1120-FSC U. S. Income Tax Return of a Foreign Sales Corporation

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Form

1120-FSC

U.S. Income Tax Return of a Foreign Sales Corporation
For calendar year 20

(Rev. November 2018)
Department of the Treasury
Internal Revenue Service

, 20

or other tax year beginning

,

OMB No. 1545-0123

and ending
, 20
▶ Go to www.irs.gov/Form1120FSC for instructions and the latest information.

A Foreign country or U.S.
possession of incorporation
(see instructions)

C Employer identification number

Name

D Date incorporated

DRAFT AS OF
September 4, 2018
DO NOT FILE

B Check type of election made:

FSC
Small FSC
Enter the effective date of
the election:

Number, street, and room or suite no. (see instructions)

E Total assets (see instructions)

City or town, state, and ZIP code

F Check applicable boxes:

(1)

Final return

(2)

$

Name change

(3)

(4)

Address change

Amended return

FSC Information

1 Principal shareholder. Complete for the shareholder that was the principal shareholder at the beginning of the FSC’s tax year. If two or more shareholders
own equal amounts of stock, complete for the shareholder that has the same tax year as the FSC (see instructions).
a Name

b Identification number

c Address (number, street, and room or suite no., city or town, state, ZIP code, or country)

d Total assets (corporations only)

e Percentage of voting stock of the
principal shareholder

f Tax year ends (month and year)

$
h Foreign owner? (check one)

g Service Center where tax return is filed

%

2 Parent-subsidiary controlled group. Is the FSC a subsidiary in a parent-subsidiary controlled group? .

.

.

.

.

.

▶

Yes

No

Yes

No

If “Yes,” and the principal shareholder (described in 1 above) is not the common parent of the group, complete
lines 2a through 2g below for the common parent (see instructions).
b Identification number

a Name of common parent

c Address (number, street, and room or suite no., city or town, state, ZIP code, or country)

d Total assets (consolidated, if applicable)

e Percentage of voting stock of the common parent

$
g Service Center where tax return is filed

f Tax year ends (month and year)
%

3 Administrative pricing rules
a Check the applicable box(es) to show the pricing rule(s) used to determine taxable income on transactions resulting in foreign trading gross receipts.
(1)

1.83% of foreign trading gross receipts

(2)

23% of combined taxable income

(4)

Section 482 method

(5)

Transactions at arm’s length with unrelated supplier(s)

(3)

Marginal costing

b If the FSC and the related supplier(s) meet the payment rules of Temporary Regulations section 1.925(a)-1T(b)(2)(ii) and elect to use the administrative
pricing rules, check here
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .▶

Tax and Payments (see instructions)
1
2

Total tax (Schedule J, line 6) . . . . . . . . . . . . . . . . . . . . . . .
Payments:
a Overpayment from prior year allowed
as a credit . . . . . . . .
2a
b Current year estimated tax payments
2b
c Less refund of overpaid estimated
) d Bal ▶ 2d
tax applied for on Form 4466 . .
2c (
e Tax deposited with Form 7004 . . . . . . . . . . . . . .
2e
f Credit for Federal tax paid on fuels (attach Form 4136) . . . . . .
2f
2g
g U.S. income tax paid or withheld at source (attach Form 1042-S) . .
h Add lines 2d through 2g . . . . . . . . . . . . . . . . . . . . . . . . .
3
Estimated tax penalty. Check if Form 2220 is attached . . . . . . . . . . . . . ▶
4
Tax due. If line 2h is smaller than the total of lines 1 and 3, enter amount owed . . . . . . .
5
Overpayment. If line 2h is larger than the total of lines 1 and 3, enter amount overpaid . . . .
6
Enter amount of line 5 you want: Credited to next year’s estimated tax ▶
Refunded ▶

2h
3
4
5
6

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true,
correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.

Date

Signature of officer

Paid
Preparer
Use Only

Print/Type preparer’s name

Firm’s name

▲

▲

Sign
Here

1

Title

Preparer’s signature

Date

Check
if
self-employed

PTIN

Firm’s EIN ▶

▶

Firm’s address ▶

For Paperwork Reduction Act Notice, see instructions.

