SCHEDULE M-3 (Form 1120-F)
Department of the Treasury Internal Revenue Service
Net Income (Loss) Reconciliation for Foreign Corporations With Reportable Assets of $10 Million or More
Attach to Form 1120-F. See separate instructions.
OMB No. 1545-0126
2008
Name of corporation
Employer identification number
A
Has the corporation reported taxable income on Form 1120-F, page 3, using a treaty provision to attribute business profits to a U.S. permanent establishment under rules other than section 864(c)? Did the corporation prepare a non-consolidated, worldwide, certified audited income statement for the period (see instructions)?
Yes
No
B
Yes Yes
No No
C Did the corporation prepare a non-consolidated, worldwide income statement for the period (see instructions)? D Did the corporation prepare certified audited income statement(s) for the set(s) of books reported on Form 1120-F, Schedule L?
Yes
No
Part I
1
Financial Information and Net Income (Loss) Reconciliation (see instructions)
Is the corporation a foreign bank as defined in Temporary Regulations section 1.882-5T(c)(4)? Yes. Complete the remainder of Part I as follows: If D is "Yes," use the income statement described in D to complete lines 2 through 5 and 7 through 11. If D is "No," use the income statement(s) for the set(s) of books reported on Form 1120-F, Schedule L to complete lines 2 through 5 and 7 through 11. No. Complete the remainder of Part I as follows: If B is "Yes," use the income statement described in B to complete lines 2 through 11. If B is "No" and C is "Yes," use the income statement described in C to complete lines 2 through 11. If B and C are "No" and D is "Yes," use the income statement described in D to complete lines 2 through 11. If B, C, and D are "No," use the income statement described in the instructions to complete lines 2 through 11.
/ / / / 2a Enter the income statement period: Beginning Ending b Has the corporation's income statement been restated for the income statement period entered on line 2a? Yes. Attach an explanation and the amount of each item restated. No. c Has the corporation's income statement been restated for any of the 5 income statement periods preceding the period on line 2a? Yes. Attach an explanation and the amount of each item restated. No. 3 Is any of the corporation's stock publicly traded on any exchange, U.S. or foreign? Yes. List exchange(s) and symbol No. 4 Non-consolidated foreign corporation net income (loss) in U.S. dollars from the income statement 4 source identified in line 1 5a 5a Net income from includible disregarded foreign entities not included on line 4 (attach schedule) 5b ( b Net loss from includible disregarded foreign entities not included on line 4 (attach schedule) 5c c Net income from includible disregarded U.S. entities not included on line 4 (attach schedule) 5d ( d Net loss from includible disregarded U.S. entities not included on line 4 (attach schedule) 6 6 Net income (loss) from foreign locations not included on line 4 (attach schedule) 7a ( 7a Net income of non-includible entities (attach schedule) 7b b Net loss of non-includible entities (attach schedule) 8 8 Adjustments to intercompany transactions (attach schedule) 9 9 Adjustments to reconcile income statement period to tax year (attach schedule) 10 10 Other adjustments to reconcile to amount on line 11 (attach schedule) 11 Adjusted financial net income (loss) of non-consolidated foreign corporation. Combine lines 4 through 10
Cat. No. 39667H
) ) )
11
For Privacy Act and Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.
