"
"1i. Certain amounts from sales of partnership interests to which the look-through rule of section 954(c)(4) applies"
"2. Gross foreign personal holding company income. Add lines 1a through 1g" field
"3. Gross foreign base company sales income (see section 954(d))" field
"4. Gross foreign base company services income (see section 954(e))" field
"5. Gross foreign base company oil-related income (see section 954(g)) after application of section 954(b)(8)" field
"6. Gross foreign base company income. Add lines 2 through 5" field
"7. Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 22 and 23)" field
"8. Gross foreign base company income and gross insurance income. Add lines 6 and 7" field
"9. Enter 5% of total gross income (as computed for income tax purposes)" field
"10. Enter 70% of total gross income (as computed for income tax purposes)" field
"11. If line 8 is less than line 9 and less than $1 million, enter 0 on this line and skip lines 12 through 21" field
"12. If line 8 is more than line 10, enter total gross income (as computed for income tax purposes)" field
"13. Total adjusted gross foreign base company income and insurance income (enter the greater of line 8 or line 12)" field
"14. Adjusted net foreign personal holding company income:"
"14a. Enter amount from line 2" field
"14b. Expenses directly related to amount on line 2" field
"14c. Subtract line 14b from line 14a" field
"14d. Related person interest expense (see section 954(b)(5))" field
"14e. Other expenses allocated and apportioned to the amount on line 2 under section 954(b)(5)" field
"14f. Net foreign personal holding company income. Subtract the sum of lines 14d and 14e from line 14c" field
"14g. Net foreign personal holding company income excluded under high-tax exception" field
"14h. Subtract line 14g from line 14f" field
"15. Adjusted net foreign base company sales income:"
"15a. Enter amount from line 3" field
"15b. Expenses allocated and apportioned to the amount on line 3 under section 954(b)(5)" field
"15c. Net foreign base company sales income. Subtract line 15b from line 15a" field
"15d. Net foreign base company sales income excluded under high-tax exception" field
"15e. Subtract line 15d from line 15c" field
"16. Adjusted net foreign base company services income:"
"16a. Enter amount from line 4" field
"16b. Expenses allocated and apportioned to line 4 under section 954(b)(5)" field
"16c. Net foreign base company services income. Subtract line 16b from line 16a" field
"16d. Net foreign base company services income excluded under high-tax exception" field
"16e. Subtract line 16d from line 16c" field