1997 Ad
Kathryn A. GreenFor 1997, U.S. corporations claiming a foreign tax credit earned $157.9 billion in foreign-source taxable income and paid $45.1 billion in income taxes to foreign governments. After limitations, these corporations reported $42.2 billion in foreign tax credits, an increase of $1.9 billion from 1996 [1]. Under the foreign tax credit provisions, these corporations reduced their U.S. tax liability 29.1 percent, from $144.8 billion (U.S. income tax before credits) to $102.6 billion. Other credits, including the U.S. possessions tax credit and the general business credit, further reduced their U.S. income tax liability to $95.8 billion.
Overall, U.S. corporations claiming a foreign tax credit reported "worldwide taxable income" (i.e., both U.S. and foreign-source income) of $410.1 billion. Approximately 38.5 percent of the "worldwide taxable income" was derived from foreign sources. Worldwide income taxes reported for these corporations totaled $144.8 billion, with foreign sources accounting for 31.0 percent of the total.
As in recent years, most foreign-source income was earned by U.S. corporations in manufacturing. Manufacturers accounted for 65.1 percent of the total foreign-source taxable income and 71.9 percent of both the total current-year foreign taxes paid, accrued, or deemed paid, and the total foreign tax credit claimed for 1997. However, the 1990's continued to shift from manufacturing toward corporations classified in the finance, insurance, and real estate industrial division (FIRE). This industrial division has rapidly increased its share of foreign-source taxable income and total foreign tax credit claimed. The share of the total foreign tax credit claimed by finance, insurance, and real estate corporations has more than doubled from 6.6 percent for 1990 to 15.8 percent for 1997.
As in prior years, the United Kingdom, Canada, Japan, Germany, and the Netherlands were the leading sources of foreign income for U.S. corporations claiming the foreign tax credit. With $25.2 billion of the $157.9 billion (or 15.9 percent) in foreign-source taxable income, the United Kingdom provided the largest amount of income. Overall, the 15 nations of the European Union combined for 37.8 percent of foreign-source taxable income, 22.5 percent of current-year taxes paid or accrued, and 48.3 percent of the current-year tax deemed paid.
Background
Since the Income Tax Law of 1913, U.S. taxpayers have been taxed on their worldwide incomes. For U.S. corporations with multinational interests, income earned abroad may be taxed by the jurisdiction where the income is earned and also by the U.S. Government. This results in double taxation of the foreign income. The U.S. has adopted a tax credit method to alleviate this consequence. Under the tax credit method, the U.S. taxes the worldwide income but allows a credit against the U.S. tax liability for the income taxes paid to foreign: countries.
The U.S. was the first 'country to provide a tax credit for income taxes paid to foreign countries. From 1913 through 1917, income and profit taxes paid to foreign countries or U.S. possessions were included in general deductions from gross worldwide income. The Revenue Act of 1918 introduced the foreign tax credit. This provision allowed taxpayers an unlimited credit against U.S. income taxes for any taxes paid to or accrued in a foreign country. In cases where the foreign tax rate exceeded the U.S. tax rate, some U.S. tax on domestic earned income was offset by the credit for taxes paid to a foreign jurisdiction. This loss of revenue from U.S. tax on domestic income led to the development of a foreign tax credit limitation.
The Revenue Act of 1921 introduced the "overall" limitation. This limitation restricts the foreign tax credit to the lesser of 1) the product of the U.S. income tax before credits multiplied by the ratio of foreign-source taxable income to worldwide taxable income, or 2) the actual foreign taxes paid. For various periods in U.S. tax history, this limitation has been a fundamental principal of the foreign tax credit provisions.
While the "overall" limitation restricted the aggregate tax credit, corporations could arrange their business activities in order to maximize the credit of taxes paid in highly-taxed foreign jurisdictions by moving U.S. income, such as investment income, to a foreign jurisdiction with little or no income tax. To prevent this averaging of income from highly taxed foreign jurisdictions with income from low or nontaxed foreign jurisdictions, Congress enacted a "per country" limitation. Under the per country limitation, the limitation on creditable foreign income taxes is computed separately for each country. The per country limitation was operational in various forms from 1932 until 1976. Historically, corporations were required to use: (1) the overall limitation (1921-1932); (2) the lesser of the per country limitation or overall limitation (1932-1954); (3) the per country limitation (1954-1961); or (4) an election of the overall or per-country limitation (1961-1976). The overall limitation remains in effect today.
Regardless of the limitation method required (per country or overall), prior to the enactment of the Revenue Act of 1962, corporations combined all types of foreign income for purposes of computing their foreign tax credit limitations. With the passage of the 1962 Act, corporations were required to compute a separate foreign tax credit limitation for non-business interest income. This legislation was directed toward U.S. corporations with foreign-source income taxed at a higher rate than the U.S. rate. The intent was to discourage these corporations from shifting non-business lower-taxed income overseas. These interest-bearing foreign investments could generate additional foreign income with very little tax, thereby, increasing the limitation on the foreign tax credit. By separating low-taxed non-business income from higher-taxed business income, U.S. corporations were limited in their ability to arrange foreign investments at the expense of U.S. tax revenue.
Subsequent legislation required additional separate foreign tax credit limitations with respect to certain types of foreign income, especially under the Tax Reform Act of 1986. The separation of income types continued to limit U.S. taxpayers' ability to cross credit. The current structure of the statutory categories requires separate treatment for different types of income and income from different industries.
For 1997, taxpayers computed a separate foreign tax credit limitation for each of the following statutory categories of foreign-source income (described in the Explanation of Selected Terms section):
* passive income,
* high withholding tax interest,
* financial services income,
* shipping income,
* income re-sourced by treaty,
* dividends from each "noncontrolled" foreign corporation as defined in Internal Revenue Code section 902,
* dividends from an Interest-Charge Domestic International Sales Corporation (IC-DISC's) or former DISC,
* certain distributions from a Foreign Sales Corporation (FSC) or former FSC,
* taxable income attributable to foreign trade income [2],
* income from sanctioned countries per Internal Revenue Code section 901 (j) [3], and
* all other income from outside the United States (commonly referred to as general limitation income or overall basket).
The foreign tax credit claimed is the sum of credits allowed in each separate category. In certain instances, the total foreign tax credit claimed was reduced for participation in or for cooperation with international boycotts [4].
The treatment of excess or "unused" credits has also varied as the foreign tax credit provisions have developed. From 1921 through 1931, the amount of income and profits taxes paid to foreign countries in excess of that deducted as a tax credit was included in deductions against the gross income. With the Internal Revenue Code of 1939, the foreign taxes in excess of those deducted as a tax credit were instead credited against the excess profits tax. Congress introduced a carryover of excess or "unused" foreign tax credits in the Technical Amendments Act of 1958. These carryover provisions superceded the treatment of excess credits as defined in the Internal Revenue Code of 1939. They directed that any excess taxes that could not be credited because of the current-year limitation could be carried back 2 years (necessitating an amended return) or carried forward 5 years, subject always to the current-year foreign tax credit limitation. In other words, the total foreign taxes under each separate limitation for any given year includes current-year foreign taxes, plus taxes that were carried forward from prior years or, in the case of an amended return, any taxes that were carried back from future years
The foreign tax credit is elective. If the taxpayer elects to take the credit, no deduction for foreign taxes paid is available. In most circumstances, a taxpayer will elect to take the credit, which offsets the U.S. taxes dollar for dollar. Comparatively, the deduction may offset U.S. taxes by only 35 cents for every dollar deducted if the corporation's tax rate were 35.0 percent [5]. To claim a foreign tax credit, a U.S. corporation must have foreign-source taxable income, pay foreign income tax on the foreign income, and have a U.S. income tax liability.
Certain types of foreign taxes or levies are not creditable under U.S. regulations. Common types of non-creditable taxes include soak-up taxes, levies that yield specific economic benefit, levies to certain foreign governments deemed ineligible for the credit, and taxes generated by tax-motivated stock acquisitions. (See Explanation of Selected Terms for definitions.) These taxes can be deducted in calculating the worldwide taxable income, even when the foreign tax credit is elected for foreign income taxes.
Foreign Tax Credit, Tax Year 1993 Through Tax Year 1997
For the 5-year period, 1993-1997, the number of U.S. corporations that elected to credit foreign taxes against their U.S. tax liabilities varied considerably [6]. However, as shown in Figure A, the total worldwide taxable income, U.S. income tax before credits, foreign-source taxable income, current-year foreign taxes, and foreign tax credit claimed by these corporations have grown steadily. This growth is most apparent when comparing the income and taxes for 1993 and 1997. For 1993, some 6,322 corporations reported $228.7 billion in worldwide taxable income (column 2), computed an $81.9-billion U.S. tax liability, and credited nearly $22.9 billion under the foreign tax credit provisions. The number of corporations for 1997 increased less than 4 percent to 6,569. Yet the income subject to U.S. tax, U.S. tax liability, and foreign tax credit amounts each increased by more than 75.0 percent.
Because these U.S. corporations have maintained steady growth both in foreign and domestic source income over this 5-year period, the effect of the foreign tax credit provisions has remained relatively constant. Worldwide income for U.S. corporations increased 79.3 percent from 1993 to 1997. Domestic source income increased 88.2 percent during this period. The foreign-source taxable income as a percentage of income subject to U.S. tax (column 8) remained in the 38-41 percent range, with foreign-source taxable income increasing 66.8 percent overall. The percent of creditable taxes to the U.S. tax liability remained relatively constant during this period. Using the foreign tax credit provisions, U.S. corporations reduced their U.S. tax liabilities annually by nearly 30.0 percent.
Separate Limitation Categories, Tax Year 1997
For 1997, U.S. corporations claiming a foreign tax credit reported $410.1 billion in worldwide taxable income. Over 38.5 percent, almost $158.0 billion, was generated from foreign sources. Much of this foreign income was subject to foreign taxation. Over $45.0 billion of income taxes were paid, accrued, or deemed paid to foreign countries. Under the foreign tax credit provisions, U.S. corporations credited 93.7 percent ($42.2 billion) of their current-year foreign taxes and were able to reduce their U.S. tax liabilities of $144.8 billion by 29.1 percent.
U.S. corporations are required to compute a separate foreign tax credit for each of several statutory categories of income. As Figure B shows, over 70.0 percent of all foreign-sourced taxable income in 1997 was classified as general limitation income. Accordingly, $35.5 billion, or nearly 80.0 percent, of the total current-year foreign taxes were paid on general limitation income. The second largest statutory group, financial service income, accounted for 20 percent of the foreign-sourced taxable income. About 15 percent ($6.9 billion) of the current-year foreign taxes were paid on financial services income.
Current-year foreign taxes as a percentage of foreign-source taxable income, reported in column (3), vary according to the statutory group [7]. General limitation income has the largest percentage of current-year foreign taxes with respect to foreign-source taxable income at 31.4 percent. Shipping income and passive income, two statutory groups that isolate low-tax income, are significantly lower. For 1997, the current-year foreign taxes as a percentage of foreign-source taxable income for these categories were 5.5 percent and 13.7 percent, respectively.
U.S. corporations determine a limitation for each statutory group based on the ratio of foreign income attributable to each income category to their worldwide incomes. For 1997, U.S. corporations were able to credit all of the current-year foreign taxes paid in only one statutory group, shipping income. In addition, 74.4 percent of the carryover in this statutory group was credited. In contrast, U.S. corporations credited 92.9 percent, or over $32.9 billion, of their $35.5 billion current-year foreign taxes paid on general limitation income. Only 85.3 percent of the current year foreign taxes paid on high withholding tax interest income was credited.
Industry Composition
Similar to recent years, manufacturing corporations continued to account for the majority of foreign-source taxable income, current-year taxes, and foreign tax credits (Figure C). U.S. manufacturers were responsible for 65.1 percent of the total $157.9 billion in foreign-source taxable income and nearly 71.9 percent of the total $45.1 billion in current-year foreign taxes. As a result, U.S. manufacturers were able to claim $30.3 billion in foreign tax credits. Figure D shows the foreign tax credit claimed by specific industry groups as a percentage of the total foreign tax credit reported for selected years in the 1990's; manufacturing was the leader in 1997 with 71.8 percent. Within manufacturing, the most significant of the specific industries in terms of foreign-source taxable income, current-year foreign taxes, and foreign tax credits, continued to be producers of petroleum (including those integrated with extraction) and coal products. This minor industry accounted for 16 percent of the total foreign tax credit claimed.
Finance, insurance, and real estate (FIRE) accounts for the second largest source of total foreign-source taxable income (20.2 percent) and generated 14.6 percent of total current-year foreign taxes. Figure D shows that FIRE was the fastest growing industry in terms of foreign tax credits claimed during the 1990's, as its share of the total foreign tax credit increased from 6.6 percent in 1990 to 15.8 percent in 1997.
Using the foreign tax credit as a measurement of industry activity actually understates the growing importance of finance, insurance, and real estate corporations to U.S. businesses, since income in those industries is usually taxed at a much lower rate than manufacturing income and, thus, would generate lower values of creditable foreign taxes. Foreign-source taxable income is a better indication of the relative importance of an industry to U.S. businesses. Since 1990, it has increased 125.8 percent for corporations in finance, insurance, and real estate, compared to an increase of only 47.5 percent for all other industries.
While finance, insurance, and real estate companies became more prominent from 1990 to 1997, it is notable that manufacturing corporations saw an equally steady decline during this period. At the beginning of the decade, manufacturing accounted for 83.1 percent of the total foreign tax credit, but, by 1997, their share had decreased to 71.8 percent. Likewise, manufacturing's share of total foreign-source income declined from 73.9 percent in 1990 to 65.1 percent in 1997.
Oil and Gas Extraction Income
Oil and gas extraction income, deductions, and taxes are reported separately from all other foreign-source income by U.S. corporations claiming a foreign tax credit related to that income. Section 907 of the Internal Revenue Code details how separate rules related to oil and gas extraction income affect the amount of foreign taxes available for corporations to credit. These provisions disallow certain foreign taxes and require another limitation calculation specifically for foreign oil and gas extraction income (FOGEI). Foreign taxes are excluded from the foreign tax credit calculation if they were paid, accrued, or deemed paid at a rate in excess of the applicable U.S. tax rate. Taxes can also be excluded if they were not, in effect, income taxes, but rather royalty payments. Under the foreign tax credit provisions, only income taxes, as viewed through U.S. tax principles, are creditable. This excludes voluntary payments and payments for specific rights (such as the right to extract a natural resource) or services.
Figure E shows gross income from foreign oil and gas extraction by both selected industry groups and selected countries for 1997. Most FOGEI was reported by U.S. corporations classified as manufacturers of petroleum (including integrated) and coal products. For 1997, the oil and gas extraction industry accounted for 9.7 percent of the total oil and gas extraction-related gross income reported. Figure E also lists the countries generating the greatest amounts of gross income associated with foreign oil and gas extraction for 1997. For the fourth year in a row, corporations reported the most gross income from the United Kingdom and Indonesia. Eight countries, the United Kingdom, Indonesia, Norway, Australia, the Netherlands, Malaysia, Canada, and Nigeria, together accounted for 59.7 percent of all gross income from foreign oil and gas extraction activities.
Geographic Focus
For 1997, European countries accounted for a considerable portion of the foreign-source taxable income and current-year taxes (Figures F, G, H, I, and Table 3) reported by U.S. corporations claiming a foreign tax credit. Europe was the source of $66.7 billion (42.2 percent) in taxable income and $20.0 billion (44.4 percent) of the current-year taxes. Specifically, more than one-third of the foreign-sourced taxable income and current-year taxes were reported by U.S. corporations with operations in the European Union (E,U.), Collectively, the E.U. accounted for nearly twice as much foreign-sourced taxable income as the next largest region, Asia.
[FIGURES F & H OMITTED]
Further analysis yields that a small number of countries account for a significant share of foreign-source taxable income as presented in Figure F. Consistently, for the past 5 years, the United Kingdom, Canada, Japan, the Netherlands, and Germany have accounted for approximately 42.2 percent of the total foreign-source taxable income. In 1997, these five countries accounted for over $70.2 billion of the nearly $158.0 billion foreign-source taxable income (44.5 percent). The United Kingdom and Canada combined account for over one-fourth of the foreign-source income at $25.2 billion (16.0 percent) and nearly $16.0 billion (10.0 percent), respectively.
The industry composition of these five countries is presented in Figure G. The largest portion of foreign-source taxable income reported in these countries was from manufacturers. U.S. manufacturers in Canada, the Netherlands, and Germany each accounted for more than 70.5 percent of the foreign-source taxable income reported for those countries. Petroleum and coal product manufacturers with operations in the Netherlands and the United Kingdom were the largest single source of the manufacturing income for these countries, accounting for 27.9 percent and 30.9 percent of the aggregate manufacturing income, respectively. Similarly, 69.2 percent of the nearly $12.0-billion Japan-source taxable income was from manufacturers ($8.3 billion). However, the most significant sources of income for U.S. manufacturers operating in Japan were from office, computing, and accounting equipment operations ($2.2 billion) and electrical and electronic equipment operations ($1.9 billion).
