Fillable F1120fh Accessible 2019 Schedule H (Form 1120-F)

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F1120fh Accessible 2019 Schedule H (Form 1120-F)

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SCHEDULE H
(Form 1120-F)
Department of the Treasury
Internal Revenue Service
Deductions Allocated to Effectively Connected
Income Under Regulations Section 1.861-8
▶
Attach to Form 1120-F.
▶
Go to www.irs.gov/Form1120F for instructions and the latest information.
OMB No. 1545-0123
2019
Name of corporation Employer identification number
Part I Home Office Deductible Expenses Definitely Related Solely to ECI or Non-ECI
Note: Enter all amounts on lines 1a through 13 in only U.S. dollars or in only functional currency. If U.S. dollars, check box
Otherwise, specify currency
▶
.
1a Total expenses on the books of the home office . . . . . . . . . . 1a
b Check the applicable box below to indicate the accounting convention used to
compute the amount on line 1a:
U.S. GAAP Home Country GAAP
IFRS Other (specify)
▶
2 Adjustments for U.S. tax principles (attach statement – see instructions) . . 2
3 Total deductible expenses on the books of the home office. Combine lines 1a and 2 . . . . . . 3
4 Interest expense included on line 3 . . . . . . . . . . . . . . 4
5 Bad debt expense included on line 3 . . . . . . . . . . . . . . 5
6 Total of interest expense and bad debt expense. Add lines 4 and 5 . . . . . . . . . . . . 6
7
Remaining deductible expenses to be allocated and apportioned between ECI and non-ECI. Subtract line 6 from line 3
7
8 Deductible expenses definitely related solely to non-ECI from subsidiaries . 8
9
Deductible expenses definitely related solely to other non-ECI booked in the home country
9
10
Deductible expenses definitely related solely to other non-ECI booked in other
countries (including the United States) . . . . . . . . . . . . .
10
11 Deductible expenses definitely related solely to ECI . . . . . . . . . 11
12 Total deductible expenses definitely related solely to ECI or non-ECI. Add lines 8 through 11 . . .
12
Part II Home Office Deductible Expenses Allocated and Apportioned to ECI
Note: Enter the amounts on lines 15 through 20 in U.S. dollars.
13 Remaining deductible expenses on the books of the home office not definitely related solely to ECI or
non-ECI. Subtract line 12 from line 7 . . . . . . . . . . . . . . . . . . . . . .
13
14 Average exchange rate used to convert amounts to U.S. dollars (see instructions) . . . . . . . 14
15 Enter the amount from line 13. If line 13 is stated in functional currency, divide line 13 by line 14 . . 15
16
Remaining home office deductible expenses on line 15 allocated and apportioned under Regulations
section 1.861-8 to ECI (attach computation) . . . . . . . . . . . . . . . . . . .
16
17 Enter the amount from line 11. If line 11 is stated in functional currency, divide line 11 by line 14 . . 17
18 Total home office deductible expenses allocated and apportioned to ECI. Add lines 16 and 17 . . . 18
19 Total deductible expenses from other non-U.S. locations allocated and apportioned to ECI . . . . 19
20
Total deductible expenses allocated and apportioned to ECI. Add lines 18 and 19 and enter the
amount here and on Form 1120-F, Section II, line 26 . . . . . . . . . . . . . . . .
20
Part III Allocation and Apportionment Methods and Financial Records Used to Complete Parts I and II
Note: Enter the amounts in Part III, lines 21a, 21b, 22a, and 22b in U.S. dollars.
• If one or more methods used are different than in prior year, check box . . . . . . . . . . . . . . . . . .
•
If any amount on line 20 is recorded as an interbranch amount on books and records used to prepare Form 1120-F,
Schedule L, include the amount on Part IV, line 35 and check this box . . . . . . . . . . . . . . . . . .
21 Gross income ratio:
a Gross ECI . . . . . . . . . . . . . . . . . . . . . . 21a
b Worldwide gross income . . . . . . . . . . . . . . . . . . 21b
c Divide line 21a by line 21b . . . . . . . . . . . . . . . . . . . . . . . . . 21c
%
22 Asset ratio:
a Average U.S. assets from Schedule I, line 5, column (d) . . . . . . . 22a
b Worldwide assets (if applicable, from Schedule I, line 6b) . . . . . . . 22b