May the IRS discuss this return
with the preparer shown below
Yes No
(see instructions)?

Phone no.
Cat. No. 11531K

Form 1120-FSC (Rev. 11-2018)

Page 2

Form 1120-FSC (Rev. 11-2018)

Schedule A

Cost of Goods Sold Related to Foreign Trading Gross Receipts (see instructions)
(a) Using administrative pricing rules (b) Not using administrative pricing rules

1
2
3
4
5
6
7
8

Inventory at beginning of year . . . . . . . . . . .
1
Purchases . . . . . . . . . . . . . . . . .
2
Cost of labor . . . . . . . . . . . . . . . . .
3
Additional section 263A costs (attach schedule) . . . . .
4
Other costs (attach schedule) . . . . . . . . . . .
5
Total. Add lines 1 through 5 . . . . . . . . . . . .
6
Inventory at end of year . . . . . . . . . . . . .
7
Cost of goods sold. Subtract line 7 from line 6. Enter here and on
line 7 of Schedule B. Small FSCs, see instructions for Schedule A
8
9a Check all methods used for valuing closing inventory:
(1)
Cost as described in Regulations section 1.471-3
(2)
Lower of cost or market as described in Regulations section 1.471-4
Other (Specify method used and attach explanation.) ▶
(3)
b Check if there was a writedown of subnormal goods as described in Regulations section 1.471-2(c) . . . . . . .
c Check if the LIFO inventory method was adopted this tax year for any goods. (If checked, attach Form 970.) . . . .
d If the LIFO inventory method was used for this tax year, enter percentage (or amounts) of closing
inventory computed under LIFO . . . . . . . . . . . . . . . . . . . . .
9d
e If property is produced or acquired for resale, do the rules of section 263A apply to the FSC? . . . . .
Yes
f Was there any change in determining quantities, cost, or valuations between opening and closing inventory?
If “Yes,” attach explanation . . . . . . . . . . . . . . . . . . . . . . . . . . .
Yes

DRAFT AS OF
September 4, 2018
DO NOT FILE
▶
▶

No
No

Additional Information (see instructions). Note: Small FSCs, complete lines 1 through 8f only.
1
a
b
c
2

See the instructions and enter the FSC’s:
Business activity code no. ▶
Business activity ▶

f

4

During the tax year, did the FSC own any foreign entity
that was disregarded as an entity separate from its
owner under Regulations sections 301.7701-2 and
301.7701-3? . . . . . . . . . . . . .
If “Yes,” attach a statement listing the name, country
under whose laws the entity was organized, and EIN (if
any) of each such entity.

5

During the tax year, did the FSC own at least a 10%
interest, directly or indirectly, in any foreign partnership?

g

If the FSC has an NOL for the tax year and is electing to
forego the carryback period, check here (see
instructions) . . . . . . . . . . ▶

7

Enter the available NOL carryover from prior tax years.
(Do not reduce it by any deduction on Schedule B, Part
II, line 19a.) . . . . . . ▶ $

8
a

9
a
b

Did the FSC have any preferred stock outstanding at
any time during the tax year? . . . . . . . .

c

During the tax year, did the FSC maintain an office in a
qualifying foreign country or U.S. possession in which a
complete set of books and records was maintained? .

d

During the tax year did the FSC maintain the records
required under section 6001 at a location within the U.S.?

e

At all times during the tax year, did the FSC have at
least one non-U.S. resident on its board of directors? .

Check the applicable box if during the tax year the FSC

Foreign management rules (does not apply to small FSCs):
Did all formally convened meetings of the board of directors
and of the shareholders occur outside the U.S.? . . .
(1) Were all cash dividends, legal and accounting fees,
salaries of officers, and salaries or fees of members of
the board of directors disbursed from bank accounts
maintained outside the United States? (If “Yes,” these
accounts are considered to be the FSC’s principal
bank accounts.) . . . . . . . . . . .
(2) At all times during the tax year, did the FSC maintain
its principal bank accounts in a qualifying foreign
country or U.S. possession (see instructions)? . .
Name of bank(s) ▶
Account number(s) ▶

10
a

b

FSC qualification rules (see instructions):
Enter the largest number of shareholders the FSC had
at any time during the tax year ▶

b

Yes No

was a member of a controlled group of corporations that
included a
DISC or a
FSC.

