IRS · Official form

Form 1120-F, U.S. Income Tax Return of a Foreign Corporation

Form 1120-F is the U.S. income tax return for foreign corporations. It covers both income effectively connected with a U.S. trade or business and U.S.-source income taxed on a gross basis.

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What is 1120-F?

A foreign corporation uses Form 1120-F to report its U.S. income, gains, losses, deductions, and credits and to figure its U.S. income tax liability. The return separates income into sections: Section I for U.S.-source income not connected with a U.S. business (typically taxed at a flat rate on the gross amount), and Section II for income effectively connected with a U.S. trade or business, which is taxed on a net basis like a domestic corporation’s income.

The form also handles the branch profits tax in Section III and carries supporting schedules for interest expense allocation, deductions tied to effectively connected income, and treaty-based positions. Corporations with $10 million or more in reportable assets complete Schedule M-3 to reconcile book and taxable income.

Who files 1120-F?

Foreign corporations engaged in a trade or business in the United States, whether or not they had U.S. income
Foreign corporations with U.S.-source income whose tax was not fully satisfied by withholding at source
Foreign corporations filing to claim a refund, a treaty-based position, or deductions and credits
Some filers claim exclusions such as section 883 for international shipping or aircraft income on this return

How to fill out 1120-F

Complete the header with the corporation’s name, country of incorporation, U.S. EIN, and the questions about U.S. business activity.
Report U.S.-source income not effectively connected with a U.S. business in Section I, along with the withholding already applied.
Report effectively connected income and deductions in Section II to reach net taxable income.
Work through Section III for the branch profits tax and tax on excess interest, if they apply.
Download the completed PDF and file by the due date in the current instructions, which depends on whether the corporation has a U.S. office.

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Page 1 76 fields

Page 2 48 fields

Page 3 39 fields

Page 4 57 fields

Name of treaty country, if any

Row: 1. Interest. Column: (b) Gross amount.

Row: 1. Interest. Column: (c) Rate of tax (%).

Row: 1. Interest. Column: (d) Amount of tax liability.

Row: 1. Interest. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 2a. Dividends (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (b) Gross amount.

Row: 2a. Dividends (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (c) Rate of tax (%).

Row: 2a. Dividends (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (d) Amount of tax liability.

Row: 2a. Dividends (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (e) Amount of U.S. income

Row: 2b. Dividend equivalents (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (b) Gross amount.

Row: 2b. Dividend equivalents (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (c) Rate of tax

Row: 2b. Dividend equivalents (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (d) Amount of

Row: 2b. Dividend equivalents (excluding payments received by Q D Ds in their equity derivatives dealer capacity). Column: (e) Amount of

Row: 3. Rents. Column: (b) Gross amount.

Row: 3. Rents. Column: (c) Rate of tax (%).

Row: 3. Rents. Column: (d) Amount of tax liability.

Row: 3. Rents. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 4. Royalties. Column: (b) Gross amount.

Row: 4. Royalties. Column: (c) Rate of tax (%).

Row: 4. Royalties. Column: (d) Amount of tax liability.

Row: 4. Royalties. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 5. Annuities. Column: (b) Gross amount.

Row: 5. Annuities. Column: (c) Rate of tax (%).

Row: 5. Annuities. Column: (d) Amount of tax liability.

Row: 5. Annuities. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 6. Gains from disposal of timber, coal, or domestic iron ore with a retained economic interest (attach supporting statement). Column:

Row: 7. Gains from sale or exchange of patents, copyrights, etc. Column: (b) Gross amount.

Row: 7. Gains from sale or exchange of patents, copyrights, etc. Column: (c) Rate of tax (%).

Row: 7. Gains from sale or exchange of patents, copyrights, etc. Column: (d) Amount of tax liability.

Row: 7. Gains from sale or exchange of patents, copyrights, etc. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 8. Fiduciary distributions (attach supporting statement). Column: (b) Gross amount.

Row: 8. Fiduciary distributions (attach supporting statement). Column: (c) Rate of tax (%).

Row: 8. Fiduciary distributions (attach supporting statement). Column: (d) Amount of tax liability.

Row: 8. Fiduciary distributions (attach supporting statement). Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 9. Gross transportation income (see instructions). Column: (b) Gross amount.

Row: 9. Gross transportation income (see instructions). Column: (d) Amount of tax liability.

Row: 10. 1. Other items of income. Column: (b) Gross amount.

Row: 10. 1. Other items of income. Column: (c) Rate of tax (%).

Row: 10. 1. Other items of income. Column: (d) Amount of tax liability.

