Interest Expense Allocation Under Regulations Section 1.882-5

• Legal Form Number: 1120-F (Schedule I)
• Issuer: Treasury Department
• Section: Treasury Department

SCHEDULE I

(Form 1120-F)

2023

Interest Expense Allocation Under Regulations

Section 1.882-5

Department of the Treasury

Internal Revenue Service

Attach to Form 1120-F.

Go to www.irs.gov/Form1120F for instructions and the latest information.

OMB No. 1545-0123

Name of corporation Employer identification number

ACheck here if the corporation is a foreign bank as defined in Regulations section 1.882-5(c)(4) . . . . . . . . . . . . .

BThis 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 Average U.S. Assets for the Tax Year: Regulations Section 1.882-5(b)

1 To determine the value of the

corporation’s U.S. assets on

lines 2 through 5 below, use the adjusted basis method

described in Regs. sec. 1.882-5(b)(2)(i).

(a)

Set(s) of Books That

Give Rise to U.S.

Booked Liabilities

(see instructions)

(b)

Partnership

Interests

(c)

Set(s) of Books

Other Than Those

Described in

Columns (a) and (b)

(d)

Totals

(add columns (a)

through (c))

2Total assets per books . . . . . . . . . . .

3a Total interbranch assets . . . . . . . . . . .

bTotal non-ECI assets under section 864(c)(4)(D) . . . .

c

Total other non-ECI assets (attach statement-see instructions)

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 on line 2

(for example, mark-to-market differences) . . . . . .

4Combine lines 3a through 3f . . . . . . . . . .

5

Total value of U.S. assets for the tax year . . . . . .

Column (a): Subtract line 4 from line 2.

Column (b): See instructions for amount to enter.

Column (c): See instructions for amount to enter.

Step 2 U.S.-Connected Liabilities for the Tax Year: Regulations Section 1.882-5(c)

6Specify the method used to determine the amounts in Step 2 (check one):

Actual ratio under Regs. sec. 1.882-5(c)(2). Complete lines 6a through 6c below.

Fixed ratio under Regs. sec. 1.882-5(c)(4). Complete line 6d below.

aAverage worldwide liabilities . . . . . . . . . . . . . . . . . 6a

bAverage worldwide assets . . . . . . . . . . . . . . . . . . 6b

cDivide line 6a by line 6b . . . . . . . . . . . . . . . . . . . 6c %

d

Fixed ratio under Regs. sec. 1.882-5(c)(4). If the corporation is a foreign bank as defined

in Regs. sec. 1.882-5(c)(4), enter 95% on line 6d. If the corporation is not a foreign bank

or an insurance company, enter 50% on line 6d . . . . . . . . . . . . 6d %

eEnter the ratio from line 6c or 6d, as applicable . . . . . . . . . . . . . . . . . . . . 6e %

7a U.S.-connected liabilities before Regs. sec. 1.884-1(e)(3) election(s). Multiply line 5, column (d) by line 6e . . . 7a

bU.S. liability reduction under Regs. sec. 1.884-1(e)(3) election . . . . . . . . . . . . . . . . 7b

c U.S.-Connected Liabilities. Subtract line 7b from line 7a . . . . . . . . . . . . . . . . . 7c

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 instructions)

(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 portion of the total from Schedule P, line

11, that constitutes U.S. booked liabilities.

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 8.

For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F. Cat. No. 49680W Schedule I (Form 1120-F) 2023