Four of the five largest (in terms of taxable income) countries reported that the majority of non-manufacturing foreign-source taxable income (less loss) was from finance, insurance, and real estate (FIRE) corporations--the United Kingdom, Canada, Japan, and Germany [8]. More than one-fourth of the foreign-source taxable income within this industry grouping was from corporations with operations in the United Kingdom. Half of the $8.4 billion U.K.-sourced taxable income for this industry group was from banking. In fact, nearly one-third of all foreign-source taxable income from banking was from the United Kingdom. FIRE corporations with operations in Canada and Japan reported the majority of their foreign-source taxable incomes from insurance operations, 83.5 percent and 68.3 percent, respectively. Nearly one-fourth of all foreign-source taxable income from insurance operations was from Canada.
Entity Focus
U.S. corporations may establish a worldwide presence via several types of entities. For example, the U.S. corporation may invest in an existing corporation, form a wholly-owned subsidiary corporation or create a partnership under the laws of a foreign jurisdiction, form a joint venture with a foreign entity, or operate through an unincorporated branch. For 1997, more than one-third ($56.3 billion) of the foreign-sourced taxable income ($158.0 billion) from U.S. corporations claiming a foreign tax credit is from foreign branch operations. Due to reporting limitations on Form 1118, Foreign Tax Credit--Corporations, the remaining two-thirds cannot be classified by entity type.
Foreign-Source Gross Income and Taxes (Excluding Foreign Branch Income)
The composition of current-year taxes and foreign-sourced gross income, excluding foreign branch income, by country or area is presented in Figure H. By definition, current-year taxes consist of two parts: (1) taxes paid or accrued and (2) taxes deemed paid [9]. For 1997, current-year taxes totaled $45.1 billion, with nearly two-thirds ($29.0 billion) from taxes deemed paid. The largest share of total tax and the largest share of taxes deemed paid were collected by countries in the European Union (E.U.). The E.U. reported $17.6 billion of the $45.1 billion in foreign taxes paid, accrued, or deemed paid. Nearly 80.0 percent of the E.U. taxes ($14.0 billion) was tax deemed paid. In fact, almost half (48.3 percent) of the foreign taxes deemed paid by all U.S. corporations claiming a foreign tax credit were paid to countries in the E.U. The second highest amount of foreign taxes paid, accrued, or deemed paid ($10.2 billion) was paid to Asian countries. The Asian taxes were distributed evenly between taxes paid or accrued and taxes deemed paid. The $5.1 billion Asian taxes paid or accrued represented almost one-third of the $16.0 billion reported by all U.S. corporations claiming a foreign tax credit.
U.S. corporations reported nearly $360.0 billion in gross foreign-sourced income. Three-fourths of the gross income were generated by entities other than foreign branches. Of the more than $271.2 billion of foreign-sourced gross income (excluding foreign branch income), $97.5 billion were dividend income and related gross-up. Interest income accounted for nearly one-fourth, or $61.5 billion. Rents, royalties, and license fees generated $48.6 million, or 17.9 percent. Income related to service accounted for only 11.6 percent, with a remaining 11.9 percent undefined.
One-third of the gross foreign-sourced income (excluding foreign branch income), $90.1 billion, was generated in the European Union (E.U.). The largest share of this E.U.-sourced gross income, 47.5 percent, was from dividends and related gross-up. In fact, U.S. corporations received 42.0 percent of their dividend income from countries in the E.U., $28.8 billion of $68.4 billion. Interest income generated in the E.U. totaled nearly $23.0 billion, or one-fourth of the total E.U.-sourced gross income (excluding foreign branch income). Rents, royalties, and license fees accounted for nearly 22.0 percent of the E.U.-sourced gross income. Both E.U.-sourced interest income and E.U.-sourced rental income accounted for a significant share of the total foreign-sourced income reported by U.S. corporations claiming a foreign tax credit. Over 37.0 percent of the $61.5 billion total interest from foreign sources was generated in E.U. countries. Similarly, 40.1 percent of the total rental, royalty, and licensing fee income from foreign sources was generated in E.U. countries.
Asian-sourced gross income totaled $47.7 billion (excluding foreign branch income) and represented the second-largest income source by region. More than half of the Asian-sourced gross income was generated from two sources nearly equally: (1) rents, royalties, and license fees and (2) dividend income and related gross-up. Rents, royalties, and license fees generated $13.5 billion, 28.3 percent of the total foreign-sourced rental, royalty, and licensing income reported by U.S. corporations claiming a foreign tax credit. Asian-sourced dividend income and gross-up combined equaled $13.0 billion. Asian-sourced gross service income and interest income were similarly split, generating over $10.0 billion each. This region generated more than one-third of the total foreign-sourced service income reported by U.S. corporations claiming a foreign tax credit.
Foreign Branch Income
An unincorporated foreign branch is not a separate legal entity, but an extension of the domestic corporation. The foreign branch is subject to the tax laws of the country in which it operates. Taxable income of a foreign branch is determined separately, as if it were independent of the domestic corporation. Direct costs, such as cost of goods sold, are allocated against the branch income, and certain indirect expenses may be charged but are subject to the limitation of the foreign country' s regulations. Foreign branch gross income and expenses are reported separately on Form 1118, Schedule F, and included in the taxable income computations for the related basket.
From the U.S. tax perspective, foreign branch income represents foreign-source income earned directly by the domestic corporation. Foreign branch profits or losses are included directly in the taxable income of the domestic corporation and are not a separate taxable event for U.S. purposes. In contrast, the income from a foreign subsidiary, in general, is not included in the taxable income of the domestic corporation until the earnings are distributed to the U.S. parent corporation as a dividend. Branch income is taxed by the U.S. at the regular corporate rates. Therefore, a taxpayer will owe a residual U.S. tax on the income from a branch operating in a low-tax jurisdiction, whereas a branch operating in a high-tax foreign jurisdiction may create excess foreign tax credits.
Figure I presents the distribution of foreign branch income by selected country and industry for 1997. More than $35.1 billion (62.5 percent) of total foreign branch taxable income was connected with operations in ten countries, three of which were members of the E.U.: Australia, Bahamas, Brazil, Germany, Hong Kong, Japan, Mexico, Netherlands, Singapore, and the United Kingdom [10]. In fact, corporations with branch operations in the United Kingdom reported one-fourth, or $14.6 billion, of the total taxable branch income. Corporations classified in three industrial groups reported most of this income: banking (51.9 percent), manufacturing (29.5 percent), and insurance (10.4 percent).
U.S. banks reported more than half of all foreign branch taxable income. More than one-third of the U.S. bank-related taxable branch income was reported by operations in the United Kingdom, $9.7 billion. The U.K.-sourced taxable branch income from banking accounted for nearly two-thirds of all income from UK branch operations. In addition, U.S. banks with branch operations in the Bahamas, Brazil, Hong Kong, and Singapore contributed most of the total taxable branch income for these countries (88.8 percent, 93.5 percent, 82.8 percent, and 92.5 percent, respectively).
U.S. manufacturers accounted for $16.5 billion of the $56.3 billion foreign-sourced taxable branch income, nearly 30.0 percent. Over $9.5 billion was contributed by petroleum and coal-product manufacturers. Specifically, U.S. petroleum and coal-product manufacturers operating in the United Kingdom accounted for more than one-third of the branch income reported by all U.S. petroleum and coal-producers. U.S. petroleum and coal-product manufacturers operating in Australia and the Netherlands accounted for an additional 30 percent ($1.2 billion and $1.6 billion, respectively). U.S. petroleum and coal product manufacturers reported nearly 70.0 percent of the $2.4 billion Netherlands-sourced branch income and nearly 65.0 percent of the $1.9 billion Australia-sourced branch income. U.S. manufacturers in the non-petroleum industries reported 68.1 percent of the $1.3 billion German-sourced branch income and 60.3 percent of the $1.4 billion Mexican-sourced branch income.
U.S. insurers were the third highest group in terms of taxable branch income. Although U.S. insurers reported only 10.4 percent of the total taxable branch income, they reported more than three-fourths ($4.9 billion) of the $6.5 billion Japan-sourced branch income. In fact, U.S. insurers with operations in Japan accounted for more than 85.0 percent of the $5.8 billion foreign-sourced branch taxable income for this industry.
Summary
U.S. corporations claimed a record high foreign tax credit of $42.2 billion for 1997, as income and taxes increased across most industrial classifications and countries. European countries, specifically those in the European Union, continued as the largest single source of foreign-source taxable income and current-year taxes. One recent change, though, has been in the relative share of foreign income and taxes claimed by various industries. Corporations in the finance, insurance, and real estate industries have been rapidly increasing their shares of aggregate foreign income and foreign tax credits since 1990. U.S. corporations with foreign tax credits can no longer be primarily characterized as manufacturers involved in foreign oil and gas extraction or in the foreign production of goods. Banking and services companies are gradually becoming more significant abroad and reporting an increasing share of the foreign tax credit.
Data Sources and Limitations
The statistics in this article were derived from corporation income tax returns with a foreign tax credit that were included in the 1997 Statistics of Income corporate sample. To be included in the sample, returns had to have accounting periods ending between July 1997 and June 1998. These returns were selected prior to any audit examination. The 1997 corporation income tax return sample included approximately 94,000 returns chosen from over 4.7 million returns filed for this period.
The foreign tax credit is claimed under section 901 of the Internal Revenue Code. Corporations report the foreign income and taxes related to the credit on Form 1118, Computation of Foreign Tax Credit--Corporations, filed with their corporate tax returns. The statistics in this article are based on information reported on Forms 1118 and related corporate returns. Corporations with "alternative minimum tax" (AMT) must compute a separate "alternative minimum foreign tax credit." Data for the AMT foreign tax credit computation were excluded from these statistics, even if the corporation reported both the foreign tax credit and the AMT computation. If the corporation reported only the AMT computation, it had no regular tax and would not be included in the foreign tax credit study.
There are slight differences between the more complete foreign tax credit data in this article and those published in Statistics of Income--1997, Corporation Income Tax Returns [11]. These differences can be attributed to several factors, including but not limited to the following masons. Some of the corporate returns selected for the SOI sample, reporting a foreign tax credit, were received too late to be included in the regular corporate statistics (although estimates for these returns were included). Some corporations reported preliminary data on their originally filed returns because information on their overseas operations were not available at the time of filing. Amended returns were not used for these statistics. However, as necessary, additional information was obtained directly from the taxpayer.
Foreign income and taxes are understated in this article to the extent that they either were not or did not have to be reported on Form 1118. Because of the carryback provisions of the law, the 1997 foreign tax credit statistics presented in this article do not represent the final amounts credited that year. Such an amount would have to reflect, in addition to the results of subsequent audit, the carryback of some foreign taxes from 1998 and 1999. The foreign taxes available for the credit shown in this article include only those carried forward to 1997 from previous years. In addition to the carryback limitations, some corporations did not file Form 1118 because they had no U.S. income tax liability and, consequently, were unable to credit any foreign taxes paid or accrued for 1997. Other corporations may have elected to deduct their foreign taxes from their gross incomes instead of claiming the foreign tax credit.
Because the estimates are based on a sample, they are subject to sampling error. Coefficients of variation (CV's) are used to measure the magnitude of this sampling error. The CV is defined in the section on sampling variability in the SOI Sampling Methodology and Data Limitations appendix of this publication. Figure J presents CV's for foreign tax credits by selected industrial groups. The smaller the CV, the more reliable the estimate is judged to be.
The industry classification used in this article conforms to the former Enterprise Standard Industrial Classification (ESIC) authorized by the Office of Information and Regulatory Affairs in the Office of Management and Budget (OMB). The structure of this classification follows closely along the underlying Standard Industrial Classification (SIC) Manual, also authorized by OMB. For Tax Year 1998, the industry classification will conform to the new North American Industry Classification System (NAICS), which has recently been adopted.
Tables 1-3
Table 1, columns 2 through 15, presents statistics on assets, receipts, income, and taxes reported on Form 1120, Corporation Income Tax Return, for those corporations claiming a foreign tax credit. Columns 16 through 52 present statistics from Form 1118, Foreign Tax Credit--Corporations. Schedule references indicate the parts of Form 1118 from which the data were obtained. Columns 16 through 36 present statistics on foreign income (i.e., income from sources outside the United States) and deductions, reported primarily on Form 1118, Schedule A, Income or Loss Before Adjustments.
Although the amounts of oil and gas income and deductions (columns 23 and 36, respectively) are included in the summary columns (i.e., columns 16 through 22 and 26 through 35), these amounts are also reported separately (on Form 1118, Schedule I, Reduction of Oil and Gas Extraction Taxes) because oil and gas extraction income is subject to special rules under Internal Revenue Code section 907, which effectively requires a separate limitation calculation for taxes related to oil and gas extraction income. This may result in a reduction of foreign taxes available for credit. Reductions in creditable oil and gas extraction income taxes are included with several other types of reductions in column 41 of Table 1 and column 27 of Table 2.
Internal Revenue Code section 863(b) income (income partly within and partly without the United States) and foreign branch income are also included in the summary amounts reported in columns 16 through 22 of Table 1, and are also reported separately (on Form 1118, Schedule F, Gross Income and Definitely Allocable Deductions From Sources Outside the U.S. Under Section 863(b) and for Foreign Branches) in columns 24 and 25 of Table 1.
Total deductions not definitely allocable to specific types of income (column 32) are equal to the sum of Table 1, columns 33 through 35, relating to research and development, interest, and any other not definitely allocable expenses (any differences are due to taxpayer reporting variations). Total foreign-source gross income (Table 1, column 16) less total foreign deductions (Table 1, column 26) is equal to foreign-source taxable income before adjustments (Table 1, column 37).
Adjustments to foreign-source taxable income (reported in column 38 of Table 1) include the allocation of: (1) current-year foreign-source losses, (2) overall foreign losses, and (3) current-year U.S.-source losses, as well as the recapture of prior-year overall foreign losses and recharacterization of prior-year foreign-source losses. These adjustments (reported on Schedule J, Separate Limitation Loss Allocations and Other Adjustments Necessary To Determine Numerators of Limitation Fractions, Year-End Recharacterization Balances, and Overall Foreign Loss Account Balances) affect the numerator of the limitation fraction used to compute the foreign tax credit. The income after adjustments (the numerator of the limitation fraction) is reported in column 39 of Table 1. The limitation fraction, foreign-source taxable divided by total taxable income from all sources, is applied to the total U.S. tax against which the credit is allowed to determine any limitation on the foreign tax credit. Taxpayers are required to calculate this limitation for each statutory income category.
Statistics on foreign taxes are reported in columns 40 through 52 of Table 1. Data on foreign taxes paid, accrued, and deemed paid (through related foreign corporations or their subsidiaries) from Form 1118, Schedule B, Foreign Tax Credit--Corporation, are reported in columns 43 through 52 of Table 1. Total foreign taxes paid or accrued (Table 1, column 44) are the sum of columns 45 through 51 (any differences are due to taxpayer reporting variations). Table 1, column 42 shows carryovers of excess or "unused" taxes from prior years, which can be added to the 1996 pool of creditable foreign taxes. Total foreign taxes paid, accrued, and deemed paid, plus carryover, are then adjusted for certain items (e.g., reductions of foreign taxes related to oil and gas extraction income under Internal Revenue code section 907, reductions of foreign taxes related to income earned in sanctioned countries under Internal Revenue code section 9010), and other reductions of creditable taxes) in column 41. Thus, total foreign taxes available for credit (Table 1, column 40) are equal to total foreign taxes paid, accrued, and deemed paid (column 43), plus any carryover of prior-year excess or "unused" foreign taxes (column 42), less any reduction in foreign taxes (column 41).
Tables 2 and 3 are similar in column format to Table 1 except that they do not provide data from Form 1120--U.S. Corporation Income Tax Return. Table 2 presents data reported by industrial grouping and separate statutory limitation income category, while Table 3 presents data by selected geographic region and country.
Explanation of Selected Terms
Adjustments to taxable income.--This includes several types of adjustments reported on Schedule J of Form 1118, Computation of Foreign Tax Credit--Corporations. These adjustments include the allocation of current-year foreign losses, overall foreign losses, and current-year domestic-source losses. In addition, adjustments due to prior-year loss allocations are made including the recapture of foreign-source losses, and the recharacterization of foreign-source income. The net results of these adjustments are reported in column 38 of Table 1 and column 24 of Table 2.
Carryover of foreign taxes.--Under Internal Revenue Code section 904, U.S. persons are allowed a 2-year carryback and 5-year carryforward of "excess" or "unused" foreign taxes for purposes of computing the foreign tax credit for those years. Such taxes were included in the computation of the current-year foreign tax credit to the extent that they did not exceed the credit limitation for the current year. For 1997, "carryover" includes only those foreign taxes that have been carried forward from previous years. See column 42 of Table 1 and column 28 of Table 2.