Row: 10. 1. Other items of income. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 10. 2. Other items of income. Specify.

Row: 10. 2. Other items of income. Column: (b) Gross amount.

Row: 10. 2. Other items of income. Column: (c) Rate of tax (%).

Row: 10. 2. Other items of income. Column: (d) Amount of tax liability.

Row: 10. 2. Other items of income. Column: (e) Amount of U.S. income tax paid or withheld at the source.

Row: 10. 3. Other items of income. Specify.

Row: 10. 3. Other items of income. Column: (b) Gross amount.

Row: 10. 3. Other items of income. Column: (c) Rate of tax (%).

Row: 10. 3. Other items of income. Column: (d) Amount of tax liability.

Row: 10. 3. Other items of income. Column: (e) Amount of U.S. income tax paid or withheld at the source.

11. Total. Enter here and on line 1, page 1. (d) Amount of tax liability.

12. Total. Enter here and include on line 5i, page 1. (e) Amount of U.S. income tax paid or withheld at the source.

13. Is the corporation fiscally transparent under the laws of the foreign jurisdiction with respect to any item of income listed above?

13. No.

Page 5 34 fields

Gross receipts or sales

b Less returns and allowances

1c. Bal.

2. Cost of goods sold (attach Form 1125-A).

3. Gross profit (subtract line 2 from line 1c).

4. Dividends (Schedule C, line 13).

5. Interest.

6. Gross rents.

7. Gross royalties.

8. Capital gain net income (attach Schedule D (Form 1120)).

9. Net gain or (loss) from Form 4797, Part I I, line 17 (attach Form 4797).

10. Other income (see instructions —attach statement).

11. Total income. Add lines 3 through 10.

12. Compensation of officers (see instructions —attach Form 1125-E).

13. Salaries and wages (less employment credits).

14. Repairs and maintenance.

15. Bad debts (for bad debts over $500,000, attach a list of debtors and amounts).

16. Rents.

17. Taxes and licenses.

18. Interest expense from Schedule I, line 25 (see instructions).

19. Charitable contributions.

20. Depreciation from Form 4562 not claimed on Form 1125-A or elsewhere on return (attach Form 4562).

21. Depletion.

22. Advertising.

23. Pension, profit-sharing, etc., plans.

24. Employee benefit programs.

26. Deductions allocated and apportioned to E C I from Schedule H, line 20 (see instructions).

27. Other deductions (attach statement).

28. Total deductions. Add lines 12 through 27.

29. Taxable income before N O L deduction and special deductions (subtract line 28 from line 11).

30. Less: a. Net operating loss deduction (see instructions).

30b. Special deductions (Schedule C, line 14).

30c. Add lines 30a and 30b.

31. Taxable income or (loss). Subtract line 30c from line 29.

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Dividends from less-than-20%-owned domestic corporations (other than debt-financed stock). Column: (a) Dividends.

Row: 1. Dividends from less-than-20%-owned domestic corporations (other than debt-financed stock). Column: (c) Special deductions: (a)

Row: 2. Dividends from 20%-or-more-owned domestic corporations (other than debt-financed stock). Column: (a) Dividends.

Row: 2. Dividends from 20%-or-more-owned domestic corporations (other than debt-financed stock). Column: (c) Special deductions: (a)

Row: 3. Dividends on certain debt-financed stock of domestic and foreign corporations (section 246A). Column: (a) Dividends.

Row: 3. Dividends on certain debt-financed stock of domestic and foreign corporations (section 246A). Column: (c) Special deductions: (a)

Row: 4. Dividends on certain preferred stock of less-than-20%-owned public utilities. Column: (a) Dividends.

Row: 4. Dividends on certain preferred stock of less-than-20%-owned public utilities. Column: (c) Special deductions: (a) multiplied by (b).

Row: 5. Dividends on certain preferred stock of 20%-or-more-owned public utilities. Column: (a) Dividends.

Row: 5. Dividends on certain preferred stock of 20%-or-more-owned public utilities. Column: (c) Special deductions: (a) multiplied by (b).

Row: 6. Dividends from less-than-20%-owned foreign corporations. Column: (a) Dividends.

Row: 6. Dividends from less-than-20%-owned foreign corporations. Column: (c) Special deductions: (a) multiplied by (b).

Row: 7. Dividends from 20%-or-more-owned foreign corporations. Column: (a) Dividends.

Row: 7. Dividends from 20%-or-more-owned foreign corporations. Column: (c) Special deductions: (a) multiplied by (b).

Row: 8. Subtotal. Add lines 1 through 7. See instructions for limitation. Column: (a) Dividends.

