For more information on consolidated
A corporation filing Form 1120-PC that is
loss of a foreign corporation electing to be
returns, see the regulations under section
not required to file Schedule M-3 may
treated as a domestic insurance company
1502.
voluntarily file Schedule M-3 instead of
under section 953(d) will be treated as a
Schedule M-1.
dual-consolidated loss and may not be
Note. If a nonlife insurance company is a
used to reduce the taxable income of any
member of an affiliated group, file Form
If you are filing Schedule M-3 (Form
other member of the affiliated group for
1120-PC as an attachment to the
1120-PC), check item A, box 3 at the top
this tax year or any other tax year.
consolidated return in addition to the
of page 1 of Form 1120-PC. See the
supporting statements discussed above.
Instructions for Schedule M-3 (Form
Note. If a section 953(d) election is
Across the top of page 1 of Form
1120-PC) for more details.
made, include the additional tax required
1120-PC, write “Supporting Statement to
to be paid, on line 13, page 1. On the
Note. If you do not file Schedule M-3
Consolidated Return.”
dotted line to the left of line 13, page 1,
(Form 1120-PC) with Form 1120-PC, see
write “Section 953(d)” and the amount.
Reconciliation under Statements on page
Life-Nonlife Consolidated
Attach a schedule showing the
3.
Return
computation. See section 953(d) for more
details.
If the corporation is the common parent of
Item B. Employer
a life-nonlife consolidated group, check
boxes 1 and 2 of Item A.
Identification Number (EIN) Item E. Final Return, Name
Change, Address Change,
Filing requirements. The common
Enter the corporation’s EIN. If the
parent of a life-nonlife consolidated group
corporation does not have an EIN, it must
or Amended Return
is required to do the following.
apply for one. An EIN can be applied for:
•
Online — Click on the EIN link at
•
Indicate a final return, name change,
File the applicable consolidated
The EIN is
corporate income tax return, as a Form
address change, or amended return by
issued immediately once the application
1120-L, U.S. Life Insurance Company
checking the appropriate box.
information is validated.
Income Tax Return, where the common
•
By telephone at 1-800-829-4933.
Note. If a change of address occurs after
parent is a life insurance company; a
•
By faxing or mailing Form SS-4,
the return is filed, use Form 8822-B,
Form 1120-PC, U.S. Property and
Application for Employer Identification
Casualty Insurance Company Income Tax
Change of Address — Business, to notify
Number.
Return, where the common parent is an
the IRS of the new address.
insurance company, other than a life
If the corporation has not received its
insurance company; or a Form 1120, U.S.
Taxable Income
EIN by the time the return is due, enter
Corporation Income Tax Return, where
“Applied for” and the date you applied in
the common parent is any other type of
Line 1, Taxable income, and line 2,
the space for the EIN. For more
corporation.
Taxable investment income. If the
information, see the Instructions for Form
•
Indicate clearly on the face of this
corporation is a small company as
SS-4.
return that such corporate tax return is a
defined in section 831(b)(2) and elects
life-nonlife return. This requirement is
under section 831(b)(2)(A)(ii) to be taxed
Only corporations located in the
satisfied by checking boxes 1 and 2 of
on taxable investment income, complete
!
United States or U.S. possessions
Item A on page 1.
Schedule B (ignore Schedule A) and
can use the online application.
CAUTION
•
enter the amount from Schedule B, line
Show any set offs required by
Foreign corporations must use one of the
paragraphs (g), (m), and (n) of
other methods to apply.
21, on line 2, page 1. All other
Regulations section 1.1502-47;
corporations should complete Schedule A
(ignore Schedule B) and enter on line 1,
•
Report separately the nonlife
Item D. Section 953
page 1, the amount from Schedule A, line
consolidated taxable income or loss,
Elections
37.
determined under Regulations section
1.1502-47(h), on a Form 1120 or
Check the applicable box if the
1120-PC (whether filed by the common
Tax Computation and
corporation is a foreign corporation and
parent or as an attachment to the
elects under:
Payments
consolidated return), for all nonlife
1. Section 953(c)(3)(C) to treat its
members of the consolidated group.
related person insurance income as
Line 3
•
Report separately the consolidated
effectively connected with the conduct of
partial Life Insurance Company Taxable
a trade or business in the United States
If the corporation is a member of a
Income (as defined by Regulations
or
controlled group, check the box on line 3.
section 1.1502-47(d)(3)) determined
2. Section 953(d) to be treated as a
Complete and attach Schedule O (Form
under Regulations section 1.1502-47, on
domestic corporation.
1120), Consent Plan and Apportionment
a Form 1120-L (whether filed by the
Schedule for a Controlled Group.
common parent or as an attachment to
Component members of a controlled
Generally, a foreign corporation
the consolidated return), for all life
group must use Schedule O to report the
making either election must file its return
members of the consolidated group.
with the Internal Revenue Service Center,
apportionment of taxable income, income
P.O. Box 409101, Ogden, UT 84409. See
tax, and certain tax benefits between the
Schedule M-3 (Form 1120-PC)
Notice 87-50, 1987-2 C.B. 357, and Rev.
members of the group. See Schedule O
A nonlife insurance company with total
Proc. 2003-47, 2003-28 I.R.B. 55, for the
and the instructions for Schedule O for
assets (non-consolidated or consolidated
procedural rules, election statement
more information.
for all companies included within a tax
formats, and filing addresses for making
consolidation group) of $10 million or
the respective elections under section
Line 4
more on the last day of the tax year must
953(c)(3)(C) or section 953(d).
If the corporation is a member of a
complete Schedule M-3 (Form 1120-PC),
controlled group and is filing Schedule O
Net Income (Loss) Reconciliation for U.S.
Note. Once either election is made, it will
(Form 1120), enter the corporation’s tax
Property and Casualty Insurance
apply to the tax year for which made and
from Part III of Schedule O.
Companies With Total Assets of $10
all subsequent tax years unless revoked
Million or More, instead of Schedule M-1.
with the consent of the IRS. Also, any
-6-
Instructions for Form 1120-PC (2011)