Controlled Foreign Corporation.--Under Internal Revenue Code section 957, a foreign corporation is a"Controlled Foreign Corporation" if more than 50 percent of its outstanding voting stock, or more than 50 percent of the value of all its outstanding stock, is owned (directly, indirectly, or constructively) by "U.S. shareholders" on any day during the foreign corporation's tax year. A "U.S. shareholder," as defined in Internal Revenue Code section 951(b), is a U.S. person who owns 10 percent or more of the foreign corporation's total combined voting stock. Ownership attribution rules are provided in Internal Revenue Code section 958.
Current-year foreign taxes.--The current-year foreign taxes include foreign taxes paid, accrued, or deemed paid and are reported in column 43 of Table 1, column 29 of Table 2, and column 15 of Table 3. Current-year foreign taxes do not include any carryback or carryforward of foreign taxes from future or prior tax years.
European Union (E.U.).--The European Union (E.U.) is a union of fifteen independent states based on the former European Communities and founded to enhance political, economic, and social cooperation. Formerly known as European Community (E.C.) or European Economic Community (E.E.C.), the member states include Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain, Sweden, and the United Kingdom.
Financial services income.--This separate limitation category applies to income from a specific industry--financial services (such as banking). Financial services income includes all income (including "passive income") that is produced in the active conduct of a banking, insurance, financing, or similar business, and from certain types of insurance investments. Financial services income does not include high withholding tax interest, dividends from noncontrolled foreign corporations as defined in Internal Revenue Code section 902, or certain types of export financing interest. Congress required a separate limitation category for financial service corporations because of a concern that the income generated could be easily shifted to low-tax jurisdictions. This separate limitation category is included in Table 2.
Foreign oil and gas extraction income.--Generally, no foreign tax credit or deduction is allowed for foreign taxes paid or accrued in connection with the purchase or sale of oil or gas extracted in a foreign country if the taxpayer has no economic interest in the oil and gas and the purchase or sale price differs from the fair market value.
Foreign Sales Corporations (FSC).--A foreign sales corporation is a company incorporated abroad, created to promote U.S. exports, and usually controlled by a U.S. person (defined below). A portion of the FSC's "foreign trade income" is exempt from U.S. taxation. These statistics do not include FSC returns. However, FSC dividends reported by corporations claiming a foreign tax credit are included. Dividends and interest from a FSC compose a separate limitation category. In July 1999, the World Trade Organization deemed that the FSC provisions constituted an illegal export subsidy. Congress repealed the FSC provisions and introduced the Extraterritorial Income Exclusion in November 2000. Under this legislation, U.S. corporations may continue to operate FSCs until December 2001.
Foreign-source taxable income.--Foreign-source taxable income is equal to gross income (less loss) less deductions from sources outside the U.S.
Foreign trade income.--Foreign trade income is the foreign trading gross receipts earned by a Foreign Sales Corporation (FSC) from 1) the sale of export property, 2) leasing of export property for use outside the U.S., or 3) services in connection with the sale or leasing of export property. The related separate limitation category, taxable income attributable to foreign trade income, is unusual in the SOI study because of the defined scope of the SOI sample.
General limitation income.--This separate limitation category includes foreign income not included in any other separate limitation category.
Gross-up.--Because a dividend represents a distribution from after-tax earnings, the amount of income that a domestic corporation recognizes on receiving a dividend from a foreign corporation is net of all the foreign income taxes paid by that foreign corporation. U.S. corporations that satisfy ownership and other requirements may take an "indirect" foreign tax credit for taxes paid with respect to the distribution. Under Internal Revenue Code section 78, these taxes are "deemed paid" by the U.S. corporation under Internal Revenue Code sections 902 and 960(a). Therefore, the dividend income is grossed-up by the amount of the deemed taxes paid. This denies the U.S. corporation the double tax benefit of crediting the deemed foreign taxes and deducting the same taxes from the foreign-sourced taxable income. The gross-up requirement eliminates the implicit deduction.
High withholding tax interest.--This separate limitation category includes only interest income subject to a withholding tax, or other gross basis tax, at a rate of 5 percent or more. Like the passive income basket, the high withholding tax interest basket does not apply to interest received in the conduct of financing certain export activities.
Income re-sourced by treaty.--A few U.S. income tax treaties contain provisions which reclassify certain items of income from U.S.-source to foreign-source. This primarily happens when a tax treaty gives the foreign country the right to tax what would otherwise be U.S.-sourced income. If the corporation elects to apply the treaty, the income will be treated as foreign income. Certain dividends, gains, and income from a U.S.-owned foreign corporation may be included in this basket. A separate foreign tax credit limitation must be computed for each amount re-sourced from a treaty country.
Interest-Charge Domestic International Sales Corporation (IC-DISC).--IC-DISC's are certain small domestic corporations formed to export U.S. products. An IC-DISC can defer the tax liability of a portion of its income, but must ultimately pay the deferred tax plus interest. Under the DISC provisions, a U.S. manufacturer could set up a DISC (located in the U.S.) whose income is not taxed at the DISC level. Instead, the corporate shareholder is taxed directly on a portion of the DISC's income deemed distributed. The portion of the income not deemed distributed is not subject to any U.S. taxation until actually distributed. The U.S.'s foreign trading partners that are party to the General Agreement on Tariffs and Trade (GATT) maintained the DISC provisions constituted an illegal export trade subsidy because they allowed indefinite deferral of direct taxes on income from exports earned in the U.S. Essentially, this pre-1985 system of tax deferral for export income had been replaced by the exemption system of foreign sales corporations (FSC's). To elect IC-DISC status, at least 95 percent of the corporation's gross receipts must be "qualified export receipts," and at least 95 percent of its assets must be "qualified export assets." Distributions from an IC-DISC are a separate limitation category.
Non-controlled section 902 corporation.--A non-controlled foreign corporation, as defined in Internal Revenue Code section 902, is a foreign corporation in which the U.S. corporation owns at least l0 percent of the voting stock and the U.S. shareholders (i.e., those owning at least 10 percent of the voting stock), as a group, own 50 percent or less of the stock measured by voting power or value. Sometimes, these foreign corporations are referred to as "10/50 companies." Each non-controlled section 902 corporation is treated separately. Taxpayers are required to place dividends from each corporation into a separate basket to prevent averaging of high-taxed and low-taxed dividends from different noncontrolled section 902 corporations.
OPEC Countries.--The members of the Organization of Petroleum Exporting Countries (OPEC) for 1997 were Algeria, Indonesia, Iran, Iraq, Kuwait, Libya, Nigeria, Qatar, Saudi Arabia, United Arab Emirates, and Venezuela.
Passive income.--This separate limitation category includes dividends, interest, rents, royalties, annuities, net capital gains, and commodity transactions. There are some important exceptions to these inclusions. Rents and royalties derived in an active trade or business from an unrelated person may not be considered passive. Also, high-taxed passive income is excluded from the passive income basket. Specifically, interest subject to a high witholding tax is placed in a separate basket. (See definition for high withholding tax interest.) In addition, income that by definition would have been classified as passive yet is subject to a foreign tax rate exceeding the highest applicable U.S. rate is removed from the passive basket and placed in the General Limitation or Overall basket.
Section 901(J) income.--Internal Revenue Code section 901(j) denies credit for taxes paid or accrued to certain foreign governments that the U.S. deems ineligible for the credit. Generally, these countries include the following: (1) countries not recognized by the U.S., (2) countries with which the U.S. has severed or does not conduct diplomatic relations, or (3) countries identified by the U.S. as providing support for terrorism. For 1997, countries subject to this restriction were Cuba, Iran, Iraq, Libya, North Korea, Sudan, and Syria. Although these taxes are not creditable, income and deductions from Internal Revenue Code section 901(j) countries are reported on Form 1118. A separate limitation credit is computed for informational purposes only and is not included in the foreign tax credit of the corporation.
Shipping income.--This statutory group applies to a specific industry--shipping. Shipping income includes the following: (1) all income from the use (or leasing for use) of a vessel or aircraft in foreign commerce, (2) income from services directly related to the use of a vessel or aircraft, (3) gains on the sale or exchange of a vessel or aircraft used in the performance of such services, and (4) income generated from other space and oceanic activities, Income that would be "foreign base company shipping income" for purposes of determining the income constructively received from Controlled Foreign Corporations, under Internal Revenue Code section 954(0, is also classified as shipping income.
Soak-up taxes.--A soak-up tax is a tax liability that depends upon the availability of a credit against the income tax liability to another country. In other words, a soak-up tax arises when a foreign tax would not be imposed on the taxpayer unless a credit is available for the tax under the laws of another jurisdiction.
Specific economic benefit.--A foreign levy is not considered a tax under U.S. regulations if the person or corporation subject to the levy receives, either directly or indirectly, a specific economic benefit from paying it.. Benefits include such items as property; services; fees and other payments; rights to use, acquire or extract resources; patents or other property owned or controlled by the foreign country; and reductions or discharge of contractual obligations. The U.S. regulations determine this levy to be payment for the specific economic benefit.
Specifically allocable income.--Internal Revenue Code section 863(b) provides special rules for determining taxable income from sources outside the U.S. with respect to gross income derived partly within and partly outside the U.S. The income apportioned to sources outside the U.S. under these special rules is commonly referred to as "Section 863(b) income" and is shown in column 25 of Table 1, and column 11 of Tables 2 and 3.
Tax deemed paid.--See definition for Gross-up.
Tax motivated stock acquisitions.--For dividends paid more than 30 days after August 5, 1997, the Taxpayer Relief Act of 1997 (TRA) 97) imposes a minimum holding period requirement with respect to claiming a credit for foreign taxes associated with foreign-source dividends. This limitation is designed to prevent the transfer of foreign tax credits from a taxpayer that cannot use the credit (such as a tax-exempt organization) to one who can, simply by transferring stock that generates foreign-source income and creditable foreign taxes.
U.S. Person.--A U.S. person is any citizen or resident of the United States, domestic partnership, corporation, association, company, or any estate or trust that is not considered "foreign." See Internal Revenue Code section 7701 for more information on the definition of a U.S. person.
Table 1.--U.S. Corporation Returns with a Foreign Tax Credit: Total Assets, Income, Tax, and Credits, and Foreign Income and Tax Reported on Form 1118, by Selected Industrial Group [All figures are estimates based on samples--money amounts are in thousands of dollars] Number Major and selected minor of Total Total industrial group returns assets receipts (1) (2) (3) All industries 6,569 14,263,224,845 5,311,659,824 Agriculture, forestry, and fishing 134 4,225,363 4,015,958 Mining 133 73,651,052 33,600,411 Metal mining 9 * 8,025,694 * 3,886,090 Coal mining 5 * 24,310,942 * 4,930,022 Oil and gas extraction 112 35,455,594 19,867,239 Nonmetallic minerals, except fuels 8 * 5,858,822 * 4,917,061 Construction 183 19,960,287 22,946,190 General building contractors 92 6,877,597 16,698,443 Heavy construction contractors 39 11,941,741 4,004,597 Special trade contractors 51 1,140,950 2,243,150 Manufacturing 1,763 3,955,074,054 2,794,697,025 Food and kindred products 83 291,962,500 185,153,297 Tobacco manufactures 5 * 86,798,606 * 55,761,730 Textile mill products 60 7,891,742 7,563,645 Apparel and other textile products 29 18,356,325 17,214,350 Lumber and wood products 15 29,795,087 19,952,844 Furniture and fixtures 13 11,078,283 12,833,556 Paper and allied products 31 104,694,794 66,384,124 Printing and publishing 97 148,457,010 79,539,328 Industrial plastics and synthetic material 100 256,671,000 152,469,542 Drugs 53 208,241,502 126,313,930 Other chemicals 75 88,211,866 98,389,498 Petroleum (including integrated) and coal products 28 612,952,862 463,528,962 Rubber and miscellaneous plastics products 71 27,275,689 33,603,207 Leather and leather products 13 2,656,074 3,823,505 Stone, clay, and glass products 28 24,757,696 20,679,811 Primary metal industries 42 69,343,470 59,872,820 Fabricated metal products 192 69,544,707 60,810,423 Office, computing, and accounting equipment 29 91,396,346 107,297,923 Other machinery, except electrical 221 124,145,998 115,381,816 Electrical and electronic equipment 327 675,225,281 371,444,877 Motor vehicles and equipment 27 696,308,021 450,630,068 Transportation equipment, except motor vehicles 37 162,371,792 153,396,735 Instruments and related products 99 120,402,007 106,077,496 Miscellaneous manufacturing and manufacturing not allocable 87 26,535,396 26,573,536 Transportation and public utilities 159 669,825,450 356,767,998 Transportation 88 151,504,474 115,205,317 Water transportation 36 6,235,570 5,723,969 All other transportation 52 145,268,904 109,481,348 Communication 17 328,346,936 166,316,586 Electric, gas, and sanitary services 54 189,974,039 75,246,095 Wholesale and retail trade 1,193 339,164,731 582,617,720 Wholesale trade 704 158,541,039 264,051,142 Groceries and related products 15 2,511,606 6,918,148 Machinery, equipment, and supplies 102 7,609,466 9,954,579 Miscellaneous wholesale trade 586 148,419,967 247,178,416 Drugs, chemicals, and allied products 17 7,318,201 20,998,972 Petroleum and petroleum products 7 * 18,350,985 * 35,005,556 Other miscellaneous wholesale trade 562 122,750,782 191,173,888 Retail trade 489 180,623,692 318,566,578 Building materials, garden supplies, and mobile home dealers 4 * 11,300,236 * 23,909,565 General merchandise stores 7 * 80,708,462 * 184,847,263 Food stores 82 * 4,572,431 * 9,537,382 Automotive dealers and service station 16 * 1,515,526 * 2,631,003 Apparel and accessory stores 20 19,613,945 30,385,961 Furniture and home furnishing stores 7 * 1,362,791 * 2,239,681 Eating and drinking places 79 39,667,742 27,574,867 All other retail stores 273 21,882,559 37,440,857 Finance, insurance, and real estate 1,676 8,898,152,618 1,287,984,403 Banking 92 3,554,188,953 296,696,941 Credit agencies other than banks 27 839,806,816 74,942,170 Security, commodity brokers, and services 113 1,338,399,719 120,257,770 Insurance 297 3,076,200,324 773,486,810 Insurance agents, brokers, and service 18 35,243,542 10,595,245 Real estate 344 13,434,284 4,169,013 Holding and other investment companies, except bank holding