Row: 8. Subtotal. Add lines 1 through 7. See instructions for limitation. Column: (c) Special deductions: (a) multiplied by (b).

Row: 9. Dividends from foreign corporations not included on line 3, 6, or 7. Column: (a) Dividends.

Row: 10. I C-D I S C and former D I S C dividends not included on line 1, 2, or 3 (section 246(d)). Column: (a) Dividends.

Row: 11. Other dividends. Column: (a) Dividends.

Row: 12. Deduction for dividends paid on certain preferred stock of public utilities. Column: (c) Special deductions: (a) multiplied by (b).

Row: 13. Total dividends. Add column (a), lines 8 through 11. Enter here and on line 4, page 5. Column: (a) Dividends.

14. Total special deductions. Add column (c), lines 8 and 12. Enter here and on line 30b, page 5.

Schedule J. Tax Computation (see instructions). 1. Income tax.

2a. Base erosion minimum tax amount (attach Form 8991).

2b. Amount from Form 4255, Part I, line 3, column (q).

2c. Other chapter 1 tax.

3. Corporate alternative minimum tax from Form 4626, Part I I, line 13 (attach Form 4626).

4. Add lines 1, 2a, 2b, 2c, and 3.

5a. Foreign tax credit (attach Form 1118).

5b. General business credit (see instructions—attach Form 3800).

5c. Credit for prior year minimum tax (attach Form 8827).

5d. Bond credits from Form 8912.

6. Total credits. Add lines 5a through 5d.

7. Subtract line 6 from line 4.

8a. Amount from Form 4255, Part I, line 3, column (r).

8b. Recapture of low-income housing credit (attach Form 8611).

8c. Completed long–term contract look–back interest due (attach Form 8697).

8d. Interest due under the look-back method -- income forecast method (attach Form 8866).

8e. Alternative tax on qualifying shipping activities (attach Form 8902).

8f. Other (attach statement).

8z. Total other taxes (add lines 8a through 8f).

9. Total tax. Add lines 7 and 8z. Enter here and on line 2, page 1.

Page 7 25 fields

1. Enter the amount from Section I I, line 29.

2. Enter total adjustments to line 1 to get effectively connected earnings and profits. (Attach required statement showing the nature and

3. Effectively connected earnings and profits. Combine line 1 and line 2.

4a. Enter U.S. net equity at the end of the current tax year. (Attach required statement.).

4b. Enter U.S. net equity at the end of the prior tax year. (Attach required statement.).

4c. Increase in U.S. net equity. If line 4a is greater than or equal to line 4b, subtract line 4b from line 4a. Enter the result here and

4d. Decrease in U.S. net equity. If line 4b is greater than line 4a, subtract line 4a from line 4b.

4e. Non-previously taxed accumulated effectively connected earnings and profits. Enter excess, if any, of effectively connected earnings

5. Dividend equivalent amount. Subtract line 4c from line 3. If zero or less, enter 0. If no amount is entered on line 4c, add the lesser

6. Branch profits tax. Multiply line 5 by 30% (0.30) (or lower treaty rate if the corporation is a qualified resident or otherwise

7a. Enter the interest from Section I I, line 18.

7b. Enter the inverse of the total amount deferred, capitalized, and disallowed from Schedule I, line 24g (that is, if line 24g is

7c. Combine lines 7a and 7b (amount must equal Schedule I, line 23).

8. Branch Interest (see instructions for definition): Enter the sum of Schedule I, line 9, column (c), and Schedule I, line 22. If the

8. Amount.

9a. Excess interest. Subtract line 8 from line 7c. If zero or less, enter 0.

9b. If the foreign corporation is a bank, enter the excess interest treated as interest on deposits (see instructions for rules for

9c. Subtract line 9b from line 9a.

10. Tax on excess interest. Multiply line 9c by 30% (0.30) (or lower treaty rate if the corporation is a qualified resident or otherwise

11. Is the corporation claiming a reduction in, or exemption from, the branch profits tax due to: a. A complete termination of all U.S.

11a. No.

11b. The tax-free liquidation or reorganization of a foreign corporation? Yes. If 11a or 11b applies and the transferee is a domestic

11b. No.

11c. The tax-free incorporation of a U.S. trade or business? Yes. If 11c applies, attach the statement required by Temporary Regulations

11c. No.

Page 8 98 fields

U.S. basis or

Worldwide basis

Row: 1. Cash. Column: Beginning of tax year. (b).

Row: 1. Cash. Column: End of tax year. (d).

