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Form 1120-F Instruktioner for Planlægning V

Vejledning til tidsplan V (form 1120-F), Liste over Vessels eller fly, operatører og ejere

Rev. december 2022

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Department of the Treasury  
Internal Revenue Service  
Instructions for Schedule V  
(Form 1120-F)  
(Rev. December 2022)  
List of Vessels or Aircraft, Operators, and Owners  
Section references are to the Internal Revenue  
Code unless otherwise noted.  
arrangement, as a partner in a  
partnership, or as the beneficiary of a trust  
or estate.  
includes income derived from demurrage,  
dispatch, and dead freight.  
2. Off board services. Income in this  
Future Developments  
category is derived from services  
The term “transportation income” (as  
defined in section 863(c)(3)) means any  
income derived from, or in connection  
with:  
For the latest information about  
performed off board any vessel or aircraft  
by an operator of a vessel or aircraft,  
provided such services are incidental to  
the operation of vessels or aircraft by such  
operator. The term does not include  
income from services performed by  
persons other than an operator. Examples  
of off board services include terminal  
services such as dockage, wharfage,  
storage, lights, water, refrigeration,  
refueling and similar services; stevedoring  
and other cargo handling services;  
developments related to Schedule V  
(Form 1120-F) and its instructions, such  
as legislation enacted after they were  
published, go to IRS.gov/Form1120F.  
The use (or hiring or leasing for use) of  
any vessel or aircraft, or  
The performance of services directly  
General Instructions  
related to the use of any vessel or aircraft.  
The term “vessel” or “aircraft” includes  
any container used in connection with a  
vessel or aircraft. However, the term  
“transportation income” does not include  
income from the disposition of vessels,  
containers, or aircraft.  
Purpose of Schedule  
Schedule V (Form 1120-F) is used by a  
foreign corporation to report basic  
information for each vessel or aircraft with  
respect to which the corporation is subject  
to the 4% rate of tax on U.S. source gross  
transportation income (USSGTI) under  
section 887.  
maintenance and repairs; and services  
performed as a travel or booking agent.  
The term “income derived from, or in  
connection with, the use (or hiring or  
leasing for use) of any vessel or aircraft”  
means:  
The term “operator” includes the actual  
operator of a vessel or aircraft, as well as  
a time or voyage charterer of such vessel  
or aircraft.  
Who Must File  
Income derived from transporting  
Foreign corporations that are subject to  
the 4% tax on their USSGTI under section  
887 must complete Schedule V.  
passengers or property by vessel or  
aircraft;  
Specific Instructions  
Income derived from hiring or leasing a  
Important. All information reported on  
Schedule V must be in English. All  
amounts must be stated in U.S. dollars.  
vessel or aircraft for use in the  
transportation of passengers or property  
on the vessel or aircraft; and  
When and Where To File  
Attach Schedule V (Form 1120-F) to the  
foreign corporation's Form 1120-F income  
tax return. See the Instructions for Form  
1120-F for the time, place, and manner for  
filing the corporation's income tax return.  
Throughout these instructions, when  
the pronouns “you” and “your” are used,  
they are used in reference to the foreign  
corporation filing Form 1120-F, U.S.  
Income Tax Return of a Foreign  
Corporation.  
Income derived by an operator of  
vessels or aircraft from the rental or use of  
containers and related equipment  
(container related income) in connection  
with, or incidental to, the transportation of  
cargo on such vessels or aircraft by the  
operator. Persons other than an operator  
of a vessel or aircraft do not derive  
container related income. Such income is  
treated as rental income, not  
Definitions  
Columns A through D. Complete a  
separate column for each vessel or aircraft  
with respect to which you are subject to a  
4% rate of tax under section 887. For  
example:  
The term “United States source gross  
transportation income (USSGTI)” means  
any gross income (without reduction by  
any deductions or losses) that is  
transportation income (as defined in  
section 863(c)(3)) to the extent such  
income is treated as from sources within  
the United States under section 863(c)(2)  
(A).  
transportation income.  
If you were a bareboat lessor of vessels  
The term “income derived from, or in  
connection with, the performance of  
services directly related to the use of a  
vessel or aircraft” includes the following  
categories of income.  
or aircraft during the tax year, complete a  
separate column for each vessel or aircraft  
you leased out during the tax year for  
which you derived USSGTI.  
If you earned income during the tax  
The term does not include  
year from the operation of vessels or  
aircraft, including time or voyage charter  
hire, complete a separate column for each  
vessel or aircraft operated by you during  
the tax year for which you derived  
USSGTI.  
1. On board services. Income in this  
transportation income which is:  
category is derived from services  
Not sourced under section 863(c)(2);  