If “Yes,” see the instructions for required attachment.
6

Small FSCs only: Check the applicable box if during the tax
year the small FSC was a member of a controlled group of
corporations that included a
DISC or a
FSC.

Product or service ▶
Enter the amount of tax-exempt interest received or
accrued during the tax year ▶
$
At any time during the tax year was the FSC engaged in
a trade or business in the United States? . . . . .

3

Yes No

Foreign economic process rules (does not apply to small FSCs):
Check the applicable box if the FSC is electing to group transactions
from its sales activities (Regulations section 1.924(d)-1(c)(5)):
Customer grouping

Contract grouping

Product or product line grouping

Product or product line subgroupings

Check the applicable box(es) to indicate how the FSC met the
foreign direct costs requirement (see instructions):
The FSC (or any person under contract with the FSC) met the
50% test of section 924(d)(1).
The FSC (or any person under contract with the FSC) met the alternative
85% test of section 924(d)(2). Check to indicate the subparagraphs of
section 924(e) for which this alternative test was met:
(e)(1)

(e)(2)

(e)(3)

(e)(4)

(e)(5)

c

If box (e)(5) is checked, enter which of the five methods listed in
Regulations section 1.924(e)-1(e)(1)(i) through (v) describes how the
FSC bears the economic risk of nonpayment ▶

d

Check the applicable box if the FSC is electing to group its foreign
direct costs on one of the following (Regulations section 1.924(d)-1(e)):
Customer grouping

Contract grouping

Product or product line grouping

Form 1120-FSC (Rev. 11-2018)

Page 3

Form 1120-FSC (Rev. 11-2018)

Schedule B

Taxable Income or (Loss) (see instructions)
Part I—Net Income Attributable to Nonexempt Foreign Trade Income
(b) Not using
administrative
pricing rules

(a) Using administrative
pricing rules

1

Sale, exchange, or other disposition of export property. (Enter 50% of
military property sales. Include the other 50% on Schedule F, line 1.) . .
Lease or rental of export property for use outside the United States
. .
Services related and subsidiary to:
Sale, exchange, or other disposition of export property. (Enter 50% of
services related to the sale or other disposition of military property. Include
the other 50% on Schedule F, line 1.)
. . . . . . . . . . . .
Lease or rental of export property . . . . . . . . . . . . . .
Engineering or architectural services for construction projects outside the U.S.
Managerial services for an unrelated FSC or IC-DISC (see instructions) .
Total foreign trading gross receipts. Add lines 1 through 5 . . . . .
Small FSCs: Complete lines 6b through 6h.
$5,000,000
Small FSC limitation (section 924(b)(2)(B)) . . . .
6b
Controlled group member’s share of line 6b . . .
6c
Enter 1. (Short tax year: Divide the number of days in
the short tax year by the number of days in the full tax
year. Enter as a decimal less than 1.00000.) . . .
6d
6e
Multiply line 6b or line 6c (whichever applies) by line 6d
Total of line 6a, columns (a) and (b) . . . . . .
6f
Note: See the instructions for line 6f if commission
income is included on line 6a.
Enter the smaller of line 6e or line 6f. Note: If line 6f
exceeds line 6e, enter the excess on line 7 of Schedule F
6g
Allocate the amount from line 6g to columns (a) and (b) (see instructions) .
Cost of goods sold (Schedule A, line 8). (Small FSCs, enter only the part of
cost of goods sold from the receipts on line 6h above. See instructions for
Schedule A.) . . . . . . . . . . . . . . . . . . . . .

1
2

DRAFT AS OF
September 4, 2018
DO NOT FILE
2
3

a

b

4
5
6a

b
c
d

e
f

g
h
7

8
9a
b
10

Foreign trade income. Subtract line 7 from line 6a or line 6h (whichever applies)
Exemption percentage from Schedule E, line 3d . . . . . . . . .
Exemption percentage from Schedule E, line 2d . . . . . . . . .
Exempt foreign trade income. Multiply line 8, column (a) by line 9a and line
8, column (b) by line 9b . . . . . . . . . . . . . . . . .