companies 784 40,878,979 7,836,454 Services 1,329 303,171,291 229,030,120 Hotels and other lodging places 16 39,001,489 45,665,053 Personal services 10 * 4,911,672 * 4,700,078 Business services 603 147,695,418 106,268,489 Auto repair; miscellaneous repair services 18 * 10,122,309 12,907,492 Amusement and recreation services 137 69,326,567 36,565,144 All other services 546 32,113,836 22,923,864 Dividends Dividends received Includable received from IC- income of Major and selected minor from DISC's or Controlled industrial group foreign former Foreign corporations DISC's (1) Corporations (4) (5) (6) All industries 39,398,674 116,806 26,163,328 Agriculture, forestry, and fishing * 38,435 -- * 2,373 Mining 585,646 -- 193,986 Metal mining * 95,211 -- * 7,629 Coal mining * 179,791 -- * 11,154 Oil and gas extraction 288,674 -- 171,981 Nonmetallic minerals, except fuels * 21,969 -- * 3,222 Construction 26,858 -- * 15,711 General building contractors * 6,561 -- * 8,086 Heavy construction contractors * 5,379 -- * 7,625 Special trade contractors * 14,919 -- -- Manufacturing 32,371,546 12,872 17,086,737 Food and kindred products 3,912,886 * 166 1,701,491 Tobacco manufactures * 1,617,865 -- * 793,640 Textile mill products * 46,070 -- * 9,804 Apparel and other textile products * 219,282 * 28 * 170,869 Lumber and wood products * 50,566 -- * 19,421 Furniture and fixtures * 44,045 -- * 11,094 Paper and allied products 895,122 -- 272,165 Printing and publishing 205,822 * 22 48,726 Industrial plastics and synthetic material 1,970,080 * 5,260 1,120,520 Drugs 4,702,171 * 125 2,326,922 Other chemicals 1,163,186 * 767 744,798 Petroleum (including integrated) and coal products 5,931,883 -- 1,513,861 Rubber and miscellaneous plastics products 403,240 -- 141,314 Leather and leather products * 690 -- * 4,754 Stone, clay, and glass products 135,573 -- * 19,930 Primary metal industries 425,569 -- 176,352 Fabricated metal products 528,288 * 1,060 485,045 Office, computing, and accounting equipment 3,545,730 -- 514,735 Other machinery, except electrical 896,194 * 3,279 638,873 Electrical and electronic equipment 1,792,838 * 802 2,861,445 Motor vehicles and equipment 2,196,450 -- 2,182,373 Transportation equipment, except motor vehicles 541,000 -- * 294,876 Instruments and related products 1,002,676 * 322 914,587 Miscellaneous manufacturing and manufacturing not allocable 144,317 * 1,041 119,143 Transportation and public utilities 1,100,518 -- 512,233 Transportation 88,844 -- 186,214 Water transportation * 4,495 -- * 47,977 All other transportation 84,349 -- 138,236 Communication 557,380 -- 113,288 Electric, gas, and sanitary services 454,293 -- 212,731 Wholesale and retail trade 780,761 -- 1,218,569 Wholesale trade 577,159 -- 647,203 Groceries and related products * 7,192 -- * 232 Machinery, equipment, and supplies 16,309 -- * 2,265 Miscellaneous wholesale trade 553,658 -- 644,706 Drugs, chemicals, and allied products * 17,301 -- * 27,667 Petroleum and petroleum products * 97,375 -- * 41,435 Other miscellaneous wholesale trade 438,982 -- 575,604 Retail trade 203,602 -- 571,366 Building materials, garden supplies, and mobile home dealers * 11 -- * 898 General merchandise stores * 19,749 -- * 18,354 Food stores * 6 -- -- Automotive dealers and service station * 241 -- * 640 Apparel and accessory stores * 47,725 -- * 147,514 Furniture and home furnishing stores * 7,375 -- * 909 Eating and drinking places * 113,712 -- * 363,486 All other retail stores * 14,783 -- * 39,566 Finance, insurance, and real estate 2,936,573 * 103,446 6,559,699 Banking 547,417 -- 3,043,939 Credit agencies other than banks * 294,044 -- 634,432 Security, commodity brokers, and services 362,864 * 413 707,388 Insurance 977,100 * 103,033 1,733,944 Insurance agents, brokers, and service * 160,472 -- * 33,796 Real estate 3,714 -- * 22,179 Holding and other investment companies, except bank holding companies 590,960 -- 384,021 Services 1,558,336 * 487 574,019 Hotels and other lodging places * 215,472 -- * 35,920 Personal services * 24,079 -- * 42 Business services 1,120,714 * 487 431,851 Auto repair; miscellaneous repair services * 1,895 -- -- Amusement and recreation services * 93,684 -- * 37,710 All other services 102,492 -- 68,495 Foreign dividend income resulting Net income Income Major and selected minor from (less subject to industrial group foreign deficit) U.S. tax taxes deemed paid (gross-up) (7) (8) (9) All industries 29,036,369 432,320,036 410,126,303 Agriculture, forestry, and fishing * 21,531 472,180 443,557 Mining 279,596 5,500,935 4,928,538 Metal mining * 25,690 * 540,859 * 522,293 Coal mining * 1,529 * 503,162 * 500,781 Oil and gas extraction 244,643 3,955,653 3,421,372 Nonmetallic minerals, except fuels * 7,734 * 501,260 * 484,091 Construction * 16,089 962,188 904,900 General building contractors * 5,962 352,012 304,354 Heavy construction contractors * 618 465,556 463,558 Special trade contractors * 9,509 144,620 136,988 Manufacturing 23,039,903 231,445,833 217,289,154 Food and kindred products 2,364,751 15,598,040 14,708,990 Tobacco manufactures * 1,020,998 * 9,926,981 * 9,531,635 Textile mill products * 25,154 464,611 453,571 Apparel and other textile products * 254,852 2,196,571 2,190,311 Lumber and wood products * 35,560 713,321 690,960 Furniture and fixtures * 22,043 1,021,869 1,011,446 Paper and allied products 521,364 5,890,290 5,693,977 Printing and publishing 157,886 8,584,473 8,193,110 Industrial plastics and synthetic material 1,352,440 14,586,044 13,318,832 Drugs 2,147,640 16,087,449 14,156,181 Other chemicals 1,084,617 10,618,235 10,379,679 Petroleum (including integrated) and coal products 3,395,084 35,010,444 34,251,734 Rubber and miscellaneous plastics products 358,362 2,851,237 2,529,530 Leather and leather products * 2,005 232,216 226,753 Stone, clay, and glass products 84,332 2,141,532 1,925,772 Primary metal industries 310,314 4,259,678 3,876,006 Fabricated metal products 690,332 6,871,096 6,567,563 Office, computing, and accounting equipment 2,629,987 12,652,628 12,467,999 Other machinery, except electrical 642,226 9,764,431 9,298,547 Electrical and electronic equipment 2,336,637 37,074,391 32,801,097 Motor vehicles and equipment 1,989,821 14,972,935 14,584,725 Transportation equipment, except motor vehicles 397,281 8,225,037 7,633,872 Instruments and related products 1,067,292 9,042,921 8,310,400 Miscellaneous manufacturing and manufacturing not allocable 148,926 2,659,399 2,486,462 Transportation and public utilities 585,820 36,544,490 34,495,220 Transportation 88,808 7,085,504 5,322,916 Water transportation * 13,417 786,138 759,474 All other transportation 75,391 6,299,367 4,563,441 Communication * 322,130 19,925,850 19,742,996 Electric, gas, and sanitary services 174,882 9,533,136 9,429,308 Wholesale and retail trade 1,120,582 26,114,386 25,492,725 Wholesale trade 510,408 8,902,140 8,419,564 Groceries and related products * 4,965 306,665 301,656 Machinery, equipment, and supplies 4,744 582,467 536,848 Miscellaneous wholesale trade 500,699 8,013,009 7,581,059 Drugs, chemicals, and allied products * 16,045 424,384 420,846 Petroleum and petroleum products * 53,744 * 690,872 * 662,784 Other miscellaneous wholesale trade 430,910 6,897,752 6,497,430 Retail trade 610,174 17,212,245 17,073,161 Building materials, garden supplies, and mobile home dealers -- * 1,701,875 * 1,701,413 General merchandise stores * 7,300 * 7,794,366 * 7,743,161 Food stores -- * 282,722 * 282,432 Automotive dealers and service station -- * 95,270 * 94,813 Apparel and accessory stores * 113,315 2,325,346 2,306,402 Furniture and home furnishing stores * 2,494 * 128,828 * 123,755 Eating and drinking places * 461,926 3,128,952 3,089,959 All other retail stores * 25,140 1,754,886 1,731,226 Finance, insurance, and real estate 2,642,365 108,014,750 104,400,301 Banking 1,061,490 37,143,609 36,532,504 Credit agencies other than banks 279,502 6,748,939 6,572,415 Security, commodity brokers, and services 320,652 12,566,309 12,102,087 Insurance 444,345 45,361,782 43,037,841 Insurance agents, brokers, and service * 44,255 1,741,357 1,929,969 Real estate 9,180 614,551 555,055 Holding and other investment companies, except bank holding companies 482,941 3,838,203 3,670,430 Services 1,330,484 23,265,274 22,171,907 Hotels and other lodging places * 145,306 2,192,769 2,090,256 Personal services * 13,274 * 447,064 * 444,511 Business services 1,039,091 14,596,239 13,808,738 Auto repair; miscellaneous repair services * 1,060 465,363 451,629 Amusement and recreation services 79,900 4,156,090 3,950,605 All other services 51,853 1,407,749 1,426,169 U.S. income tax before credits Regular and Foreign Major and selected minor alternative tax credit industrial group Total minimum claimed tax (10) (11) (12) All industries 144,779,411 144,767,666 42,222,743 Agriculture, forestry, and fishing 154,284 154,284 34,696 Mining 1,756,666 1,756,187 906,954 Metal mining * 194,015 * 194,015 * 166,282 Coal mining * 175,178 * 175,178 * 94,155 Oil and gas extraction 1,215,068 1,214,590 637,691 Nonmetallic minerals, except fuels * 172,404 * 172,404 * 8,826 Construction 319,265 316,158 44,412 General building contractors 108,052 107,437 19,511 Heavy construction contractors 163,416 161,619 14,083 Special trade contractors 47,797 47,103 10,817 Manufacturing 76,694,471 76,689,694 30,299,210 Food and kindred products 6,205,414 5,203,843 2,801,304 Tobacco manufactures * 3,335,972 * 3,335,972 * 1,302,880 Textile mill products 158,242 158,242 26,532 Apparel and other textile products 767,940 767,940 266,279 Lumber and wood products 244,822 251,376 40,342 Furniture and fixtures 353,841 353,841 22,761 Paper and allied products 2,040,861 2,040,837 664,059 Printing and publishing 2,867,128 2,867,177 288,130 Industrial plastics and synthetic material 4,687,617 4,687,617 1,647,569 Drugs 5,011,193 5,011,193 2,202,041 Other chemicals 3,646,416 3,646,416 1,321,594 Petroleum (including integrated) and coal products 12,006,024 12,006,279 6,748,403 Rubber and miscellaneous plastics products 932,101 931,094 402,316 Leather and leather products 78,695 78,695 11,724 Stone, clay, and glass products 681,784 681,775 101,193 Primary metal industries 1,379,623 1,385,009 421,868 Fabricated metal products 2,301,922 2,303 694,974 Office, computing, and accounting equipment 4,489,836 4,489,836 3,150,955 Other machinery, except electrical 3,262,793 3,261,089 854,506 Electrical and electronic equipment 11,533,239 11,531,064 2,962,524 Motor vehicles and equipment 5,149,323 5,148,598 2,380,504 Transportation equipment, except motor vehicles 2,675,815 2,671,974 517,204 Instruments and related products 3,014,366 3,006,188 1,292,349 Miscellaneous manufacturing and manufacturing not allocable 869,504 870,661 177,199 Transportation and public utilities 12,348,590 12,353,898 802,644 Transportation 2,151,865 2,151,825 187,641 Water transportation 269,228 269,225 27,947 All other transportation 1,882,637 1,882,600 159,694 Communication 6,885,103 6,890,788 451,925 Electric, gas, and sanitary services 3,311,623 3,311,285 163,078 Wholesale and retail trade 8,987,993 8,985,680 1,383,247 Wholesale trade 3,013,051 3,012,306 686,471 Groceries and related products 105,210 105,210 5,902 Machinery, equipment, and supplies 188,020 188,015 9,877 Miscellaneous wholesale trade 2,719,821 2,719,081 670,692 Drugs, chemicals, and allied products 184,551 184,580 88,289 Petroleum and petroleum products * 231,768 * 231,768 * 98,437 Other miscellaneous wholesale trade 2,303,502 2,302,734 483,966 Retail trade 5,974,941 5,973,374 696,776 Building materials, garden supplies, and mobile home dealers * 595,469 * 595,469 * 1,835 General merchandise stores * 2,710,699 * 2,710,417 * 24,769 Food stores * 98,716 * 98,716 * 6,661 Automotive dealers and service station * 32,953 * 32,953 * 129 Apparel and accessory stores 808,322 808,322 79,494 Furniture and home furnishing stores * 43,072 * 43,072 * 3,552 Eating and drinking places 1,082,399 1,081,114 528,482 All other retail stores 603,310 603,309 51,854 Finance, insurance, and real estate 36,747,145 36,741,714 6,654,591 Banking 12,757,974 12,757,921 3,337,311 Credit agencies other than banks 2,300,161 2,299,871 457,527 Security, commodity brokers, and services 4,232,201 4,233,899 765,424 Insurance 15,296,430 15,290,783 1,552,984 Insurance agents, brokers, and service 675,117 675,117 50,162 Real estate 201,049 201,049 9,759 Holding and other investment companies, except bank holding companies 1,284,212 1,283,073 481,423 Services 7,770,999 7,770,053 2,096,990 Hotels and other lodging places 733,791 733,644 177,348 Personal services * 155,379 * 155,379 * 14,819 Business services 4,850,636 4,850,144 1,601,492 Auto repair; miscellaneous repair services 157,784 157,702 1,322 Amusement and recreation services 1,380,888 1,380,888 204,541 All other services 492,521 492,295 97,468 U.S. General U.S. Income Major and selected minor possessions business tax after industrial group tax credit credit credits (2) (13) (14) (15) All industries 146,440 3,548,009 95,787,290 Agriculture, forestry, and fishing -- * 7,172 110,854 Mining -- 14,700 767,253 Metal mining -- -- * 27,060 Coal mining -- * 42 * 66,554 Oil and gas extraction -- 12,181 521,611 Nonmetallic minerals, except fuels -- * 2,477 * 152,028 Construction -- * 8,435 266,016 General building contractors -- * 8,221 79,917 Heavy construction contractors -- * 213 149,120 Special trade contractors -- * 1 36,979 Manufacturing 145,433 2,268,555 42,395,173 Food and kindred products * 1,687 66,929 2,306,084 Tobacco manufactures -- * 26,481 * 1,996,103 Textile mill products -- * 6,205 125,048 Apparel and other textile products * 17,291 * 2,524 481,634 Lumber and wood products -- * 1,042 196,202 Furniture and fixtures -- * 4,411 326,058 Paper and allied products * 2,154 47,050 1,316,682 Printing and publishing * 408 58,228 2,507,107 Industrial plastics and synthetic material -- 90,037 2,743,397 Drugs * 117,158 275,325 2,357,662 Other chemicals * 1,611 82,607 2,239,988 Petroleum (including integrated) and coal products * 221 322,110 3,944,902 Rubber and miscellaneous plastics products * 778 25,441 491,613 Leather and leather products -- * 735 66,235 Stone, clay, and glass products -- 25,302 544,744 Primary metal industries -- 7,492 886,419 Fabricated metal products * 9 35,270 1,553,143 Office, computing, and accounting equipment -- 90,825 1,242,658 Other machinery, except electrical * 236 105,219 2,275,217 Electrical and electronic equipment -- 597,501 7,923,717 Motor vehicles and equipment -- 173,533 2,588,190 Transportation equipment, except motor vehicles -- 110,079 2,002,940 Instruments and related products * 3,878 88,749 1,622,324 Miscellaneous manufacturing and manufacturing not allocable -- 25,463 657,107 Transportation and public utilities -- 245,999 10,865,454 Transportation -- 16,599 1,709,341 Water transportation -- * 733 236,227 All other transportation -- 15,865 1,473,114 Communication -- 198,601 6,135,206 Electric, gas, and sanitary services -- 30,799 3,020,908 Wholesale and retail trade -- 87,112 7,442,207 Wholesale trade -- 23,320 2,243,343 Groceries and related products -- -- 97,621 Machinery, equipment, and supplies -- * 809 172,522 Miscellaneous wholesale trade -- 22,510 1,973,201 Drugs, chemicals, and allied products -- * 2,384 92,083 Petroleum and petroleum products -- * 10,145 * 91,295 Other miscellaneous wholesale trade -- 9,981 1,789,822 Retail trade -- 63,793 5,198,864 Building materials, garden supplies, and mobile home dealers -- * 451 * 593,183 General merchandise stores -- * 15,643 * 2,670,287 Food stores -- * 1,335 * 90,720 Automotive dealers and service station -- * 5,139 * 14,713 Apparel and accessory stores -- * 1,101 727,727 Furniture and home furnishing stores -- * 354 * 39,165 Eating and drinking places -- 31,916 520,153 All other retail stores -- * 7,853 542,914 Finance, insurance, and real estate * 31 525,692 28,684,700 Banking -- 281,570 9,110,182 Credit agencies other than banks -- * 30,680 1,789,485 Security, commodity brokers, and services -- 31,849 3,365,430 Insurance * 31 169,659 12,835,673 Insurance agents, brokers, and service -- * 6,648 616,521 Real estate -- * 626 178,398 Holding and other investment companies, except bank holding companies -- * 4,660 789,010 Services * 976 390,344 5,255,633 Hotels and other lodging places * 976 * 36,141 514,725 Personal services -- * 1,002 * 138,598 Business services -- 312,273 2,925,825 Auto repair; miscellaneous repair services -- * 676 155,786 Amusement and recreation services -- * 24,706 1,142,071 All other services -- 15,547 378,629 Foreign income and taxes reported on Form 1118 Gross income (less loss) Foreign dividend income resulting Major and selected minor from industrial group Total Dividends foreign taxes deemed paid (gross-up) (16) (17) (18) All industries 359,898,600 68,480,746 29,020,456 Agriculture, forestry, and fishing 238,033 54,572 * 21,774 Mining 8,292,326 769,336 279,548 Metal mining * 1,842,738 * 102,841 * 25,690 Coal mining * 882,770 * 188,394 * 1,529 Oil and gas extraction 5,508,205 452,910 244,644 Nonmetallic minerals, except fuels * 58,613 * 25,191 * 7,686 Construction 449,484 85,149 * 16,088 General building contractors 217,131 * 57,205 * 5,962 Heavy construction contractors 135,803 * 13,019 * 618 Special trade contractors 96,550 * 14,925 * 9,509 Manufacturing 188,632,881 52,156,799 23,031,191 Food and kindred products 13,689,338 5,725,052 2,363,100 Tobacco manufactures * 6,301,840 * 2,409,557 * 1,020,175 Textile mill products 134,199 * 55,839 * 25,154 Apparel and other textile products 1,072,953 * 389,563 * 254,620 Lumber and wood products 216,099 * 68,009 * 35,533 Furniture and fixtures 183,348 * 54,589 * 22,043 Paper and allied products 3,343,913 1,302,738 521,416 Printing and publishing 4,916,174 257,955 158,002 Industrial plastics and synthetic material 11,448,415 3,568,707 1,350,852 Drugs 16,247,439 6,852,075 2,147,856 Other chemicals 6,940,225 1,912,289 1,084,618 Petroleum (including integrated) and coal products 34,726,319 7,444,356 3,395,725 Rubber and miscellaneous plastics products 1,914,920 547,831 358,333 Leather and leather products 137,581 * 8,431 * 2,005 Stone, clay, and glass products 702,088 221,602 84,332 Primary metal industries 2,389,004 635,810 310,309 Fabricated metal products 3,448,092 1,019,606 694,109 Office, computing, and accounting equipment 17,124,711 4,104,545 2,629,650 Other machinery, except electrical 7,450,265 1,607,925 642,113 Electrical and electronic equipment 27,323,241 5,844,142 2,336,386 Motor vehicles and equipment 13,028,265 4,355,007 1,981,592 Transportation equipment, except motor vehicles 4,695,527 1,064,354 397,281 Instruments and related products 9,976,595 2,423,756 1,067,059 Miscellaneous manufacturing and manufacturing not allocable 1,222,332 283,062 148,927 Transportation and public utilities 22,221,685 1,606,457 585,276 Transportation 13,704,989 271,889 88,808 Water transportation 320,690 * 52,469 * 13,417 All other transportation 13,384,299 219,420 75,391 Communication 7,261,024 671,676 * 322,130 Electric, gas, and sanitary services 1,255,671 662,892 174,338 Wholesale and retail trade 13,921,240 1,997,340 1,121,448 Wholesale trade 9,486,444 1,224,310 510,674 Groceries and related products 61,489 * 7,424 * 4,965 Machinery, equipment, and supplies 235,439 18,574 4,744 Miscellaneous wholesale trade 9,189,516 1,198,312 500,965 Drugs, chemicals, and allied products 1,102,131 * 44,931 * 16,312 Petroleum and petroleum products * 2,164,090 * 137,794 * 53,744 Other miscellaneous wholesale trade 5,923,295 1,015,587 430,909 Retail trade 4,434,796 773,030 610,774 Building materials, garden supplies, and mobile home dealers * 10,428 * 11 -- General merchandise stores * 452,001 * 38,139 * 7,300 Food stores * 77,019 * 23 -- Automotive dealers and service station * 1,169 * 241 -- Apparel and accessory stores 435,712 * 194,739 * 113,315 Furniture and home furnishing stores * 27,945 * 8,284 * 2,494 Eating and drinking places 2,839,366 * 477,165 * 462,507 All other retail stores 591,155 54,428 * 25,159 Finance, insurance, and real estate 102,621,003 9,539,627 2,636,478 Banking 52,894,722 3,648,589 1,055,611 Credit agencies other than banks 8,858,262 947,618 279,502 Security, commodity brokers, and services 13,336,865 1,065,400 320,652 Insurance 24,599,962 2,685,225 444,350 Insurance agents, brokers, and service 448,845 * 193,598 * 44,255 Real estate 71,603 26,037 9,180 Holding and other investment companies, except bank holding companies 2,410,746 973,161 482,929 Services 23,521,948 2,271,466 1,328,651 Hotels and other lodging places 1,494,584 * 251,427 * 144,531 Personal services * 183,347 * 24,122 * 13,274 Business services 15,820,544 1,542,152 1,038,858 Auto repair; miscellaneous repair services 11,023 * 1,897 * 1,060 Amusement and recreation services 4,131,202 280,102 79,132 All other services 1,881,249 171,767 51,796 Foreign income and taxes reported on Form 1118 Gross income (less loss) Rents, Major and selected minor royalties, Service industrial group Interest and income license fees (19) (20) (21) All industries 61,505,751 48,610,292 31,387,624 Agriculture, forestry, and fishing * 19,744 * 14,007 -- Mining 221,170 310,547 3,073,644 Metal mining * 58,968 * 5,255 * 216,428 Coal mining * 58,789 * 32,068 * -5,239 Oil and gas extraction 92,837 271,660 2,861,612 Nonmetallic minerals, except fuels * 10,576 * 1,564 * 843 Construction * 9,344 23,555 195,865 General building contractors * 4,151 * 12,720 * 116,958 Heavy construction contractors * 3,540 * 2,978 * 58,228 Special trade contractors * 1,653 * 7,857 * 20,680 Manufacturing 8,366,129 33,953,415 3,733,558 Food and kindred products 242,803 2,054,826 * 197,065 Tobacco manufactures * 70,454 * 1,016,244 * 7,054 Textile mill products * 3,535 * 17,548 * 594 Apparel and other textile products * 7,410 320,759 * 11,058 Lumber and wood products * 38,249 * 11,653 * 150 Furniture and fixtures * 8,896 15,133 * 9,974 Paper and allied products 73,976 533,801 * 57,331 Printing and publishing 37,208 2,421,093 54,105 Industrial plastics and synthetic material 414,493 1,773,306 354,457 Drugs 253,898 2,784,874 * 92,065 Other chemicals 116,757 1,717,717 33,956 Petroleum (including integrated) and coal products 3,661,334 687,722 * 135,735 Rubber and miscellaneous plastics products 51,422 439,837 * 1,406 Leather and leather products * 4,918 58,924 * 12,587 Stone, clay, and glass products 30,230 147,743 * 44,539 Primary metal industries 114,964 151,540 * 19,440 Fabricated metal products 154,931 337,368 63,442 Office, computing, and accounting equipment 165,280 7,189,193 * 304,791 Other machinery, except electrical 376,011 705,574 141,730 Electrical and electronic equipment 1,354,714 5,139,642 555,468 Motor vehicles and equipment 453,655 2,215,662 * 540,803 Transportation equipment, except motor vehicles 471,914 651,303 747,740 Instruments and related products 243,554 3,165,308 326,712 Miscellaneous manufacturing and manufacturing not allocable 15,524 396,647 21,357 Transportation and public utilities 320,490 426,902 9,220,380 Transportation 43,022 83,274 8,925,407 Water transportation * 549 * 31 * 219,255 All other transportation 42,473 83,242 8,706,151 Communication * 192,035 * 287,698 * 196,704 Electric, gas, and sanitary services 85,434 * 55,931 98,269 Wholesale and retail trade 2,054,128 1,450,456 414,872 Wholesale trade 1,848,267 424,144 148,570 Groceries and related products * 1,437 * 1,795 * 2,319 Machinery, equipment, and supplies 3,334 * 13,237 * 4,627 Miscellaneous wholesale trade 1,843,497 409,112 141,623 Drugs, chemicals, and allied products * 5,516 * 3,907 * 18,212 Petroleum and petroleum products * 1,468,833 * 10,665 * 709 Other miscellaneous wholesale trade 369,147 394,539 122,703 Retail trade 208,860 1,026,312 266,303 Building materials, garden supplies, and mobile home dealers -- * 10,418 -- General merchandise stores * 21,818 * 103,710 * 187,127 Food stores * 5,821 * 71,121 -- Automotive dealers and service station * 591 * 91 * 47 Apparel and accessory stores * 4,337 * 54,279 -- Furniture and home furnishing stores * 195 * 11,367 -- Eating and drinking places * 152,079 662,263 * 6,040 All other retail stores 21,019 113,063 * 73,089 Finance, insurance, and real estate 49,935,328 1,923,139 9,976,238 Banking 31,926,026 1,217,318 * 1,933,550 Credit agencies other than banks 2,388,198 * 118,648 * 30,821 Security, commodity brokers, and services 8,325,109 * 21,833 398,894 Insurance 6,866,178 510,999 7,236,052 Insurance agents, brokers, and service * 15,483 -- * 187,313 Real estate 11,073 * 14,708 * 4,899 Holding and other investment companies, except bank holding companies 403,262 * 39,633 * 184,710 Services 579,418 10,508,272 4,773,067 Hotels and other lodging places 96,072 * 361,875 * 76,766 Personal services * 2,873 * 8,616 * 132,621 Business services 287,651 7,015,616 2,882,667 Auto repair; miscellaneous repair services * 861 * 5,613 * 917 Amusement and recreation services * 188,204 2,830,579 * 575,038 All other services 3,757 285,974 1,105,059 Foreign income and taxes reported on Form 1118 Gross income (less loss) Oil and gas Major and selected minor Other extraction Foreign industrial group income income branch (less income (3) loss) (3) (22) (23) (24) All industries 120,893,731 21,013,968 88,607,770 Agriculture, forestry, and fishing * 127,936 -- * 673 Mining 3,638,080 2,037,440 3,126,813 Metal mining * 1,433,557 -- * 182,890 Coal mining * 607,229 -- * 173,008 Oil and gas extraction 1,584,542 2,037,440 2,765,767 Nonmetallic minerals, except fuels * 12,752 -- * 5,146 Construction 119,483 -- * 83,784 General building contractors * 20,136 -- * 27,218 Heavy construction contractors * 57,420 -- * 38,583 Special trade contractors * 41,927 -- * 17,982 Manufacturing 67,391,789 18,743,589 27,638,925 Food and kindred products 3,106,492 -- 1,531,208 Tobacco manufactures * 1,778,356 -- * 1,068,525 Textile mill products * 31,529 -- * 904 Apparel and other textile products * 89,542 -- * 52,217 Lumber and wood products * 62,506 -- * 12,452 Furniture and fixtures * 72,711 -- * 29,775 Paper and allied products 854,652 -- * 26,739 Printing and publishing 1,987,810 -- * 314,801 Industrial plastics and synthetic material 3,986,600 * 1,394,900 1,828,270 Drugs 4,116,672 -- 1,414,540 Other chemicals 2,074,888 -- 1,298,847 Petroleum (including integrated) and coal products 19,401,447 17,348,689 * 14,093,770 Rubber and miscellaneous plastics products 516,091 -- 97,681 Leather and leather products * 50,716 -- * 853 Stone, clay, and glass products 173,642 -- * 53,447 Primary metal industries 1,156,941 -- 724,469 Fabricated metal products 1,178,637 -- 140,547 Office, computing, and accounting equipment 2,731,252 -- * 1,506,613 Other machinery, except electrical 3,976,912 -- 789,711 Electrical and electronic equipment 12,092,889 -- 819,692 Motor vehicles and equipment 3,481,547 -- * 998,434 Transportation equipment, except motor vehicles 1,362,935 -- * 367,002 Instruments and related products 2,750,206 -- 358,610 Miscellaneous manufacturing and manufacturing not allocable 356,815 -- 109,819 Transportation and public utilities 10,062,180 * 41,616 4,476,116 Transportation 4,292,590 -- * 4,084,653 Water transportation * 34,968 -- -- All other transportation 4,257,621 -- * 4,084,653 Communication * 5,590,781 -- * 292,337 Electric, gas, and sanitary services 178,808 * 41,616 * 99,126 Wholesale and retail trade 6,882,996 * 21,791 2,983,585 Wholesale trade 5,330,479 * 21,791 1,704,490 Groceries and related products * 43,550 -- * 37,787 Machinery, equipment, and supplies 190,922 -- * 44,084 Miscellaneous wholesale trade 5,096,007 * 21,791 1,622,619 Drugs, chemicals, and allied products * 1,013,252 -- * 903,109 Petroleum and petroleum products * 492,346 * 21,791 * 272,400 Other miscellaneous wholesale trade 3,590,409 -- 447,110 Retail trade 1,552,517 -- 1,279,096 Building materials, garden supplies, and mobile home dealers -- -- -- General merchandise stores * 93,907 -- * 83,406 Food stores * 53 -- -- Automotive dealers and service station * 198 -- -- Apparel and accessory stores * 69,042 -- * 37,300 Furniture and home furnishing stores * 5,606 -- -- Eating and drinking places 1,079,313 -- * 899,542 All other retail stores 304,397 -- * 258,848 Finance, insurance, and real estate 28,610,193 * 169,532 46,773,056 Banking 13,113,629 -- 32,930,336 Credit agencies other than banks 5,093,475 -- * 3,153,617 Security, commodity brokers, and services 3,204,977 -- * 159,241 Insurance 6,857,159 -- 10,509,334 Insurance agents, brokers, and service * 8,198 -- * 1,407 Real estate * 5,706 -- * 6,896 Holding and other investment companies, except bank holding companies 327,051 * 169,532 * 12,225 Services 4,061,074 -- 3,524,818 Hotels and other lodging places * 563,913 -- * 297,942 Personal services * 1,842 -- * 22,938 Business services 3,053,601 -- 2,552,818 Auto repair; miscellaneous repair services * 675 -- -- Amusement and recreation services 178,147 -- * 495,870 All other services 262,897 -- 155,251 Foreign income and taxes reported on Form 1118 Deductions Deductions allocable to specific types of income Specifically allocable Major and selected minor income Total Total industrial group [section 883(b)] (3) (25) (26) (27) All industries 24,911,121 201,909,309 107,480,799 Agriculture, forestry, and fishing * 92,236 * 98,061 * 59,042 Mining * 378,536 5,133,029 4,199,314 Metal mining -- * 1,354,276 * 1,013,529 Coal mining -- * 575,397 * 548,549 Oil and gas extraction * 354,548 3,186,103 2,630,430 Nonmetallic minerals, except fuels * 23,989 * 17,253 * 6,806 Construction * 40,924 294,026 228,015 General building contractors * 40,924 150,124 119,147 Heavy construction contractors -- * 91,323 * 61,372 Special trade contractors -- * 52,579 * 47,496 Manufacturing 17,567,896 85,811,444 48,178,233 Food and kindred products 517,916 4,632,143 2,513,109 Tobacco manufactures * 718,717 * 2,464,893 * 1,680,497 Textile mill products * 30,789 47,970 * 26,657 Apparel and other textile products * 10,788 * 210,758 * 108,597 Lumber and wood products * 2,983 76,157 * 36,416 Furniture and fixtures * 33,952 * 106,435 * 71,617 Paper and allied products 474,619 1,299,730 472,386 Printing and publishing * 61,357 3,366,082 1,823,944 Industrial plastics and synthetic material 1,632,453 5,640,689 3,132,183 Drugs 1,449,375 8,454,539 5,624,402 Other chemicals 552,709 2,895,692 1,690,790 Petroleum (including integrated) and coal products * 190,579 14,924,911 12,667,712 Rubber and miscellaneous plastics products 50,542 704,508 436,016 Leather and leather products * 4,365 * 63,404 * 14,037 Stone, clay, and glass products * 135,532 387,642 171,408 Primary metal industries 116,468 1,059,985 501,595 Fabricated metal products 334,411 1,241,234 646,658 Office, computing, and accounting equipment * 836,332 6,700,626 2,153,977 Other machinery, except electrical 919,857 4,144,570 1,990,970 Electrical and electronic equipment 5,655,989 13,893,037 7,179,468 Motor vehicles and equipment 1,053,508 5,298,138 1,344,068 Transportation equipment, except motor vehicles 464,594 2,560,215 2,073,629 Instruments and related products 2,117,560 5,063,276 1,531,697 Miscellaneous manufacturing and manufacturing not allocable 202,503 574,811 286,404 Transportation and public utilities 2,615,529 16,849,056 14,832,180 Transportation * 2,516,237 11,584,803 10,940,760 Water transportation * 23,532 * 115,069 * 98,127 All other transportation * 2,492,704 11,469,734 10,842,633 Communication * 13,515 4,656,524 3,663,007 Electric, gas, and sanitary services * 85,777 607,729 228,414 Wholesale and retail trade 196,739 8,143,471 5,880,777 Wholesale trade 180,946 6,187,407 4,401,434 Groceries and related products -- * 41,000 * 39,659 Machinery, equipment, and supplies * 5,784 158,239 100,781 Miscellaneous wholesale trade 175,162 5,988,168 4,320,995 Drugs, chemicals, and allied products * 56,465 810,817 791,439 Petroleum and petroleum products -- * 1,402,555 * 568,747 Other miscellaneous wholesale trade 118,696 3,774,796 2,960,808 Retail trade * 15,792 1,956,063 1,419,342 Building materials, garden supplies, and mobile home dealers -- * 2,656 -- General merchandise stores -- * 242,788 * 135,548 Food stores * 13 * 4,153 * 3,449 Automotive dealers and service station -- -- -- Apparel and accessory stores -- * 125,147 * 80,190 Furniture and home furnishing stores -- * 10,207 * 4,732 Eating and drinking places * 836 1,262,250 925,979 All other retail stores * 14,944 308,862 269,444 Finance, insurance, and real estate 3,040,235 70,715,971 24,356,750 Banking * 2,520,932 39,669,069 7,873,266 Credit agencies other than banks * 19,409 6,704,041 4,824,157 Security, commodity brokers, and services * 2,279 8,440,162 2,056,750 Insurance 452,503 14,877,880 8,752,969 Insurance agents, brokers, and service -- * 204,978 * 180,890 Real estate * 8,452 26,100 19,715 Holding and other investment companies, except bank holding companies * 36,661 793,741 651,002 Services 1,039,026 14,864,252 9,744,408 Hotels and other lodging places -- 914,712 553,882 Personal services * 291 * 125,905 * 119,710 Business services 635,938 9,032,948 5,157,554 Auto repair; miscellaneous repair services * 3,347 * 2,253 * 1,347 Amusement and recreation services * 234,220 3,450,600 2,848,448 All other services * 165,231 1,337,835 