Rev. December 2022
The document provides instructions for completing Schedule V of Form 1120-F for corporations subject to a 4% tax rate under section 887. For each vessel or aircraft, the corporation must provide information such as name, ID number, charter status, registered owner EIN or SSN, operator EIN or SSN, and U.S. source gross transportation income. Additional instructions are given for vessels or aircraft chartered in or out. The document also includes a Paperwork Reduction Act Notice.
Schedule V requires reporting the name and type of each vessel or aircraft, the country of registration, the name and address of the registered owner, the name and EIN or SSN of the operator, and the USSGTI derived from the vessel or aircraft.
USSGTI (Undertaxed Payment to Controlled Foreign Corporation for Services in Connection with International Traffic) refers to income that a foreign corporation derives from the operation of vessels or aircraft in international trade, and which is subject to a 4% tax rate under section 887 of the Internal Revenue Code.
The calculation of USSGTI may depend on whether the corporation is the operator or lessor of the vessel or aircraft. One reasonable method for calculating USSGTI from a charter under a bareboat lease or sublease agreement is to apply to such charter income the ratio of (a) the number of days of uninterrupted travel on voyages between the United States and the farthest point where cargo or passengers are loaded en route to, or discharged en route from, the United States, to (b) the total number of days in the smaller of the tax year or the particular charter period. Another reasonable method would be to use a ratio based on the USSGTI earned from the operation of the vessel or aircraft by the lessee-operator compared with the total gross income of the lessee-operator from the operation of the vessel or aircraft during the smaller of the tax year or the term of the charter.
Schedule V is used by a foreign corporation to report income derived from the operation of vessels or aircraft in international trade, including income from bareboat leases or charter hire, and income from services directly related to the use of such vessels or aircraft.
Form 1120-F Schedule V is one of Tax forms that are documents used to report information related to taxes to the relevant tax authority. There are various types of tax forms, including federal, state, and local tax forms, which can vary depending on the taxpayer's circumstances and location.
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