FTC Generator Information Document Request (IDR) #1 |
|
This IDR requests information regarding any foreign tax paid or accrued (or deemed paid) and reported on line 5, Part II., Schedule B, of any Form 1118 that is attributable to an arrangement that satisfies the conditions described in Treas. Reg. §1.901-2T(e)(5)(iv)(B) (without regard to the effective date described in §1.901-2T(h)(2)) or to a substantially similar arrangement.
-
Indicate whether taxpayer engaged in the above-described arrangement(s) and provide the name(s) or title(s) of such arrangement(s), the date(s) entered into such arrangement(s) and the identity(ies) of the counter-party(ies).
-
State the amount of foreign taxes paid, accrued and deemed paid and foreign taxes carried over that are attributable to the above-identified arrangement(s) and identify the country(ies) to whom the tax was paid.
-
Describe the taxpayer’s US income tax reporting of the above-identified arrangement(s), including the timing and amounts of each item of income, credit, deduction, loss, the basis of assets involved and any other tax effect of the above-identified arrangement(s)for all tax years affected by the arrangement(s).
The Following Definitions Apply to this IDR:
-
The word “taxpayer” refers to [insert name of taxpayer] its subsidiaries, and affiliates whether owned directly or indirectly, including all successor and predecessor entities or names under which it has done business and all past or present divisions or subsidiaries of any of the those entities, whether or not such subsidiaries or affiliates which are owned directly or indirectly are part of the consolidated group, and all other entities over which the taxpayer exercises legal or effective control.
-
The words “substantially similar” have the meaning set forth at Treas. Reg. §1.6011-4(c)(4).
|
|
|
Page Last Reviewed or Updated: February 23, 2009