1,063,546 Foreign income and taxes reported on Form 1118 Deductions Deductions allocable to specific types of income Rental, royalty, and licensing expenses Depreciation, Major and selected minor depletion, Service industrial group and Other expenses amortization (28) (29) (30) All industries 1,257,812 7,358,799 13,663,474 Agriculture, forestry, and fishing -- * 521 -- Mining 117,568 66,502 1,266,808 Metal mining * 874 * 933 * 1,063 Coal mining * 13,438 * 5,882 -- Oil and gas extraction 103,257 59,687 1,261,520 Nonmetallic minerals, except fuels -- -- * 4,225 Construction * 349 * 1,281 131,860 General building contractors * 150 * 508 * 74,977 Heavy construction contractors -- * 460 * 43,766 Special trade contractors * 200 * 313 * 13,117 Manufacturing 298,396 3,113,488 2,125,735 Food and kindred products * 1,271 * 786,114 * 1,867 Tobacco manufactures -- * 37,383 -- Textile mill products -- -- * 301 Apparel and other textile products * 71 * 9,729 * 1,956 Lumber and wood products -- -- -- Furniture and fixtures * 216 * 2,918 * 1,944 Paper and allied products * 620 * 19,947 * 56,472 Printing and publishing * 2,892 350,370 * 35,935 Industrial plastics and synthetic material * 4,827 18,085 * 170,175 Drugs * 8 * 769,599 * 19,115 Other chemicals * 354 * 2,144 * 10,268 Petroleum (including integrated) and coal products * 8,536 * 147,312 * 234,590 Rubber and miscellaneous plastics products * 3,758 * 6,524 * 333 Leather and leather products -- * 1,187 * 371 Stone, clay, and glass products * 16 * 1,104 * 41,425 Primary metal industries * 159,211 * 65,016 -- Fabricated metal products * 2,466 * 11,173 * 49,644 Office, computing, and accounting equipment * 1,333 * 2,936 * 1,945 Other machinery, except electrical * 662 61,786 185,236 Electrical and electronic equipment * 796 260,198 206,656 Motor vehicles and equipment * 1,241 * 305,446 * 532,719 Transportation equipment, except motor vehicles * 103,305 * 82,546 * 557,084 Instruments and related products * 1,302 * 67,996 * 13,245 Miscellaneous manufacturing and manufacturing not allocable * 5,512 * 103,974 * 4,457 Transportation and public utilities 33,657 60,222 5,797,057 Transportation * 1,848 * 5,542 5,548,311 Water transportation * 409 * 3,207 * 93,256 All other transportation * 1,439 * 2,336 5,455,055 Communication * 1 * 54,668 * 184,200 Electric, gas, and sanitary services * 31,808 * 12 * 64,546 Wholesale and retail trade 8,652 315,244 159,090 Wholesale trade 7,091 181,708 59,965 Groceries and related products * 161 * 951 * 2,085 Machinery, equipment, and supplies * 5,576 * 10,312 * 1,489 Miscellaneous wholesale trade * 1,353 170,445 56,391 Drugs, chemicals, and allied products -- -- * 17,228 Petroleum and petroleum products -- -- -- Other miscellaneous wholesale trade * 1,353 170,445 39,163 Retail trade * 1,561 133,536 * 99,125 Building materials, garden supplies, and mobile home dealers -- -- -- General merchandise stores * 388 -- * 70,149 Food stores -- * 2,658 -- Automotive dealers and service station -- -- -- Apparel and accessory stores -- * 373 -- Furniture and home furnishing stores -- * 1,929 -- Eating and drinking places -- * 15,055 * 3,594 All other retail stores * 1,174 * 113,521 * 25,382 Finance, insurance, and real estate 551,075 1,551,966 1,008,729 Banking * 403,901 488,406 * 68,402 Credit agencies other than banks * 56,245 * 3,428 * 42,909 Security, commodity brokers, and services * 85 * 545,215 219,290 Insurance * 88,339 497,258 489,676 Insurance agents, brokers, and service * 358 * 4,242 * 12,675 Real estate * 1,804 * 10,039 * 4,250 Holding and other investment companies, except bank holding companies * 343 * 3,378 * 171,527 Services 248,114 2,249,674 3,174,195 Hotels and other lodging places * 4,553 * 12,606 * 9,787 Personal services -- -- * 117,789 Business services 12,276 461,536 1,877,405 Auto repair; miscellaneous repair services * 356 * 10 * 469 Amusement and recreation services * 230,806 1,696,939 * 365,003 All other services * 122 78,483 803,743 Foreign income and taxes reported on Form 1118 Deductions Deductions not allocable to specific types of income Other deductions allocable Research Major and selected minor to Total and industrial group specific development types of income (31) (32) (33) All industries 85,200,714 94,428,510 9,565,637 Agriculture, forestry, and fishing * 58,521 * 39,019 * 20,993 Mining 2,740,435 933,715 * 38,287 Metal mining * 1,010,659 * 340,747 -- Coal mining * 529,229 * 26,648 -- Oil and gas extraction 1,205,966 555,672 * 38,287 Nonmetallic minerals, except fuels * 2,581 * 10,447 -- Construction 94,524 66,011 * 1,015 General building contractors * 43,513 * 30,977 * 179 Heavy construction contractors * 17,145 * 29,951 -- Special trade contractors * 33,866 * 5,083 * 836 Manufacturing 42,640,613 37,633,211 7,834,168 Food and kindred products 1,723,856 2,119,034 50,435 Tobacco manufactures * 1,643,114 * 784,396 * 57,775 Textile mill products * 26,356 21,314 * 1,919 Apparel and other textile products * 96,840 * 102,161 * 5,397 Lumber and wood products * 38,416 * 39,741 * 399 Furniture and fixtures * 66,539 * 34,818 * 4,426 Paper and allied products 395,347 827,344 124,072 Printing and publishing 1,434,747 1,542,138 * 17,717 Industrial plastics and synthetic material 2,939,096 2,508,506 506,875 Drugs 4,835,681 2,830,137 726,805 Other chemicals 1,678,023 1,204,902 345,898 Petroleum (including integrated) and coal products 12,277,274 2,257,200 143,030 Rubber and miscellaneous plastics products 425,401 268,493 78,867 Leather and leather products * 12,480 * 49,367 * 1,260 Stone, clay, and glass products * 128,863 216,234 * 33,135 Primary metal industries 277,367 558,391 9,476 Fabricated metal products 583,374 594,576 78,327 Office, computing, and accounting equipment * 2,147,762 4,546,649 1,786,323 Other machinery, except electrical 1,743,286 2,153,600 292,562 Electrical and electronic equipment 6,711,819 6,713,569 1,626,595 Motor vehicles and equipment 504,662 3,954,070 460,521 Transportation equipment, except motor vehicles 1,330,694 486,586 133,758 Instruments and related products 1,449,154 3,531,579 1,268,596 Miscellaneous manufacturing and manufacturing not allocable 172,462 288,407 80,000 Transportation and public utilities 8,941,243 2,016,875 * 57,203 Transportation 5,385,058 644,043 * 7,874 Water transportation * 1,255 * 16,942 -- All other transportation 5,383,803 627,101 * 7,874 Communication * 3,424,138 993,517 * 49,218 Electric, gas, and sanitary services 132,048 379,315 * 110 Wholesale and retail trade 5,397,790 2,262,694 24,693 Wholesale trade 4,212,670 1,725,973 24,284 Groceries and related products * 36,461 * 1,341 -- Machinery, equipment, and supplies * 83,404 57,458 * 49 Miscellaneous wholesale trade 4,092,805 1,667,173 24,235 Drugs, chemicals, and allied products * 774,212 * 19,378 -- Petroleum and petroleum products * 568,747 * 833,808 -- Other miscellaneous wholesale trade 2,749,846 813,988 24,235 Retail trade 1,185,120 536,721 * 409 Building materials, garden supplies, and mobile home dealers -- * 2,658 -- General merchandise stores * 65,012 * 107,240 * 6 Food stores * 791 * 704 -- Automotive dealers and service station -- -- -- Apparel and accessory stores * 79,817 * 44,957 * 171 Furniture and home furnishing stores * 2,803 * 5,476 -- Eating and drinking places * 907,331 336,271 * 12 All other retail stores 129,367 39,418 * 221 Finance, insurance, and real estate 21,246,980 46,357,221 * 106,260 Banking 6,912,557 31,795,803 * 99,921 Credit agencies other than banks 4,721,575 1,879,884 -- Security, commodity brokers, and services 1,292,161 6,383,412 -- Insurance 7,677,696 6,124,911 * 944 Insurance agents, brokers, and service * 163,615 * 24,088 * 5,394 Real estate 3,622 * 6,384 -- Holding and other investment companies, except bank holding companies 475,755 142,738 -- Services 4,072,605 5,119,764 1,483,018 Hotels and other lodging places * 526,937 360,830 -- Personal services * 1,921 * 6,195 * 317 Business services 2,806,337 3,875,394 1,445,526 Auto repair; miscellaneous repair services * 512 * 905 * 1 Amusement and recreation services * 555,700 602,152 * 16,487 All other services 181,198 274,289 * 20,688 Foreign income and taxes reported on Form 1118 Deductions Deductions not allocable to specific types of income Deductions from oil Major and selected minor Interest Other and gas industrial group extraction income (4) (34) (35) (36) All industries 43,342,264 40,176,836 8,915,360 Agriculture, forestry, and fishing * 8,934 * 90,93 -- Mining 302,159 589,613 1,032,644 Metal mining * 98,566 * 242,182 -- Coal mining * 25,751 -- -- Oil and gas extraction 169,871 346,379 1,032,644 Nonmetallic minerals, except fuels * 7,971 * 1,053 -- Construction * 9,348 * 34,612 -- General building contractors * 3,248 * 27,532 -- Heavy construction contractors * 4,438 * 5,875 -- Special trade contractors * 1,662 * 1,206 -- Manufacturing 12,397,235 16,818,994 7,836,010 Food and kindred products 783,997 1,270,577 -- Tobacco manufactures * 313,781 * 412,840 -- Textile mill products * 14,510 * 4,492 -- Apparel and other textile products * 67,938 * 26,571 -- Lumber and wood products * 22,088 * 17,192 -- Furniture and fixtures * 23,354 * 6,582 -- Paper and allied products 200,269 499,898 -- Printing and publishing 192,317 1,294,902 -- Industrial plastics and synthetic material 1,317,191 669,543 * 538,615 Drugs 935,282 953,100 -- Other chemicals 367,840 474,129 -- Petroleum (including integrated) and coal products 1,556,901 557,242 7,299,395 Rubber and miscellaneous plastics products 103,100 85,280 -- Leather and leather products * 6,876 * 39,636 -- Stone, clay, and glass products 96,151 * 85,634 -- Primary metal industries 184,443 345,538 -- Fabricated metal products 292,676 211,494 -- Office, computing, and accounting equipment 491,793 2,266,819 -- Other machinery, except electrical 526,380 1,157,116 -- Electrical and electronic equipment 1,997,431 3,047,823 -- Motor vehicles and equipment 2,147,313 1,342,840 -- Transportation equipment, except motor vehicles 181,469 171,265 -- Instruments and related products 503,284 1,748,345 -- Miscellaneous manufacturing and manufacturing not allocable 70,851 130,136 -- Transportation and public utilities 1,002,896 951,350 * 35,759 Transportation 159,933 474,034 -- Water transportation * 16,406 * 416 -- All other transportation 143,527 473,618 -- Communication * 492,785 * 451,514 -- Electric, gas, and sanitary services 350,178 * 25,803 * 35,759 Wholesale and retail trade 1,459,232 719,208 * 10,947 Wholesale trade 1,158,259 506,770 * 10,947 Groceries and related products * 280 * 638 -- Machinery, equipment, and supplies * 6,319 * 47,736 -- Miscellaneous wholesale trade 1,151,660 458,397 * 10,947 Drugs, chemicals, and allied products * 2,301 * 8,476 -- Petroleum and petroleum products * 762,332 * 71,462 * 10,947 Other miscellaneous wholesale trade 387,027 378,458 -- Retail trade 300,973 212,438 -- Building materials, garden supplies, and mobile home dealers -- -- -- General merchandise stores * 80,490 * 26,744 -- Food stores * 468 * 218 -- Automotive dealers and service station -- -- -- Apparel and accessory stores * 30,655 * 12,949 -- Furniture and home furnishing stores * 965 * 2,742 -- Eating and drinking places * 175,733 * 158,093 -- All other retail stores 12,661 * 11,692 -- Finance, insurance, and real estate 27,300,990 18,442,444 -- Banking 18,942,052 12,279,487 -- Credit agencies other than banks 1,222,764 * 657,120 -- Security, commodity brokers, and services 5,892,346 488,979 -- Insurance 1,154,868 4,942,605 -- Insurance agents, brokers, and service * 15,316 * 3,373 -- Real estate * 5,586 * 798 -- Holding and other investment companies, except bank holding companies 68,057 70,081 -- Services 861,470 2,611,521 -- Hotels and other lodging places * 154,879 * 192,524 -- Personal services * 3,385 * 221 -- Business services 250,159 2,053,030 -- Auto repair; miscellaneous repair services * 95 * 689 -- Amusement and recreation services * 427,521 * 152,531 -- All other services 25,431 212,527 -- Foreign income and taxes reported on Form 1118 Taxable Taxable income Adjustments income Major and selected minor (less loss) to taxable (less loss) industrial group before income after adjustments adjustment (37) (38) (39) All industries 157,989,290 7,715,086 150,274,204 Agriculture, forestry, and fishing 139,972 * 4,133 135,839 Mining 3,159,297 288,600 2,870,696 Metal mining * 488,462 * 5,310 * 483,152 Coal mining * 307,372 -- * 307,372 Oil and gas extraction 2,322,103 283,290 2,038,812 Nonmetallic minerals, except fuels * 41,360 -- * 41,360 Construction 155,458 * 6,287 149,171 General building contractors 67,007 * 2,403 64,605 Heavy construction contractors 44,480 -- 44,480 Special trade contractors 43,971 * 3,885 40,086 Manufacturing 102,821,437 4,235,398 98,586,039 Food and kindred products 9,057,195 134,739 8,922,456 Tobacco manufactures * 3,836,947 * (5) * 3,836,947 Textile mill products 86,228 * 700 85,528 Apparel and other textile products 862,195 * 44,756 817,439 Lumber and wood products 139,943 * (5) 139,943 Furniture and fixtures 76,913 * 1,107 75,806 Paper and allied products 2,044,183 * 38,928 2,005,255 Printing and publishing 1,550,092 354,886 1,195,206 Industrial plastics and synthetic material 5,807,726 341,991 5,465,735 Drugs 7,792,900 465,238 7,327,662 Other chemicals 4,044,534 84,122 3,960,412 Petroleum (including integrated) and coal products 19,801,407 129,124 19,672,283 Rubber and miscellaneous plastics products 1,210,411 19,292 1,191,120 Leather and leather products 74,177 -- 74,177 Stone, clay, and glass products 314,446 * (5) 314,446 Primary metal industries 1,329,018 11,043 1,317,975 Fabricated metal products 2,206,858 118,428 2,088,431 Office, computing, and accounting equipment 10,424,085 * 801,571 9,622,515 Other machinery, except electrical 3,305,695 87,521 3,218,174 Electrical and electronic equipment 13,430,204 915,992 12,514,212 Motor vehicles and equipment 7,730,127 31,245 7,698,882 Transportation equipment, except motor vehicles 2,135,312 * 26,305 2,109,007 Instruments and related products 4,913,319 558,748 4,354,571 Miscellaneous manufacturing and manufacturing not allocable 647,521 * 69,663 577,856 Transportation and public utilities 5,372,629 941,262 4,431,367 Transportation 2,120,187 851,056 1,269,130 Water transportation 205,621 * 51,065 154,556 All other transportation 1,914,565 799,991 1,114,574 Communication 2,604,500 * 65,795 2,538,706 Electric, gas, and sanitary services 647,943 24,411 623,531 Wholesale and retail trade 5,777,769 910,079 4,867,690 Wholesale trade 3,299,037 774,933 2,524,104 Groceries and related products 20,489 * (5) 20,489 Machinery, equipment, and supplies 77,199 * 20,300 56,899 Miscellaneous wholesale trade 3,201,349 754,633 2,446,716 Drugs, chemicals, and allied products 291,314 * 17,077 274,237 Petroleum and petroleum products * 761,536 * 324,892 * 436,644 Other miscellaneous wholesale trade 2,148,499 412,664 1,735,835 Retail trade 2,478,732 135,147 2,343,586 Building materials, garden supplies, and mobile home dealers * 7,772 -- 7,772 General merchandise stores * 209,213 * 5,699 * 203,515 Food stores * 72,866 * 50,064 * 22,802 Automotive dealers and service station * 1,169 -- * 1,169 Apparel and accessory stores 310,565 * 25,154 285,411 Furniture and home furnishing stores * 17,738 * (5) * 17,738 Eating and drinking places 1,577,116 * 15,149 1,561,967 All other retail stores 282,293 * 39,081 243,212 Finance, insurance, and real estate 31,906,032 717,773 31,187,259 Banking 13,225,653 69,232 13,156,420 Credit agencies other than banks 2,154,220 * 9,418 2,144,802 Security, commodity brokers, and services 4,896,703 48,264 4,848,439 Insurance 9,722,081 563,665 9,158,416 Insurance agents, brokers, and service 243,867 -- 243,867 Real estate 45,503 * 3,295 42,208 Holding and other investment companies, except bank holding companies 1,617,005 23,898 1,593,107 Services 8,657,696 611,554 8,046,142 Hotels and other lodging places 579,872 * 29,028 550,843 Personal services * 57,442 -- * 57,442 Business services 6,787,596 377,714 6,409,883 Auto repair; miscellaneous repair services 8,770 * 465 8,305 Amusement and recreation services 680,603 29,987 650,615 All other services 543,414 174,360 369,054 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Reduction for Major and selected minor Total certain Carryover industrial group foreign taxes (40) (41) (42) All industries 49,979,466 2,516,340 7,416,008 Agriculture, forestry, and fishing 38,313 -- * 3,837 Mining 1,416,118 444,333 562,043 Metal mining * 417,581 * 1,703 * 121,791 Coal mining * 134,825 * 26,791 * 16,450 Oil and gas extraction 854,837 410,416 418,289 Nonmetallic