Taxable as effectively connected with  
performed on board a vessel or aircraft in  
the course of the actual transportation of  
passengers or property aboard vessels or  
aircraft. Examples of income in this  
category include income from renting  
staterooms, berths, or living  
the corporation's trade or business in the  
United States pursuant to section 887(b)  
(4); or  
If you earned income during the tax  
Taxable in a possession of the United  
year from providing services directly  
related to the use of vessels or aircraft,  
complete a separate column for each  
vessel or aircraft for which such services  
were performed and for which you derived  
USSGTI.  
States under a provision of the Code, as  
made applicable in such possession.  
accommodations; furnishing meals and  
entertainment; operating shops and  
casinos; providing excess baggage  
storage; and the performance of personal  
services by individuals. The term also  
Note. Foreign corporations may derive  
USSGTI directly, from participation in a  
pool, joint venture, joint service  
Dec 12, 2022  
Cat. No. 51664Q  
If you derive USSGTI subject to a 4%  
rate of tax under section 887 from more  
than four vessels or aircraft, attach  
continuation statements using the same  
size and format as this Schedule V.  
5. A description of the method used to method of determining the portion of such  
determine the USSGTI from the leases for  
the vessel or aircraft, and the calculations  
charter income which is USSGTI is to  
apply to such charter income the ratio of  
used to apply this method (see the Note in (a) the number of days of uninterrupted  
the instructions for line 9 for examples of  
reasonable methods that may be used).  
travel on voyages or flights between the  
United States and the farthest point(s)  
where cargo or passengers are loaded en  
route to, or discharged en route from, the  
United States, to (b) the number of days in  
the smaller of the tax year or the particular  
charter period. When determining  
Line 1. Enter the name of the vessel or  
type of aircraft.  
Line 5. Enter the name of the registered  
owner. If you are the registered owner,  
enter “Same as filer above” on line 5.  
Line 2. For each column, if you are  
completing the column for a vessel, enter  
the Lloyd's register number on line 2. If  
you are completing the column for an  
aircraft, enter the registration number on  
line 2.  
Line 6. Enter the employer identification  
number (EIN) or social security number  
(SSN) of the registered owner, if known. If  
you are the registered owner, enter “Same  
as filer above” on line 6. If you are not the  
registered owner and you do not know the  
EIN or SSN of the registered owner, enter  
"Not known."  
USSGTI, the number of days the vessel is  
located in United States waters for repairs  
or maintenance should not be included in  
either the numerator or in the denominator  
of the ratio.  
Line 3. For each column, if the answer to  
the question on line 3 is “Yes” and you  
operate the vessel or aircraft which is  
under a bareboat lease or sublease to  
you, attach to Schedule V the following  
items.  
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  
Line 7. Enter the name of the operator, if  
known. If you are the operator, enter  
1. The name and address of the  
“Same as filer above” on line 7. If you are  
not the operator and you do not know the  
name of the operator, enter "Not known."  
lessee-operator from the operation of the  
vessel or aircraft during the smaller of the  
tax year or the term of the charter.  
lessor of the vessel or aircraft.  
2. The term of the bareboat lease or  
charter and the method for calculating the  
rental portion of the payment.  
Line 8. Enter the EIN or SSN of the  
operator, if known. If you are the operator,  
enter “Same as filer above” on line 8. If  
you are not the operator and you do not  
know the EIN or SSN of the operator,  
enter "Not known."  
However, an allocation based on the net  
income of the lessee-operator will not be  
considered reasonable for this purpose.  
Line 4. For each column, if the answer to  
the question on line 4 is “Yes” and you are  
the bareboat lessor of the vessel or  
aircraft, attach to Schedule V the following  
items.  
Important. You must attach a statement  
to Schedule V describing the method used  
to determine the USSGTI from the vessel  
or aircraft.  
Line 9. For each column, enter the  
USSGTI the corporation derived with  
respect to the vessel or aircraft. See  
Definitions, earlier.  
1. The country of registration of the  
Line 11. If the foreign corporation is  
claiming a treaty exemption on its  
USSGTI, enter the amount on line 11 and  
attach Form 8833, Treaty-Based Return  
Position Disclosure Under Section 6114 or  
7701(b).  
vessel or aircraft.  
2. Name and address of each lessee  
or person chartering the vessel or aircraft  
from you.  
Note. In determining the amount of  
USSGTI, the foreign corporation must  
establish the actual amount of USSGTI  
derived from a charter under a reasonable  
method. For example, where a vessel or  
aircraft is under charter, one reasonable  
3. The term of the lease.  
4. The number of days during the tax  
year the vessel or aircraft was under  
lease.  
Instructions for Schedule V (Form 1120-F) (12-2022)  
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