Schedule M-3 (Form 1120-F) 2008
Schedule M-3 (Form 1120-F) 2008 Name of corporation
Page Employer identification number
2
Part II
Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions)
(a) Income (Loss) per Income Statement (optional) (b) Temporary Differences (c) Permanent Differences (d) Other Permanent Differences for Allocations to Non-ECI and ECI (e) Income (Loss) per Return (optional)
Income (Loss) Items
1 2 3a b c 4a b c 5 6 7 8 9 10 11 12 13
Gross receipts Cost of goods sold (attach schedule) Dividends from foreign entities Dividends from U.S. entities Substitute dividend payments received Interest income excluding interest equivalents Substitute interest payments received Interest equivalents not included on line 4b Gross rental income Gross royalty income Fee and commission income Income (loss) from equity method corporations Net income (loss) from U.S. partnerships Net income (loss) from certain foreign partnerships (see instructions) Net income (loss) from other passthrough entities (attach schedule) Items relating to reportable transactions (attach details) Hedging transactions
14a Mark-to-market income (loss) under section 475(a) b Mark-to-market income (loss) subject to section 475(d)(3)(B) c Mark-to-market income (loss) under section 475(e) d Mark-to-market income (loss) under section 475(f) 15 Gain (loss) from certain section 988 transactions
16a Interest income from global securities dealing b Dividends from global securities dealing c Gains (losses) and other fixed and determinable, annual, or periodic income from global securities dealing not included on lines 16a and 16b 17 18 19 20 Sales versus lease (for sellers and/or lessors) Section 481(a) adjustments Unearned/deferred revenue Original issue discount, imputed interest, and phantom income
21a Income statement gain/loss on sale, exchange, abandonment, worthlessness, or other disposition of assets other than inventory and pass-through entities b Gross capital gains from Schedule D, excluding amounts from passthrough entities
Schedule M-3 (Form 1120-F) 2008
Schedule M-3 (Form 1120-F) 2008 Name of corporation
Page Employer identification number
3
Part II
Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (continued from page 2)
(a) Income (Loss) per Income Statement (optional) (b) Temporary Differences (c) Permanent Differences (d) Other Permanent Differences for Allocations to Non-ECI and ECI (e) Income (Loss) per Return (optional)
Income (Loss) Items
21c Gross capital losses from Schedule D,
excluding amounts from pass-through entities, abandonment losses, and worthless stock losses
d Net gain/loss reported on Form 4797,
line 17, excluding amounts from pass-through entities, abandonment losses, and worthless stock losses
e Abandonment losses f Worthless stock losses (attach details) g Other gain/loss on disposition of
assets other than inventory
22 23
Capital loss limitation carryforward used
and
Gross effectively connected income of foreign banks from books that do not give rise to U.S. booked liabilities Other income (loss) items differences (attach schedule) with
24 25 26 27 28
Total income (loss) items. Combine lines 1 through 24 Total expense/deduction (from Part III, line 33) Other items with no differences Reconciliation totals. Combine lines 25 through 27 Note. Line 28, column (a), must equal the amount on Part I, line 11, and column (e) must equal Form 1120-F, page 3, line 29. items
Part III
Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions)
(a) Expense per Income Statement (optional) (b) Temporary Differences (c) Permanent Differences (d) Other Permanent Differences for Allocations to Non-ECI and ECI (e) Deduction per Tax Return (optional)
Expense/Deduction Items
1 2 3 4 5 6 7 8 9 10 11 12
U.S. current income tax expense U.S. deferred income tax expense Non-U.S. current income tax expense (other than foreign withholding taxes) Non-U.S. expense deferred income tax
Non-U.S. withholding taxes Compensation with section 162(m) limitation Salaries and other base compensation Stock option expense Other equity-based compensation Meals and entertainment Fines and penalties Judgments, damages, awards, and similar costs
Schedule M-3 (Form 1120-F) 2008
Schedule M-3 (Form 1120-F) 2008 Name of corporation
Page Employer identification number
4
Part III
Reconciliation of Net Income (Loss) per Income Statement of Non-Consolidated Foreign Corporations With Taxable Income per Return (see instructions) (continued from page 3)
(a) Expense per Income Statement (optional) (b) Temporary Differences (c) Permanent Differences (d) Other Permanent Differences for Allocations to Non-ECI and ECI (e) Deduction per Tax Return (optional)
Expense/Deduction Items
13 14 15 16 17 18
Pension and profit-sharing Other post-retirement benefits Deferred compensation Charitable contributions Domestic deduction production activities
Current year acquisition or reorganization investment banking fees, legal and accounting fees Current year acquisition/reorganization other costs Amortization/impairment of goodwill Amortization of acquisition, reorganization, and start-up costs Other amortization and impairment write-offs Depreciation Bad debt expense Purchase versus lease (for purchasers and/or lessees)
19 20 21 22 23 24 25
26a Interest expense per books b Interest expense under Regulations
section 1.882-5 (from Schedule I (Form 1120-F), line 23)
c Regulations section 1.882-5 allocation
amount subject to deferral or disallowance (from Schedule I (Form 1120-F), line 24d)
(
)
d U.S.
source payments
substitute
interest
e Interest equivalents (e.g., guarantee
fees) not included on line 26d
27 28 29 30 31
U.S. source payments Rental expense
substitute
dividend
Fee and commission expense Royalty expense Expenses allocable to effectively connected income under Regulations section 1.861-8 from home office or other books that do not give rise to U.S. booked liabilities (from Schedule H (Form 1120-F), line 20) Other expense/deduction items with differences (attach schedule) Total expense/deduction items. Combine lines 1 through 32. Enter here and on Part II, line 26
Schedule M-3 (Form 1120-F) 2008
32 33