Free 2008 Form 1120-F (Schedule I) - Federal

SCHEDULE I (Form 1120-F)
Department of the Treasury Internal Revenue Service

Interest Expense Allocation Under Regulations Section 1.882-5
Attach to Form 1120-F. See separate instructions.

OMB No. 1545-0126

2008
Employer identification number

Name of corporation

A B

Check here if the corporation is a foreign bank as defined in Temporary Regulations section 1.882-5T(c)(4) This Schedule I is being completed with respect to (check one): Adjusted U.S. booked liabilities method under Regs. sec. 1.882-5(d). Complete lines 1 through 15 and 21 through 25. Separate currency pools method under Regs. sec. 1.882-5(e). Complete lines 1 through 9 and 16a through 25.

Step 1
1

Average U.S. Assets for the Tax Year: Regulations Section 1.882-5(b)
(a) Set(s) of Books that Give Rise to U.S. Booked Liabilities (see inst.) (b) Partnership Interests (c) Set(s) of Books Other than those Described in Columns (a) and (b) (d) Totals. Add columns (a) through (c)

Specify the method used to determine the value of the corporation's U.S. assets on lines 2 through 5 below (check one): Adjusted basis method: Regs. sec. 1.882-5(b)(2)(i) Fair market value method: Temp. Regs. sec. 1.882-5T(b)(2)(ii)

2

Total assets per books b Total non-ECI assets under section 864(c)(4)(D) c Total other non-ECI assets d Adjustments for amounts from partnerships and certain disregarded entities included on line 2, column (a) e Adjustments for assets that give rise to direct interest expense allocations under Regs. sec. 1.882-5(a)(1)(ii) f Other adjustments to average assets included in line 2 (e.g., mark-to-market differences) Combine lines 3a through 3f Total value of U.S. assets for the tax year Column (a): Subtract line 4 from line 2. Column (b): Enter total from Schedule P, line 19. Column (c): See instructions for amount to enter.

3a Total interbranch assets

4 5

Step 2
6

U.S.-Connected Liabilities for the Tax Year: Regulations Section 1.882-5(c)
Actual ratio under Regs. sec. 1.882-5(c)(2). Complete lines 6a through 6c below. Fixed ratio under Temp. Regs. sec. 1.882-5T(c)(4). Complete line 6d below.

Specify the method used to determine the amounts in Step 2 (check one):

a Average worldwide liabilities b Average worldwide assets c Divide line 6a by line 6b d Fixed ratio under Temp. Regs. sec. 1.882-5T(c)(4). If the corporation is a foreign bank as defined in Temp. Regs. sec. 1.882-5T(c)(4), enter 95% on line 6d. If the corporation is not a foreign bank, enter 50% on line 6d e Enter the ratio from line 6c or 6d, as applicable 7a U.S.-connected liabilities before Regs. sec. 1.884-1(e)(3) election(s). Multiply line 5, column (d) by line 6e b Total amount of U.S. liability reduction under Regs. sec. 1.884-1(e)(3) election(s) c U.S.-Connected Liabilities. Subtract line 7b from line 7a %

%

%

Step 3

Interest Expense Paid or Accrued on Average U.S. Booked Liabilities: Regulations Section 1.882-5(d)
(a) Set(s) of Books that Give Rise to U.S. Booked Liabilities (see inst.) (b) Partnership Interests (c) Totals. Add columns (a) and (b)

8

Total average amount of U.S. booked liabilities as defined in Regs. sec. 1.882-5(d)(2) (see instructions) Column (a): Do not include amounts that give rise to directly allocable interest under Regs. sec. 1.882-5(a)(1)(ii) or from partnerships includible in column (b). Column (b): Enter the total from Schedule P, line 17.

9

Total interest paid or accrued during the tax year on line 8 amount Column (a): Do not include amounts that give rise to directly allocable interest under Regs. sec. 1.882-5(a)(1)(ii) or from partnerships includible in column (b). Column (b): Enter the total from Schedule P, line 14c.
Cat. No. 49680W

Schedule I (Form 1120-F) 2008

Schedule I (Form 1120-F) 2008

Page

2

Step 3 (cont.)