11
12

Nonexempt foreign trade income. Subtract line 10 from line 8 . . . .
Deductions attributable to nonexempt foreign trade income. Enter amount
from Schedule G, line 18 . . . . . . . . . . . . . . . . .
Net income attributable to nonexempt foreign trade income. Subtract line 12
from line 11 . . . . . . . . . . . . . . . . . . . . .
Net income attributable to nonexempt foreign trade income from Schedule
F, line 6 . . . . . . . . . . . . . . . . . . . . . .
Total net income attributable to nonexempt foreign trade income. Add
lines 13 and 14 . . . . . . . . . . . . . . . . . . . .

13
14
15

3a
3b
4
5
6a

00

Part II—Taxable Income or (Loss)
16

17
18

6h

7
8
9a
9b

%
%

10
11
12
13
14
15

Taxable income from foreign trade income. Enter total of line 15, columns (a) and (b), minus any
nontaxable income included in line 15, column (b). Attach a schedule that shows the computation
of the taxable and nontaxable income included on line 15, column (b) . . . . . . . . . .

Taxable nonforeign trade income from Schedule F, line 19
. . . . . . . . . . . . .
Taxable income or (loss) before net operating loss deduction and dividends-received deduction.
Add lines 16 and 17 . . . . . . . . . . . . . . . . . . . . . . . . . .
19a Net operating loss deduction (attach schedule) . . . . . . . . 19a
b Dividends-received deduction (attach schedule) . . . . . . . . 19b
c Add lines 19a and 19b . . . . . . . . . . . . . . . . . . . . . . . . .
20
Taxable income or (loss). Subtract line 19c from line 18. (See instructions for Schedule J to
figure the tax on this income.) . . . . . . . . . . . . . . . . . . . . . . .

16
17
18

19c
20

Form 1120-FSC (Rev. 11-2018)

Page 4

Form 1120-FSC (Rev. 11-2018)

Schedule E

Exemption Percentages Used in Figuring Exempt Foreign Trade Income (see instructions)

Note: If all shareholders of the FSC are C corporations, enter .30000 on line 2d and .65217 on line 3d and skip all other lines.
If all shareholders of the FSC are other than C corporations, enter .32000 on line 2d and .69565 on line 3d and skip all other lines.

1
2

Percentage (round to at least five decimal places) of voting stock owned by shareholders that are
C corporations . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Exemption percentage for foreign trade income determined by not using the administrative pricing rules:
Difference between section 923(a)(2) and section 291(a)(4)(A) percentage . . . . . . . . .

1

DRAFT AS OF
September 4, 2018
DO NOT FILE
2a

.02000

.

2b

.32000

c Multiply line 1 by line 2a . . . . . . . . . . . . . . . . . . . . . . . . .
d Exemption percentage. Subtract line 2c from line 2b. Enter here and on Schedule B, line 9b, and
on Schedule G, line 16b . . . . . . . . . . . . . . . . . . . . . . . . .
3
Exemption percentage for foreign trade income determined using administrative pricing rules:
a Difference between section 923(a)(3) fraction and section 291(a)(4)(B) fraction (16/23 – 15/23 =
1/23) shown as a decimal . . . . . . . . . . . . . . . . . . . . . . . .

2c

a

b Section 923(a)(2) percentage

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2d

3a

.04348

.

3b

.69565

c Multiply line 1 by line 3a . . . . . . . . . . . . . . . . . . . . . . . . .
d Exemption percentage. Subtract line 3c from line 3b. Enter here and on Schedule B, line 9a, and
on Schedule G, line 16a . . . . . . . . . . . . . . . . . . . . . . . . .

3c

b Section 923(a)(3) fraction (16/23) shown as a decimal

Schedule F

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3d

Net Income From Nonexempt Foreign Trade Income and Taxable Nonforeign Trade Income
(see instructions)
Part I—Net Income From Nonexempt Foreign Trade Income
(a) Using administrative
pricing rules

1 Enter 50% of total receipts from the sale, exchange, or other disposition of
military property and related services . . . . . . . . . . . . .

