Preparing Form 1120-F for Foreign Corporations: 2021 Revisions, ECI, Protective Claims, and Branch Profits Tax
Note: CLE credit is not offered on this program
A live 110-minute CPE webinar with interactive Q&A
This course will provide a practical explanation of completing Form 1120-F, U.S. Income Tax Return of a Foreign Corporation. Our experts will explain how to properly prepare this onerous form, including who is required to file, filing protective returns, and issues for consideration with respect to certain schedules and attachments to the tax return.
Outline
- Who should file Form 1120-F
- Protective Returns
- Treas. Reg. Sec. 1.882-4 along with Adams Challenge (UK) Ltd v. Commissioner and Swallows Holdings, Ltd. v. Commissioner
- Section I - Income From U.S. Sources Not Effectively Connected With the Conduct of a Trade or Business in the United States
- FDAP withholding and when FDAP income reporting is required
- Section II - Income Effectively Connected With the Conduct of a Trade or Business in the United States
- Engaged in a U.S. trade or business
- Activities conducted by a foreign corporation through a U.S. partnership
- Income effectively connected to a U.S. trade or business
- Engaged in a U.S. trade or business
- Section III – Branch Profits Tax and Tax on Excess Interest
- Calculating and reporting the Branch Profits Tax
- Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)
- When treaty-based return position disclosure is required and certain key exceptions to reporting
- Limitations on Benefits Article
- Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
- Information generally required
- Exceptions from filing
- Filing obligation for Foreign-Owned U.S. Disregarded Entities
Benefits
The panel will review these and other key issues:
- Who is required to file Form 1120-F?
- When should an entity file an 1120-F protective claim, even though not subject to tax and possibly not required to file?
- What methods are used to allocate and apportion ECI and non-ECI expenses on Schedule H?
- What are examples of treaty-based positions that might require filing Form 8833, Treaty-Based Return Position Disclosure?
Faculty

Sean Dokko, J.D., LL.M.
Principal, Head of Tax
CWS CPA
Mr. Dokko advises clients on U.S. international tax matters with a focus on inbound and outbound tax planning and... | Read More
Mr. Dokko advises clients on U.S. international tax matters with a focus on inbound and outbound tax planning and consulting. He has extensive experience in developing, implementing, and reporting tax planning strategies and cross-border restructurings.
Closeto be announced.
Early Discount (through 09/30/22)
CPE credit processing is available for an additional fee of $39.
CPE processing must be ordered prior to the event.
See
NASBA details.