Adjusted U.S. Booked Liabilities Method: Regulations Section 1.882-5(d)

If line 7c is greater than line 8, column (c), complete lines 10 through 13 below and skip lines 14a and 14b. If line 7c is less than or equal to line 8, column (c), skip lines 10 through 13 and complete lines 14a and 14b. 10 If the corporation is a foreign bank which is making a current-year election to use the published average 30-day LIBOR (see instructions), check the box on this line, skip lines 10a through 10c, and enter the rate on line 10d a Total interest paid or accrued during the tax year on U.S. dollar liabilities that are not U.S. booked liabilities included on line 8 b Average U.S. dollar denominated liabilities that are not U.S. booked liabilities included on line 8 c Divide line 10a by line 10b d Enter the 30-day LIBOR rate, if elected under Temp. Regs. sec. 1.882-5T(d)(5)(ii)(B) e Enter the rate from line 10c or, if elected, the 30-day LIBOR rate on line 10d 11 12 13 14a 15 Excess U.S.-connected liabilities. Subtract line 8 from line 7c Excess interest. Multiply line 10e by line 11 Add lines 9, column (c) and 12 Scaling ratio. Divide line 7c by line 8, column (c) Interest expense allocable to ECI under the adjusted U.S. booked liabilities method. Enter the result from line 13 or line 14b here and on line 21 b Multiply line 9, column (c) by line 14a. See instructions for hedging amounts 10a 10b 10c 10d

% %
10e 11 12 13 14a 14b 15
(d) Other Currency. Specify:

%

%

Step 3 (cont.)

Separate Currency Pools Method: Regulations Section 1.882-5(e)
(a) U.S. Dollar Denominated (b) Home Country Currency. Specify: (c) Other Currency. Specify:

16a

U.S. assets. Enter the corporation's U.S. assets, using the methodology in Regs. sec. 1.882-5(e)(1)(i). If more columns are needed, attach schedule (see instructions)

b Check here if a less than 3% currency election was made 17a Enter the percentage from line 6e

%

%

%

%

b U.S.-connected liabilities. Multiply line 16a by line 17a, or, if a liability reduction election is made, see instructions 18a Enter the total interest expense paid or accrued for the tax year with respect to the foreign corporation's worldwide liabilities denominated in that foreign currency (enter in functional currency)

b Enter the corporation's average worldwide liabilities (whether interest bearing or not) denominated in that foreign currency (enter in functional currency) c Borrowing rate: Divide line 18a by line 18b 19 20 Interest expense allocation by separate currency pool. Multiply line 17b by line 18c Interest expense allocable to ECI under the separate currency pools method. Total the amounts on line 19, columns (a) through (d), and amounts from attached schedule, if any, and enter the result here and on line 21

%

%

%

%

SUMMARY--Interest Expense Allocation and Deduction under Regulations Section 1.882-5
21 22 23 24a Amount from line 15 or line 20, as applicable Enter the corporation's interest expense directly allocable under Temp. Regs. sec. 1.882-5T(a)(1)(ii). (Include total from Schedule P, line 14b.) Amount of line 23 that is disallowed as a deduction under section 265 or under an income tax treaty (attach schedule--see instructions) 21 22 23

Interest expense allocable to ECI under Regs. sec. 1.882-5. Add lines 21 and 22 24a ( 24b 24c (

)

b Deferred interest expense under section 163(e)(3), 163(j), or 267(a)(3) (attach schedule--see instructions) c Amount of line 23 that is capitalized under section 263A (attach schedule--see instructions) d Combine lines 24a through 24c 25

)
24d

Total interest expense deduction under Regs. sec. 1.882-5. Combine lines 23 and 24d and enter here and on Form 1120F, Section II, line 18. The amount entered on line 25 may not exceed the total interest expense paid or accrued by the foreign corporation

25
Schedule I (Form 1120-F) 2008