minerals, except fuels * 8,875 * 5,423 * 5,512 Construction 63,431 -- 15,329 General building contractors 34,284 -- * 4,967 Heavy construction contractors 14,103 -- * 8,397 Special trade contractors 15,045 -- * 1,965 Manufacturing 35,792,177 2,059,580 5,450,727 Food and kindred products 3,042,404 -- 128,921 Tobacco manufactures * 1,379,627 -- * 67,626 Textile mill products 28,485 * 75 * 474 Apparel and other textile products 291,790 -- * 306 Lumber and wood products 52,370 -- * 11,604 Furniture and fixtures 41,940 -- * 15,666 Paper and allied products 716,140 -- 77,341 Printing and publishing 331,423 -- 9,504 Industrial plastics and synthetic material 1,851,492 -- 97,854 Drugs 2,815,266 -- 105,561 Other chemicals 1,471,640 -- 20,667 Petroleum (including integrated) and coal products 9,102,941 2,054,206 3,770,305 Rubber and miscellaneous plastics products 440,363 -- 16,549 Leather and leather products 11,896 -- * 208 Stone, clay, and glass products 144,642 -- * 34,489 Primary metal industries 701,061 * 5,049 265,146 Fabricated metal products 844,557 -- 47,490 Office, computing, and accounting equipment 3,376,725 -- * 81,825 Other machinery, except electrical 985,714 -- 133,257 Electrical and electronic equipment 3,437,298 -- 232,766 Motor vehicles and equipment 2,624,433 -- * 227,137 Transportation equipment, except motor vehicles 527,783 -- * 16,440 Instruments and related products 1,344,804 -- 63,803 Miscellaneous manufacturing and manufacturing not allocable 217,384 * 251 25,789 Transportation and public utilities 969,683 * 122 97,772 Transportation 213,860 -- 56,636 Water transportation 29,694 -- * 4,015 All other transportation 184,166 -- 52,621 Communication 539,130 -- * 26,238 Electric, gas, and sanitary services 216,693 * 122 * 14,898 Wholesale and retail trade 1,894,147 * (5) 237,214 Wholesale trade 980,300 * (5) 170,654 Groceries and related products 7,462 -- * 1,043 Machinery, equipment, and supplies 16,579 -- * 4,651 Miscellaneous wholesale trade 956,258 * (5) 164,961 Drugs, chemicals, and allied products 108,659 -- * 13,893 Petroleum and petroleum products * 143,801 -- * 22,910 Other miscellaneous wholesale trade 703,798 * (5) 128,157 Retail trade 913,847 -- 56,559 Building materials, garden supplies, and mobile home dealers * 1,835 -- -- General merchandise stores * 46,648 -- * 15,794 Food stores * 7,987 -- -- Automotive dealers and service station * 137 -- * 12 Apparel and accessory stores 135,143 -- * 13,361 Furniture and home furnishing stores * 3,573 -- * 7 Eating and drinking places 654,592 -- * 32,467 All other retail stores 63,932 -- * 4,918 Finance, insurance, and real estate 7,370,111 * 12,176 809,000 Banking 3,672,822 -- 391,946 Credit agencies other than banks 505,543 -- 39,738 Security, commodity brokers, and services 801,877 -- 56,838 Insurance 1,703,013 -- 219,370 Insurance agents, brokers, and service 50,660 -- * 400 Real estate 16,188 -- * 4,203 Holding and other investment companies, except bank holding companies 620,007 * 12,176 96,504 Services 2,435,487 * 129 240,087 Hotels and other lodging places 264,248 -- * 49,004 Personal services * 30,576 -- * 13,520 Business services 1,717,946 * 129 85,634 Auto repair; miscellaneous repair services 1,779 -- * 232 Amusement and recreation services 245,618 -- * 12,378 All other services 175,320 -- 79,319 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Paid or accrued Taxes Total paid, withheld Major and selected minor accrued Total at industrial group and deemed source on paid dividends (43) (44) (45) All industries 45,079,798 16,056,942 2,767,327 Agriculture, forestry, and fishing 34,476 12,702 2,521 Mining 1,298,408 1,018,859 53,846 Metal mining * 297,492 * 271,803 * 26,875 Coal mining * 145,166 * 143,637 * 1,408 Oil and gas extraction 846,964 602,320 * 25,198 Nonmetallic minerals, except fuels * 8,785 * 1,099 * 366 Construction 45,103 32,014 1,490 General building contractors 29,317 23,355 * 420 Heavy construction contractors 5,706 5,088 * 624 Special trade contractors 13,080 3,571 * 446 Manufacturing 32,401,030 9,367,486 2,203,741 Food and kindred products 2,913,483 550,383 241,284 Tobacco manufactures * 1,312,000 * 291,825 * 208,396 Textile mill products 28,086 2,933 * 1,790 Apparel and other textile products 291,484 36,864 * 13,082 Lumber and wood products 40,766 5,233 * 1,468 Furniture and fixtures 26,274 4,231 * 2,671 Paper and allied products 638,799 117,383 44,923 Printing and publishing 321,919 163,917 14,125 Industrial plastics and synthetic material 1,763,639 412,787 115,894 Drugs 2,709,705 561,850 323,897 Other chemicals 1,450,973 366,355 94,684 Petroleum (including integrated) and coal products 7,386,841 3,991,117 331,287 Rubber and miscellaneous plastics products 423,814 65,481 23,181 Leather and leather products 11,688 9,683 * 14 Stone, clay, and glass products 110,153 25,765 7,981 Primary metal industries 440,963 130,654 13,007 Fabricated metal products 797,067 102,958 29,376 Office, computing, and accounting equipment 3,294,900 665,251 268,408 Other machinery, except electrical 852,457 210,339 35,824 Electrical and electronic equipment 3,204,532 865,853 147,954 Motor vehicles and equipment 2,397,296 415,704 186,852 Transportation equipment, except motor vehicles 511,343 114,062 31,947 Instruments and related products 1,281,000 213,941 55,038 Miscellaneous manufacturing and manufacturing not allocable 191,846 42,919 10,677 Transportation and public utilities 872,033 286,757 22,552 Transportation 157,224 68,415 5,879 Water transportation 25,679 12,262 * 1,138 All other transportation 131,544 56,153 4,740 Communication 512,893 190,763 * 5,799 Electric, gas, and sanitary services 201,917 27,579 10,875 Wholesale and retail trade 1,656,933 535,490 90,146 Wholesale trade 809,646 298,976 65,388 Groceries and related products 6,420 * 1,454 * 279 Machinery, equipment, and supplies 11,928 7,185 1,055 Miscellaneous wholesale trade 791,298 290,337 64,053 Drugs, chemicals, and allied products 94,766 78,454 * 1,759 Petroleum and petroleum products * 120,891 * 67,147 * 24,466 Other miscellaneous wholesale trade 575,642 144,737 37,828 Retail trade 847,287 236,513 24,758 Building materials, garden supplies, and mobile home dealers * 1,835 * 1,835 * 2 General merchandise stores * 30,854 * 23,554 * 6,269 Food stores * 7,987 * 7,987 * 4 Automotive dealers and service station * 125 * 125 * 32 Apparel and accessory stores 121,782 8,467 * 907 Furniture and home furnishing stores * 3,566 * 1,072 * 373 Eating and drinking places 622,125 159,618 * 12,459 All other retail stores 59,014 33,855 * 4,712 Finance, insurance, and real estate 6,573,288 3,936,806 319,619 Banking 3,280,877 2,225,266 149,514 Credit agencies other than banks 465,804 186,303 17,133 Security, commodity brokers, and services 745,040 424,387 39,477 Insurance 1,483,643 1,039,290 85,587 Insurance agents, brokers, and service 50,260 6,005 * 3,186 Real estate 11,984 2,805 303 Holding and other investment companies, except bank holding companies 535,680 52,750 24,419 Services 2,195,529 866,829 73,412 Hotels and other lodging places 215,244 70,713 * 1,205 Personal services * 17,056 * 3,782 * 1,386 Business services 1,632,440 593,583 65,420 Auto repair; miscellaneous repair services 1,547 486 * (5) Amusement and recreation services 233,240 154,108 * 3,681 All other services 96,001 44,156 1,720 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Paid or accrued Other taxes Taxes withheld at paid or source on-- accrued on-- Rents, royalties, Major and selected minor Interest and Branch industrial group license income fees (46) (47) (48) All industries 640,883 2,238,232 6,063,443 Agriculture, forestry, and fishing * 484 * 3,076 * 1,724 Mining 9,917 12,595 286,739 Metal mining * 5,538 * 1,235 * 109,919 Coal mining * 1,674 -- * 9,278 Oil and gas extraction * 2,231 11,360 167,282 Nonmetallic minerals, except fuels * 474 -- * 260 Construction * 490 835 * 4,455 General building contractors * 89 * 383 * 2,765 Heavy construction contractors * 285 * 183 * 334 Special trade contractors * 116 * 269 * 1,356 Manufacturing 140,905 1,580,966 2,945,132 Food and kindred products 9,642 99,894 * 162,714 Tobacco manufactures * 8,255 * 58357 * 10,898 Textile mill products * 346 * 657 * 46 Apparel and other textile products * 71 16,908 * 6,168 Lumber and wood products * 1,274 * 579 * 1,890 Furniture and fixtures * 438 620 -- Paper and allied products 2,740 36,249 * 32,486 Printing and publishing 1,267 125,236 * 9,591 Industrial plastics and synthetic material 5,733 81,070 143,821 Drugs 7,394 99,741 89,468 Other chemicals 3,928 116,233 145,395 Petroleum (including integrated) and coal products 31,842 36,099 * 1,956,226 Rubber and miscellaneous plastics products 2,187 31,172 * 8,542 Leather and leather products * 192 * 8,531 * 931 Stone, clay, and glass products 3,625 7,907 * 181 Primary metal industries 2,432 10,388 * 38,517 Fabricated metal products 3,115 15,271 4,741 Office, computing, and accounting equipment * 2,462 328,268 * 51,561 Other machinery, except electrical 9,760 34,078 50,600 Electrical and electronic equipment 19,519 247,921 91,340 Motor vehicles and equipment 15,393 63,905 * 72,561 Transportation equipment, except motor vehicles 1,637 29,585 * 41,522 Instruments and related products 6,464 118,933 20,193 Miscellaneous manufacturing and manufacturing not allocable 1,191 13,363 5,741 Transportation and public utilities 7,467 21,541 36,575 Transportation 2,091 4,353 * 27,786 Water transportation * 85 * 1,198 -- All other transportation 2,006 3,154 * 27,786 Communication * 855 * 15,739 * 5,716 Electric, gas, and sanitary services * 4,522 * 1,450 * 3,074 Wholesale and retail trade 31,323 123,960 254,711 Wholesale trade 26,777 43,797 141,810 Groceries and related products * 99 * 188 * 791 Machinery, equipment, and supplies 347 * 396 * 3,089 Miscellaneous wholesale trade 26,331 43,212 137,930 Drugs, chemicals, and allied products * 1 * 260 * 75,989 Petroleum and petroleum products * 3,936 * 408 * 38,108 Other miscellaneous wholesale trade 22,393 42,544 23,833 Retail trade 4,546 80,164 112,901 Building materials, garden supplies, and mobile home dealers -- * 1,834 -- General merchandise stores * 3 * 6,742 * 7,194 Food stores * 582 * 7,401 -- Automotive dealers and service station * 59 * 12 -- Apparel and accessory stores * 117 * 3,246 * 1,700 Furniture and home furnishing stores * 19 * 680 -- Eating and drinking places * 2,942 52,397 * 90,147 All other retail stores * 823 7,852 * 13,861 Finance, insurance, and real estate 435,813 15,362 2,435,572 Banking 201,582 * 694 1,615,057 Credit agencies other than banks * 3,313 * 9,312 * 141,882 Security, commodity brokers, and services 73,091 * 40 79,323 Insurance 152,849 1,528 596,755 Insurance agents, brokers, and service * 92 -- * 1,866 Real estate * 1,378 * 416 * 407 Holding and other investment companies, except bank holding companies 3,507 * 3,372 * 282 Services 14,485 479,897 98,535 Hotels and other lodging places * 2,467 * 34,763 * 15,046 Personal services * 157 * 902 * 1,299 Business services 6,984 314,307 74,308 Auto repair; miscellaneous repair services * 105 * 359 -- Amusement and recreation services * 4,683 117,745 * 7,089 All other services * 88 11,821 * 794 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Paid or accrued Other taxes paid or accrued on-- Specifically allocable Major and selected minor income Service industrial group [section income 863(b)] (49) (50) All industries 29,802 292,786 Agriculture, forestry, and fishing -- -- Mining -- * 12,908 Metal mining -- * 8,171 Coal mining -- -- Oil and gas extraction -- * 4,737 Nonmetallic minerals, except fuels -- -- Construction -- 22,828 General building contractors -- * 18,459 Heavy construction contractors -- * 3,121 Special trade contractors -- * 1,246 Manufacturing 15,116 83,972 Food and kindred products * 817 * 6,964 Tobacco manufactures -- * 839 Textile mill products -- * 9 Apparel and other textile products -- * 379 Lumber and wood products -- * 15 Furniture and fixtures -- * 253 Paper and allied products * 509 * 460 Printing and publishing * 40 * 1,146 Industrial plastics and synthetic material * 93 * 3,051 Drugs * 317 * 5,979 Other chemicals -- * 4,763 Petroleum (including integrated) and coal products -- * 361 Rubber and miscellaneous plastics products * 78 * 98 Leather and leather products -- * 12 Stone, clay, and glass products * 71 * 2,616 Primary metal industries -- * 2,151 Fabricated metal products -- * 279 Office, computing, and accounting equipment -- * 4,557 Other machinery, except electrical * 358 19,169 Electrical and electronic equipment * 12,051 9,582 Motor vehicles and equipment -- * 10,972 Transportation equipment, except motor vehicles * 232 * 7,866 Instruments and related products * 549 * 2,405 Miscellaneous manufacturing and manufacturing not allocable -- * 47 Transportation and public utilities * 6,887 22,252 Transportation * 6,788 15,868 Water transportation -- * 4,709 All other transportation * 6,768 11,158 Communication * 98 * 2,369 Electric, gas, and sanitary services -- * 4,015 Wholesale and retail trade -- 9,568 Wholesale trade -- 2,599 Groceries and related products -- * 97 Machinery, equipment, and supplies -- * 95 Miscellaneous wholesale trade -- 2,406 Drugs, chemicals, and allied products -- * 194 Petroleum and petroleum products -- * 227 Other miscellaneous wholesale trade -- 1,984 Retail trade -- * 6,969 Building materials, garden supplies, and mobile home dealers -- -- General merchandise stores -- * 1,264 Food stores -- -- Automotive dealers and service station -- * 12 Apparel and accessory stores -- -- Furniture and home furnishing stores -- -- Eating and drinking places -- -- All other retail stores -- * 5,693 Finance, insurance, and real estate * 40 83,257 Banking * 40 * 4,279 Credit agencies other than banks -- * 4,828 Security, commodity brokers, and services -- 16,469 Insurance -- 51,422 Insurance agents, brokers, and service -- * 494 Real estate -- * 41 Holding and other investment companies, except bank holding companies -- * 5,724 Services * 7,759 58,002 Hotels and other lodging places -- * 5,263 Personal services -- * 39 Business services * 7,759 16,733 Auto repair; miscellaneous repair services -- * 18 Amusement and recreation services -- * 16,899 All other services -- 19,050 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Paid or accrued Other taxes paid or accrued on-- Taxes Major and selected minor Other deemed industrial group income paid (51) (52) All industries 4,024,468 29,022,856 Agriculture, forestry, and fishing * 4,897 * 21,774 Mining 642,854 279,548 Metal mining * 120,065 * 25,690 Coal mining * 131,276 * 1,529 Oil and gas extraction 391,513 244,644 Nonmetallic minerals, except fuels -- * 7,686 Construction 1,918 * 16,088 General building contractors * 1,238 * 5,962 Heavy construction contractors * 542 * 618 Special trade contractors * 137 * 9,509 Manufacturing 2,397,654 23,033,544 Food and kindred products 29,068 2,363,100 Tobacco manufactures * 5,079 * 1,020,175 Textile mill products * 84 * 25,154 Apparel and other textile products * 256 * 254,620 Lumber and wood products * 7 * 35,533 Furniture and fixtures * 249 * 22,043 Paper and allied products * 16 521,416 Printing and publishing 12,511 158,002 Industrial plastics and synthetic material 63,124 1,350,852 Drugs 35,053 2,147,856 Other chemicals 1,351 1,084,618 Petroleum (including integrated) and coal products 1,635,322 3,395,725 Rubber and miscellaneous plastics products * 223 358,333 Leather and leather products * 4 * 2,005 Stone, clay, and glass products * 3,385 84,388 Primary metal industries 64,158 310,309 Fabricated metal products 50,176 694,109 Office, computing, and accounting equipment * 9,995 2,629,650 Other machinery, except electrical 60,550 642,117 Electrical and electronic equipment 337,487 2,338,679 Motor vehicles and equipment * 66,022 1,981,592 Transportation equipment, except motor vehicles * 1,273 397,281 Instruments and related products 10,360 1,067,059 Miscellaneous manufacturing and manufacturing not allocable 11,901 148,927 Transportation and public utilities 169,482 585,276 Transportation * 5,651 88,808 Water transportation * 5,131 * 13,417 All other transportation * 520 75,391 Communication * 160,187 * 322,130 Electric, gas, and sanitary services 3,644 174,338 Wholesale and retail trade 25,781 1,121,443 Wholesale trade 18,606 510,669 Groceries and related products -- * 4,965 Machinery, equipment, and supplies 2,202 4,744 Miscellaneous wholesale trade 16,404 500,960 Drugs, chemicals, and allied products * 249 * 16,312 Petroleum and petroleum products * 1 * 53,744 Other miscellaneous wholesale trade 16,154 430,905 Retail