Worksheet B--U.S. Shareholder's Pro Rata Share of Earnings of a C.F.C. Invested in U.S. Property

Worksheet B--U.S. Shareholder's Pro Rata Share of Earnings of a C.F.C. Invested in U.S. Property

Summary: This is an example of Worksheet B, used to calculate the U.S. shareholder's share of earnings of a C.F.C. from investment in U.S. property and to translate the amount from functional currency to U.S. dollars. The line items to be completed are:

"1. Amount of U.S. property (as defined in sections 956(c) and (d)) held (directly or indirectly) by the C.F.C. as of the close of:"
"1a. The first quarter of the tax year" field
"1b. The second quarter of the tax year" field
"1c. The third quarter of the tax year" field
"1d. The fourth quarter of the tax year" field
"2. Number of quarter-ends the foreign corporation was a C.F.C. during the tax year" field
"3. Average amount of U.S. property held (directly or indirectly) by the C.F.C. as of the close of each quarter of the tax year. (Add lines 1a through 1d. Divide this amount by the number on line 2.)" field
"4. U.S. shareholder's pro rata share of the amount on line 3" field
"5. U.S. shareholder's earnings and profits described in section 959(c)(1)(A) after reductions (if any) for current year distributions" field
"6. Subtract line 5 from line 4" field
"7. Applicable earnings:"
"7a. Current earnings and profits" field
"7b. Line 7a plus accumulated earnings and profits" field
"8. Enter the greater of line 7a or line 7b" field
"9. Distributions made by the C.F.C. during the tax year" field
"10. Subtract line 9 from line 8" field
"11. Earnings and profits described in section 959(c)(1)" field
"12. Subtract line 11 from line 10" field
"13. U.S. shareholder's pro rata share of the amount on line 12" field
"14. U.S. shareholder's earnings invested in U.S. property. (Enter the smaller of line 6 or line 13)" field
"15. Amount on line 14 that is excluded from the U.S. shareholder's gross income under section 959(a)(2)" field
"16. Subtract line 15 from line 14" field
"17. Translate the amount on line 16 from functional currency to U.S. dollars at the year-end spot rate (as provided in section 989(b)). Enter the result here and on line 2 of Schedule I" field