Worksheets C and D

Worksheets C and D

Summary: These are the worksheets used to calculate a U.S. shareholder's pro rata share in: Worksheet C--Previously Excluded Subpart F Income of a C.F.C. Withdrawn From Qualified Investments in Less Developed Countries and From Qualified Investments in Foreign Base Company Shipping Operations; and Worksheet D--Previously Excluded Export Trade Income of a C.F.C. Withdrawn From Investment in Export Trade Assets. The line items to be completed on each worksheet are:

Worksheet C:
"1. Decrease in qualified investments in less developed countries (see Regulations section 1.955-1(b)(1)) and foreign base company shipping operations (see Regulations section 1.955A-1(b)(1))" field
"2. Limitation (see Regulations section 1.955-1(b)(2)):"
"2a. Enter the sum of E. & P. for the tax year and E. & P. accumulated for prior tax years beginning after 1962" field
"2b. Enter the sum of amounts invested in less developed countries or foreign base company shipping operations and excluded from foreign base company income for all prior tax years, minus the sum of such amounts withdrawn for such years (see Regulations section 1.955-1(b)(2)(i))" field
"3. Enter the smaller of line 2a or line 2b" field
"4. Previously excluded subpart F income withdrawn for the tax year (enter the smaller of line 1 or line 3)" field
"5. U.S. shareholder's pro rata share of line 4 (see Regulations section 1.955-1(c))" field
"6a. Divide the number of days in the tax year that the foreign corporation was a C.F.C. by the number of days in the tax year and multiply the result by line 5" field
"6b. Translate the amount on line 6a from functional currency to U.S. dollars at the average exchange rate. See section 989(b). Enter the result here and on line 3, Schedule I" field
Worksheet D:
"1. Decrease in investments of the C.F.C. in export trade assets (see Regulations section 1.970-1(d)(3))" field
"2. U.S. shareholder's pro rata share of line 1" field
"3. U.S. shareholder's pro rata share of the sum of E. & P. of the C.F.C. for the tax year and E. & P. accumulated for prior tax years beginning after 1962 (see Regulations section 1.970-1(c)(2)(ii))" field
"4. Limitation under section 970(b) (see Regulations section 1.970-1(c)(2)(i)):"
"4a. U.S. shareholder's pro rata share of the sum of the amounts by which the C.F.C.'s subpart F income for prior tax years was reduced under section 970(a)" field
"4b. U.S. shareholder's pro rata share of the sum of the amounts that were not included in subpart F income of the C.F.C. for prior tax years because of Regulations section 1.972-1" field
"4c. Add lines 4a and 4b" field
"4d. U.S. shareholder's pro rata share of the sum of the amounts that were previously included in his or her gross income for prior tax years under section 951(a)(1)(A)(ii) because of section 970(b)" field
"5. Subtract line 4d from line 4c" field
"6. Enter the smallest of line 2, 3, or 5" field
"7a. Divide the number of days in the tax year that the foreign corporation was a C.F.C. by the number of days in the tax year and multiply the result by line 6" field
"7b. Translate the amount on line 7a from functional currency to U.S. dollars at the average exchange rate. See section 989(b). Enter the result here and on line 4, Schedule I" field