
Demystifying the Form 1118 Part 8. Schedule F-3 Determining the Tax Consequences of Tax Deemed Paid by Third, Fourth, and Fifth-Tier Foreign Corporations Under Section 902(b) Prior to Tax Reform
By Anthony Diosdi In order to provide the Internal Revenue Service (“IRS”) with the information necessary to claim a foreign tax credit, a U.S. corporation claiming a foreign tax credit must attach Form 1118 otherwise known as “Foreign Tax Credit - Corporations,” to its tax return. This is the eighth of a series of articles designed to provide a basic overview of the Form 1118. This article is designed to supplement the instructions for the Form 1118 promulgated by the IRS.Introduction to Schedule F-3Claiming Foreign Tax Credits Through Multiple TiersSchedule F-3 is designed to report foreign taxes deemed paid with respect to dividends from certain fourth, fifth, and sixth-tier controlled foreign corporations (“CFC”s”) out of earnings accumulated in tax years beginning after August 5, 1997. An indirect foreign tax…