(b) Not using administrative
pricing rules

1
2
3
4

2
3
4
5

International boycott income . . . . . . . . . . . . . . . .
Illegal bribes and other payments . . . . . . . . . . . . . .
Total. Add lines 1, 2, and 3 . . . . . . . . . . . . . . . .
Cost of goods sold and other costs related to above income
(attach schedule) . . . . . . . . . . . . . . . . . . . .
6 Net income from nonexempt foreign trade income. Subtract line 5 from
line 4. Enter here and on Schedule B, line 14, columns (a) and (b) . . . .

5
6

Part II—Taxable Nonforeign Trade Income
7 Small FSCs: If line 6f, Schedule B, is greater than line 6e, Schedule B, enter the excess here .

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7

8 Interest .

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8

9 Dividends (attach schedule—see instructions)

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9

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10

11 Royalties
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
12 Other investment income . . . . . . . . . . . . . . . . . . . . . . . . .
13 Receipts excluded under section 924(f) on the basis of use, subsidized receipts, and receipts from
related parties . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14 Income from excluded property under sections 927(a)(2) and (3) . . . . . . . . . . . .
15 Income from transactions that did not meet the Foreign economic process rules (see instructions).
(See Foreign Trading Gross Receipts in the instructions.) . . . . . . . . . . . . . .
16 Other income . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
17 Total. Add lines 7 through 16 . . . . . . . . . . . . . . . . . . . . . . . .
18 Enter deductions allocated or apportioned to line 17 income. (Attach schedule. Small FSCs also
include the cost of goods sold deduction attributable to the amount entered on line 7 above) . . .
19 Taxable nonforeign trade income. Subtract line 18 from line 17. Enter here and on Schedule B,
line 17 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

11
12

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10 Carrying charges .

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13
14
15
16
17
18
19

Form 1120-FSC (Rev. 11-2018)

Page 5

Form 1120-FSC (Rev. 11-2018)

Schedule G

Deductions Allocated or Apportioned to Foreign Trade Income Other Than Foreign Trade Income
Reported on Schedule F (See instructions for limitations on deductions before completing lines 1 through 14.)
(a) Using administrative
pricing rules

1

Foreign direct costs described in section 924(e):
a Advertising and sales promotion . . . . . . . . . . . . . .
b Certain processing and arranging costs . . . . . . . . . . . .
c Certain transportation costs . . . . . . . . . . . . . . . .
d Certain determination and transmittal costs . . . . . . . . . .
e Assumption of credit risk . . . . . . . . . . . . . . . . .
f Total foreign direct costs. Add lines 1a through 1e . . . . . . . .
2
Advertising . . . . . . . . . . . . . . . . . . . . .
3
Interest . . . . . . . . . . . . . . . . . . . . . .
4
Depreciation from Form 4562 (less any depreciation claimed elsewhere on
this return) (attach Form 4562) . . . . . . . . . . . . . . .
5
Salaries and wages . . . . . . . . . . . . . . . . . .
6
Rents . . . . . . . . . . . . . . . . . . . . . . .
7
Sales commissions
. . . . . . . . . . . . . . . . . .
8
Warehousing
. . . . . . . . . . . . . . . . . . . .
9
Freight . . . . . . . . . . . . . . . . . . . . . . .
10
Compensation of officers
. . . . . . . . . . . . . . . .
11
Bad debts
. . . . . . . . . . . . . . . . . . . . .
12
Pension, profit-sharing, etc., plans . . . . . . . . . . . . .
13
Employee benefit programs . . . . . . . . . . . . . . . .
14
Other deductions (attach list) . . . . . . . . . . . . . . .
15
Total deductions. Add lines 1f through 14 . . . . . . . . . . .
16a Exemption percentage from Schedule E, line 3d . . . . . . . . .
b Exemption percentage from Schedule E, line 2d . . . . . . . . .
17
Deductions attributable to exempt foreign trade income. Multiply line 15,
column (a) by line 16a and enter the result in column (a). Multiply line 15,
column (b) by line 16b and enter the result in column (b) . . . . . .