c Divide line 22a by line 22b . . . . . . . . . . . . . . . . . . . . . . . . . 22c
%
23 Number of personnel ratio:
a Personnel of U.S. trade or business . . . . . . . . . . . . . . 23a
b Worldwide personnel . . . . . . . . . . . . . . . . . . . 23b
c Divide line 23a by line 23b . . . . . . . . . . . . . . . . . . . . . . . . . 23c
%
24 Did the corporation use any ratio-based methods (other than those indicated on lines 21 through 23 above) in
Parts I and II? If “Yes,” attach statement (see instructions) . . . . . . . . . . . . . . . . . .
Yes No
25 Did the corporation use any other methods (e.g., time-spent analysis or estimates) in Parts I and II? If “Yes,”
attach statement (see instructions). . . . . . . . . . . . . . . . . . . . . . . . . .
For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.
Cat. No. 49679V Schedule H (Form 1120-F) 2019
Schedule H (Form 1120-F) 2019
Page 2
Part III Allocation and Apportionment Methods and Financial Records Used to Complete
Parts I and II (continued)
Note: Indicate whether the corporation used any of the following financial and other records in Parts I and II
to identify deductible expenses allocated and apportioned to ECI.
Yes No
26a Published or other non-public audited financial statements . . . . . . . . . . . . . . . . . .
b Non-audited financial statements . . . . . . . . . . . . . . . . . . . . . . . . . . .
27 Home office management or other departmental cost accounting reports . . . . . . . . . . . . . .
28 Other (e.g., home country regulatory reports or written, contemporaneous functional analyses) (attach statement)
Part IV
Allocation and Apportionment of Expenses on Books and Records Used to Prepare Form 1120-F, Schedule L
Note: Enter all amounts in Part IV in U.S. dollars.
29
Total expenses per books and records used to prepare Form 1120-F,
Schedule L . . . . . . . . . . . . . . . . . . . . . . 29
30 Adjustments for U.S. tax principles (attach statement – see instructions) . . 30
31 Total deductible expenses. Combine lines 29 and 30 . . . . . . . . . . . . . . . . 31
32a Third-party interest expense included on line 31 . . . . . . . . . . 32a
b Interbranch interest expense included on line 31 . . . . . . . . . . 32b
33 Bad debt expense included on line 31 . . . . . . . . . . . . .
33
34
Other third-party deductible expenses not allocated or apportioned to ECI and
non-ECI under Regulations section 1.861-8 included on line 31 (attach
statement). . . . . . . . . . . . . . . . . . . . . . . 34
35 Interbranch expenses per books and records included on line 31 and not
included on line 32b (attach statement) . . . . . . . . . . . . . 35
36 Add lines 32a through 35 . . . . . . . . . . . . . . . . . . . . . . . . . 36
37
Deductible expenses on books and records allocated and apportioned to ECI or non-ECI under
Regulations section 1.861-8. Subtract line 36 from line 31 . . . . . . . . . . . . . . .
37
Reconciliation of allocation and apportionment of deductible
expenses to ECI and non-ECI on books and records under
Regulations section 1.861-8 (from line 37)
(a)
ECI Amounts
(b)
Non-ECI Amounts
(c)
Total: Add columns
(a) and (b)
38a Derivative transaction deductible expenses definitely related to
ECI or non-ECI under Regulations section 1.861-8 (from line 37) . 38a
b Other deductible expenses definitely related to ECI or non-ECI
(from line 37) . . . . . . . . . . . . . . . . . . 38b
39 Total deductible expenses definitely related to ECI or non-ECI.
Add lines 38a and 38b . . . . . . . . . . . . . . 39
40
Other deductible expenses on books and records not definitely
related to ECI or non-ECI that are allocated and apportioned to
ECI and non-ECI (from line 37) . . . . . . . . . . . . 40
41
Total deductible expenses on books and records allocated and
apportioned to ECI and non-ECI. Add lines 39 and 40. Column (c)
must equal line 37 . . . . . . . . . . . . . . . . 41
Note: Line 41, column (a) is the total of the deductions reported on Form 1120-F, Section II, lines 12, 13, 14, 16, 17, 19 through
24, and 27.
Schedule H (Form 1120-F) 2019
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F1120fh Accessible 2019 Schedule H (Form 1120-F)

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Completed 17 May 2020

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