Row: 2a. Trade notes and accounts receivable. Column: Beginning of tax year. (a).

Row: 2a. Trade notes and accounts receivable. Column: End of tax year. (c).

Row: 2b. Less allowance for bad debts. Column: Open parenthesis. Beginning of tax year. (a). Close parenthesis.

Row: 2b. Less allowance for bad debts. Column: Beginning of tax year. (b).

Row: 2b. Less allowance for bad debts. Column: Open parenthesis. End of tax year. (c). Close parenthesis.

Row: 2b. Less allowance for bad debts. Column: End of tax year. (d).

Row: 3. Inventories. Column: Beginning of tax year. (b).

Row: 3. Inventories. Column: End of tax year. (d).

Row: 4. U.S. government obligations. Column: Beginning of tax year. (b).

Row: 4. U.S. government obligations. Column: End of tax year. (d).

Row: 5. Tax-exempt securities (see instructions). Column: Beginning of tax year. (b).

Row: 5. Tax-exempt securities (see instructions). Column: End of tax year. (d).

Row: 6a. Interbranch current assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 6a. Interbranch current assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 6b. Other current non-U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 6b. Other current non-U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 6c. Other current U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 6c. Other current U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 7. Loans to shareholders. Column: Beginning of tax year. (b).

Row: 7. Loans to shareholders. Column: End of tax year. (d).

Row: 8. Mortgage and real estate loans. Column: Beginning of tax year. (b).

Row: 8. Mortgage and real estate loans. Column: End of tax year. (d).

Row: 9a. Other loans and investments—non-U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 9a. Other loans and investments—non-U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 9b. Other loans and investments—U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 9b. Other loans and investments—U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 10a. Buildings and other depreciable assets. Column: Beginning of tax year. (a).

Row: 10a. Buildings and other depreciable assets. Column: End of tax year. (c).

Row: 10b. Less accumulated depreciation. Column: Open parenthesis. Beginning of tax year. (a). Close parenthesis.

Row: 10b. Less accumulated depreciation. Column: Beginning of tax year. (b).

Row: 10b. Less accumulated depreciation. Column: Open parenthesis. End of tax year. (c). Close parenthesis.

Row: 10b. Less accumulated depreciation. Column: End of tax year. (d).

Row: 11a. Depletable assets. Column: Beginning of tax year. (a).

Row: 11a. Depletable assets. Column: End of tax year. (c).

Row: 11b. Less accumulated depletion. Column: Open parenthesis. Beginning of tax year. (a). Close parenthesis.

Row: 11b. Less accumulated depletion. Column: Beginning of tax year. (b).

Row: 11b. Less accumulated depletion. Column: Open parenthesis. End of tax year. (c). Close parenthesis.

Row: 11b. Less accumulated depletion. Column: End of tax year. (d).

Row: 12. Land (net of any amortization). Column: Beginning of tax year. (b).

Row: 12. Land (net of any amortization). Column: End of tax year. (d).

Row: 13a. Intangible assets (amortizable only). Column: Beginning of tax year. (a).

Row: 13a. Intangible assets (amortizable only). Column: End of tax year. (c).

Row: 13b. Less accumulated amortization. Column: Open parenthesis. Beginning of tax year. (a). Close parenthesis.

Row: 13b. Less accumulated amortization. Column: Beginning of tax year. (b).

Row: 13b. Less accumulated amortization. Column: Open parenthesis. End of tax year. (c). Close parenthesis.

Row: 13b. Less accumulated amortization. Column: End of tax year. (d).

Row: 14. Assets held in trust. Column: Beginning of tax year. (b).

Row: 14. Assets held in trust. Column: End of tax year. (d).

Row: 15. Other non-current interbranch assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 15. Other non-current interbranch assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 16a. Other non-current non-U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 16a. Other non-current non-U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 16b. Other non-current U.S. assets*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 16b. Other non-current U.S. assets*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 17. Total assets. Column: Beginning of tax year. (b).

Row: 17. Total assets. Column: End of tax year. (d).

Row: 18. Accounts payable. Column: Beginning of tax year. (b).

Row: 18. Accounts payable. Column: End of tax year. (d).

Row: 19. Mortgages, notes, bonds payable in less than 1 year: a. Interbranch liabilities*. * Attach statement—see instructions. Column:

Row: 19. Mortgages, notes, bonds payable in less than 1 year: a. Interbranch liabilities*. * Attach statement—see instructions. Column: End

Row: 19. Mortgages, notes, bonds payable in less than 1 year: b. Third-party liabilities*. * Attach statement—see instructions. Column:

Row: 19. Mortgages, notes, bonds payable in less than 1 year: b. Third-party liabilities*. * Attach statement—see instructions. Column: End

Row: 20. Other current liabilities*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 20. Other current liabilities*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 21. Loans from shareholders. Column: Beginning of tax year. (b).