(b) Not using administrative
pricing rules

1a
1b
1c
1d
1e
1f
2
3

DRAFT AS OF
September 4, 2018
DO NOT FILE

18

4
5
6
7
8
9
10
11
12
13
14
15
16a
16b

%

17

Deductions allocated or apportioned to nonexempt foreign trade
income other than foreign trade income reported on Schedule F.
Subtract line 17 from line 15. Enter here and on Schedule B, line 12, columns
(a) and (b) . . . . . . . . . . . . . . . . . . . . . .

Schedule J

%

18

Tax Computation (see instructions)

1

Check if the FSC is a member of a controlled group (see section 927(d)(4)) (attach Schedule
O (Form 1120)) . . . . . . . . . . . . . . . . . . . . . . . . . ▶

2

Income tax

3

Base erosion minimum tax (attach Form 8991)

4

Add lines 2 and 3

5

Foreign tax credit (attach Form 1118)

6

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4

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5

Total tax. Subtract line 5 from line 4. Enter here and on line 1, page 1 .

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6
Form 1120-FSC (Rev. 11-2018)

Page 6

Form 1120-FSC (Rev. 11-2018)

Schedule L

Balance Sheets per Books

Beginning of tax year
(a)

Assets
1
2a
b
c
3
4
5
6
7
8
9
10a
b
11a
b
12
13a
b
14
15

Cash
. . . . . . . . . .
Trade notes and accounts receivable .
Commissions receivable . . . . .
Less allowance for bad debts . . .
Inventories . . . . . . . . .
U.S. government obligations
. . .
Tax-exempt securities (see instructions)
Other current assets (attach schedule) .
Loans to shareholders . . . . .
Mortgage and real estate loans . . .
Other investments (attach schedule) .
Buildings and other depreciable assets
Less accumulated depreciation . . .
Depletable assets . . . . . . .
Less accumulated depletion . . . .
Land (net of any amortization) . . .
Intangible assets (amortizable only)
.
Less accumulated amortization . . .
Other assets (attach schedule) . . .
Total assets
. . . . . . . .

.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.

End of tax year
(b)

(c)

(d)

(

)

(

)

(

)

(

)

(

)

(

)

(

)

(

)

DRAFT AS OF
September 4, 2018
DO NOT FILE
Liabilities and Shareholders’ Equity

16
17
18
19
20
21
22
23
24
25
26
27
28
29

Accounts payable . . . . . . . .
Mtges., notes, bonds payable in less than 1 year
Transfer prices payable . . . . . .
Other current liabilities (attach schedule) .
Loans from shareholders . . . . . .
Mtges., notes, bonds payable in 1 year or more
Other liabilities (attach schedule) . . .
Capital stock . . . . . . . . .
Additional paid-in capital . . . . . .
Retained earnings—Appropriated (attach schedule)
Retained earnings—Unappropriated . .
Adjustments to shareholders’ equity (attach schedule)
Less cost of treasury stock . . . . .
Total liabilities and shareholders’ equity .

Schedule M-1

Net income (loss) per books .
Federal income tax per books

3
4

Excess of capital losses over capital gains
Income subject to tax not recorded
on books this year (itemize):

5

Expenses recorded on books this year not
deducted on this return (itemize):
Depreciation

b

Deductions attributable to
exempt foreign trade income $
Travel and entertainment $

6

.

.

.

Add lines 1 through 5 .

.
.

.
.

.
.

(

)

Income recorded on books this year
not included on this return (itemize):

7
a
b

8

.

Tax-exempt interest $
Exempt foreign trade
$
income
Deductions on this return not charged
against book income this year (itemize):
Depreciation .

9
10
.

.

.

.

.

.

$

Add lines 7 and 8
. . . . .
Taxable income (line 18, Schedule B)—
line 6 less line 9 . . . . . .

Analysis of Unappropriated Retained Earnings per Books (Line 26, Schedule L)

1
2

Balance at beginning of year
Net income (loss) per books .

3

Other increases (itemize):

4

.
.

$

a

Schedule M-2

)

Reconciliation of Income (Loss) per Books With Income per Return (see instructions)

1
2

c

(

Add lines 1, 2, and 3 .

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5

Distributions:

a
b

6
7
8

c Property . .
Other decreases (itemize):
Add lines 5 and 6
. . . . .
Balance at end of year (line 4 less line 7)

Cash .
Stock .

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Form 1120-FSC (Rev. 11-2018)