Row: 21. Loans from shareholders. Column: End of tax year. (d).

Row: 22. Mortgages, notes, bonds payable in 1 year or more: a. Interbranch liabilities*. * Attach statement—see instructions. Column:

Row: 22. Mortgages, notes, bonds payable in 1 year or more: a. Interbranch liabilities*. * Attach statement—see instructions. Column: End

Row: 22. Mortgages, notes, bonds payable in 1 year or more: b. Third-party liabilities*. * Attach statement—see instructions. Column:

Row: 22. Mortgages, notes, bonds payable in 1 year or more: b. Third-party liabilities*. * Attach statement—see instructions. Column: End

Row: 23. Liabilities held in trust. Column: Beginning of tax year. (b).

Row: 23. Liabilities held in trust. Column: End of tax year. (d).

Row: 24a. Other interbranch liabilities*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 24a. Other interbranch liabilities*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 24b. Other third-party liabilities*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 24b. Other third-party liabilities*. * Attach statement—see instructions. Column: End of tax year. (d).

Equity. Row: 25. Capital stock: a. Preferred stock. Column: Beginning of tax year. (a).

Row: 25. Capital stock: a. Preferred stock. Column: End of tax year. (c).

Row: 25. Capital stock: b. Common stock. Column: Beginning of tax year. (a).

Row: 25. Capital stock. b. Common stock. Column: Beginning of tax year. (b).

Row: 25. Capital stock: b. Common stock. Column: End of tax year. (c).

Row: 25. Capital stock. b. Common stock. Column: End of tax year. (d).

Row: 26. Additional paid-in capital. Column: Beginning of tax year. (b).

Row: 26. Additional paid-in capital. Column: End of tax year. (d).

Row: 27. Retained earnings—Appropriated*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 27. Retained earnings—Appropriated*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 28. Retained earnings—Unappropriated. Column: Beginning of tax year. (b).

Row: 28. Retained earnings—Unappropriated. Column: End of tax year. (d).

Row: 29. Adjustments to shareholders' equity*. * Attach statement—see instructions. Column: Beginning of tax year. (b).

Row: 29. Adjustments to shareholders' equity*. * Attach statement—see instructions. Column: End of tax year. (d).

Row: 30. Less cost of treasury stock. Column: Open parenthesis. Beginning of tax year. (b). Close parenthesis.

Row: 30. Less cost of treasury stock. Column: Open parenthesis. End of tax year. (d). Close parenthesis.

Row: 31. Total liabilities and shareholders' equity. Column: Beginning of tax year. (b).

Row: 31. Total liabilities and shareholders' equity. Column: End of tax year. (d).

Page 9 7 fields

1. Total Chapter 3 and 4 payments. Enter the amount from page 1, line 5i.

2. Enter the tax amount from page 1, line 1. Dollars.

3. Enter the portion of the tax amount shown on page 1, line 2, pertaining to income associated with amounts deducted and withheld under

4. Total Chapter 3 and 4 tax. Combine lines 2 and 3.

5. Tentative overpayment resulting from tax deducted and withheld under Chapters 3 and 4. Subtract line 4 from line 1.

6. Enter the amount from page 1, line 8a.

7. Overpayment resulting from tax deducted and withheld under Chapters 3 and 4. Enter the smaller of line 5 or line 6. Enter the result

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Frequently asked questions

Does a foreign corporation with no U.S. income ever need to file?

Often yes. A foreign corporation engaged in a U.S. trade or business generally files Form 1120-F even if it had no effectively connected income, and filing protects the right to claim deductions and credits.

What is effectively connected income?

Income tied to the conduct of a trade or business in the United States. It is taxed on a net basis at regular corporate rates, unlike passive U.S.-source income, which is generally taxed at a flat rate on the gross amount, often collected through withholding.

Can a tax treaty change what goes on Form 1120-F?

Yes. Treaties can reduce rates or exempt business profits not attributable to a U.S. permanent establishment. Treaty-based return positions are typically disclosed on Form 8833 attached to the return.

Form 1120-F, U.S. Income Tax Return of a Foreign Corporation

What is 1120-F?

Who files 1120-F?

How to fill out 1120-F

Quick fill 1120-F on this page

Frequently asked questions

Related forms

Form 1120, U.S. Corporation Income Tax Return

Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b)