trade 7,175 610,774 Building materials, garden supplies, and mobile home dealers -- -- General merchandise stores * 2,082 * 7,300 Food stores -- -- Automotive dealers and service station * 9 -- Apparel and accessory stores * 2,496 * 113,315 Furniture and home furnishing stores -- * 2,494 Eating and drinking places * 1,673 * 462,507 All other retail stores * 914 * 25,159 Finance, insurance, and real estate 647,142 2,636,482 Banking 254,100 1,055,611 Credit agencies other than banks * 9,835 279,502 Security, commodity brokers, and services 215,987 320,652 Insurance 151,149 444,353 Insurance agents, brokers, and service * 366 * 44,255 Real estate * 260 9,180 Holding and other investment companies, except bank holding companies 15,446 482,929 Services 134,739 1,328,700 Hotels and other lodging places * 11,968 * 144,531 Personal services -- * 13,274 Business services 108,072 1,038,858 Auto repair; miscellaneous repair services * 4 * 1,060 Amusement and recreation services * 4,010 79,132 All other services 10,684 51,845 * Data should be used with caution because of the small number of returns on which they were based. (1) Interest-Charge Domestic International Sales Corporation (IC-DISC) and Domestic International Sales Corporation (DISC). (2) In addition to the credits shown in columns 12-14, this is after reduction by other credits, such as the jobs credit and the investment credit, which are not shown separately in this table. (3) Included in gross income (less loss), columns 16-22. See notes below. (4) Included in deductions, columns 26-35. See notes below. (5) Less than $500. NOTES: Columns 2 through 15 present statistics on assets, receipts, income, and taxes reported on Form 1120 (Corporation Income Tax Return) series for corporations claiming a foreign tax credit. Columns 16 through 52 present statistics from Form 1118, Foreign Tax Credit-Corporations. Schedule references indicate the schedule of Form 1118 from which the date were obtained. Columns 16 through 36 present statistics on foreign income (i.e., income from sources outside the United States) and deductions reported primarily on Schedule A, Form 1118. Although the amounts of oil and gas income and deductions (columns 23 and 36, respectively) are contained in the summary columns (i.e., columns 18 through 22 and 28 through 35), these amounts are also reported separately (on Schedule I) because oil and gas income is subject to special rules under Internal Revenue Code section 907, which may result in a reduction of foreign taxes available for credit. Code section 863(b) income (income partly within and partly without the United States) and foreign branch income are also included in the summary amounts reported in columns 16 through 22 and are also reported separately (on Schedule F) in columns 24 and 25. Total deductions not allocable to specific types of income (column 32) are equal to the sum of columns 33 through 35 (any differences are due to taxpayer reporting practices). Total foreign-source gross income (column 16) less total foreign deductions (column 26) is equal to foreign-source taxable income before adjustments (column 37). Adjustments to foreign-source taxable income (reported in column 38) include allocations of current-year U.S.-source losses and recapture of foreign losses, as well as other adjustments. These adjustments (reported on Schedule J) affect the numerator of the limitation fraction used to compute the foreign tax credit. The foreign-source taxable income alter adjustments (the numerator of the limitation fraction) is reported in column 39. The limitation fraction, which represents the ratio of foreign-source taxable income alter adjustments to total (U.S. and foreign) taxable income after adjustments, is applied to the total U.S. tax against which the credit is allowed to determine any limitation on the foreign tax credit. Statistics on foreign taxes are reported in columns 40 through 52. Date on foreign taxes paid, accrued, and deemed paid (through related foreign corporations or their subsidiaries) from Schedule B, Form 1118, are reported in columns 43 through 52. Total foreign taxes paid or accrued (column 44) are the sum of columns 45 through 51 (any differences are due to taxpayer reporting practices). Total foreign taxes paid, accrued, and deemed paid (column 43) are equal to the sum of total taxes paid or accrued (column 44) and taxes deemed paid (column 52). Total foreign taxes paid, accrued, and deemed paid are then adjusted for certain items (e.g., reductions of foreign taxes under Code section 907 related to oil and gas income), which are reported in column 41, as well as carryovers of foreign taxes not credited in prior years, which are reported in column 42. Thus, total foreign texas available for credit (column 40) are equal to total foreign taxes paid, accrued, and deemed paid (column 43) less certain foreign texas (column 41), plus any carryover of prior-year foreign texas (column 42). Table 2.--U.S. Corporation Returns with a Foreign Tax Credit: Foreign Income and Tax Reported on Form 1118, by Industrial Division and Income Type [All figures are estimates based on samples--money amounts are in thousands of dollars] Foreign income and taxes reported on Form 1118 Gross income (less loss) Number Industrial division and income type of re- Total turns (1) (2) ALL INDUSTRIES All income types 6,569 359,898,600 Passive income 2,471 7,771,190 High withholding tax interest 375 1,956,124 Financial services income 429 105,293,627 Shipping income 58 12,178,158 Dividends from noncontrolled section 902 corp 676 4,303,132 Dividends from an IC-DISC or former DISC (1) 5 * 1,029 Miscellaneous separately calculated limitation 28 595,700 Certain distributions from a FSC or former FSC (2) 84 3,268,813 General limitation income 3,974 224,530,827 AGRICULTURE, FORESTRY, AND FISHING All income types 134 238,033 Passive income 76 * 7,705 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp 53 * 3,346 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 11 213,244 MINING All income types 133 8,292,326 Passive income 34 76,275 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp 6 * 20,693 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 117 8,151,080 CONSTRUCTION All income types 183 449,484 Passive income 40 14,025 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp 29 * 10,789 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 123 381,977 MANUFACTURING All income types 1,763 188,632,881 Passive income 636 6,135,387 High withholding tax interest 88 198,554 Financial services income 74 6,383,961 Shipping income 27 592,555 Dividends from noncontrolled section 902 corp 235 1,705,839 Dividends from an IC-DISC or former DISC (1) 5 * 1,029 Miscellaneous separately calculated limitation 20 73,114 Certain distributions from a FSC or former FSC (2) 59 2,911,583 General limitation income 1,459 170,630,859 TRANSPORTATION AND PUBLIC UTILITIES All income types 159 22,221,685 Passive income 73 175,218 High withholding tax interest 15 18,281 Financial services income ** ** Shipping income 20 11,489,126 Dividends from noncontrolled section 902 corp 18 826,456 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 109 9,202,669 WHOLESALE AND RETAIL TRADE All income types 1,193 13,921,240 Passive income 598 491,426 High withholding tax interest 61 122,391 Financial services income 91 * 2,187,197 Shipping income ** ** Dividends from noncontrolled section 902 corp 49 51,991 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 507 11,010,755 FINANCE, INSURANCE, AND REAL ESTATE All income types 1,676 102,621,003 Passive income 833 593,561 High withholding tax interest 128 1,544,689 Financial services income 197 96,455,210 Shipping income ** ** Dividends from noncontrolled section 902 corp 170 894,591 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) 9 * 122,936 General limitation income 567 2,998,106 SERVICES All income types 1,329 23,521,948 Passive income 182 277,594 High withholding tax interest 74 28,666 Financial services income 57 209,953 Shipping income 5 * 82,051 Dividends from noncontrolled section 902 corp 117 789,428 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation 3 * 17,699 Certain distributions from a FSC or former FSC (2) 11 * 174,421 General limitation income 1,082 21,942,137 Foreign income and taxes reported on Form 1118 Gross income (less loss) Foreign dividend income resulting from Industrial division and income type Dividends foreign taxes deemed paid (gross-up) (3) (4) ALL INDUSTRIES All income types 68,480,746 29,020,456 Passive income 4,066,867 544,062 High withholding tax interest 54,709 30,281 Financial services income 9,486,835 2,947,844 Shipping income 325,879 58,023 Dividends from noncontrolled section 902 corp 2,780,784 1,286,523 Dividends from an IC-DISC or former DISC (1) * 1,029 -- Miscellaneous separately calculated limitation 81,800 * 18,114 Certain distributions from a FSC or former FSC (2) 3,268,712 * 102 General limitation income 48,414,131 24,135,507 AGRICULTURE, FORESTRY, AND FISHING All income types 54,572 * 21,774 Passive income * 2,043 * 465 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 3,082 * 263 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 35,709 * 21,047 MINING All income types 769,336 279,548 Passive income 19,906 * 765 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 19,700 * 993 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 726,680 275,973 CONSTRUCTION All income types 85,149 * 16,088 Passive income 4,974 * 221 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 6,854 * 3,595 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 30,765 * 12,272 MANUFACTURING All income types 52,156,799 23,031,191 Passive income 3,468,764 465,443 High withholding tax interest * 1,904 * 569 Financial services income 1,561,353 966,332 Shipping income 135,806 * 8,174 Dividends from noncontrolled section 902 corp 1,094,929 490,053 Dividends from an IC-DISC or former DISC (1) * 1,029 -- Miscellaneous separately calculated limitation * 41,573 * 5,715 Certain distributions from a FSC or former FSC (2) 2,911,481 * 102 General limitation income 42,939,961 21,094,803 TRANSPORTATION AND PUBLIC UTILITIES All income types 1,606,457 585,276 Passive income 92,212 7,115 High withholding tax interest -- -- Financial services income ** ** Shipping income 178,167 * 49,627 Dividends from noncontrolled section 902 corp 549,236 266,052 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 781,178 262,482 WHOLESALE AND RETAIL TRADE All income types 1,997,340 1,121,448 Passive income 128,725 15,911 High withholding tax interest * 8,926 * 3,421 Financial services income * 133,190 * 55,235 Shipping income ** ** Dividends from noncontrolled section 902 corp 39,423 12,554 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 1,642,248 1,021,838 FINANCE, INSURANCE, AND REAL ESTATE All income types 9,539,627 2,636,478 Passive income 306,763 48,071 High withholding tax interest 41,008 * 24,474 Financial services income 7,770,290 1,921,146 Shipping income ** ** Dividends from noncontrolled section 902 corp 561,250 243,327 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 122,936 -- General limitation income 729,418 399,329 SERVICES All income types 2,271,466 1,328,651 Passive income 43,482 6,071 High withholding tax interest * 692 -- Financial services income * 16,403 * 5,130 Shipping income * 1,621 -- Dividends from noncontrolled section 902 corp 506,310 269,686 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 365 * (3) Certain distributions from a FSC or former FSC (2) * 174,421 -- General limitation income 1,528,172 1,047,764 Foreign income and taxes reported on Form 1118 Gross income (less loss) Rents, royalties, Industrial division and income type Interest and license fees (5) (6) ALL INDUSTRIES All income types 61,505,751 48,610,292 Passive income 2,374,840 365,338 High withholding tax interest 1,870,093 -- Financial services income 50,393,059 2,637,891 Shipping income 55,040 505,464 Dividends from noncontrolled section 902 corp 23,101 6,440 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 25,023 * 32 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 6,764,595 45,095,127 AGRICULTURE, FORESTRY, AND FISHING All income types * 19,744 * 14,007 Passive income * 5,241 -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 14,503 * 14,007 MINING All income types 221,170 310,547 Passive income 27,737 * 9,311 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 154,024 301,236 CONSTRUCTION All income types * 9,344 23,555 Passive income * 7,538 * 1,248 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 1,669 * 22,307 MANUFACTURING All income types 8,366,129 33,953,415 Passive income 1,821,678 220,793 High withholding tax interest 196,082 -- Financial services income 963,743 * 733,193 Shipping income * 29,934 * 323,831 Dividends from noncontrolled section 902 corp 5,127 6,419 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 24,904 * 32 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 5,324,661 32,669,147 TRANSPORTATION AND PUBLIC UTILITIES All income types 320,490 426,902 Passive income 58,319 * 12,004 High withholding tax interest 18,281 -- Financial services income ** ** Shipping income * 17,095 * 124,433 Dividends from noncontrolled section 902 corp * 5,755 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 221,041 251,149 WHOLESALE AND RETAIL TRADE All income types 2,054,128 1,450,456 Passive income 133,748 97,553 High withholding tax interest 110,043 -- Financial services income * 1,515,395 * 10,084 Shipping income ** ** Dividends from noncontrolled section 902 corp * 3 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 294,818 1,342,818 FINANCE, INSURANCE, AND REAL ESTATE All income types 49,935,328 1,923,139 Passive income 191,537 * 1,642 High withholding tax interest 1,478,166 -- Financial services income 47,850,987 1,838,877 Shipping income ** ** Dividends from noncontrolled section 902 corp * 1,265 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 408,229 82,620 SERVICES All income types 579,418 10,508,272 Passive income 129,041 22,788 High withholding tax interest 27,974 -- Financial services income * 62,934 * 16,420 Shipping income * 2,807 * 57,200 Dividends from noncontrolled section 902 corp * 10,950 * 21 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 60 -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 345,652 10,411,842 Foreign income and taxes reported on Form 1118 Gross income (less loss) Service Other Industrial division and income type income income (7) (8) ALL INDUSTRIES All income types 31,387,624 120,893,731 Passive income 18,093 401,990 High withholding tax interest -- * 1,041 Financial services income 9,779,560 30,048,438 Shipping income 6,933,462 4,300,288 Dividends from noncontrolled section 902 corp * 235 206,051 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- * 470,731 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 14,656,274 85,465,192 AGRICULTURE, FORESTRY, AND FISHING All income types -- 127,936 Passive income -- * -44 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 2 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- * 127,978 MINING All income types 3,073,644 3,638,080 Passive income * 6,732 * 11,824 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 3,066,912 3,626,256 CONSTRUCTION All income types 195,865 119,483 Passive income -- * 45 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 339 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 195,865 119,099 MANUFACTURING All income types 3,733,558 67,391,789 Passive income * 1,097 157,612 High withholding tax interest -- -- Financial services income * 3,578 2,155,762 Shipping income * 9,895 84,915 Dividends from noncontrolled section 902 corp * 36 109,274 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- * 891 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 3,718,953 64,883,334 TRANSPORTATION AND PUBLIC UTILITIES All income types 9,220,380 10,062,180 Passive income * 1,424 * 4,143 High withholding tax interest -- -- Financial services income ** ** Shipping income 6,923,568 * 4,196,236 Dividends from noncontrolled section 902 corp -- * 5,414 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 2,282,998 5,403,820 WHOLESALE AND RETAIL TRADE All income types 414,872 6,882,996 Passive income * 87 115,403 High withholding tax interest -- -- Financial services income -- * 473,292 Shipping income ** ** Dividends from noncontrolled section 902 corp -- * 10 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 414,786 6,294,248 FINANCE, INSURANCE, AND REAL ESTATE All income types 9,976,238 28,610,193 Passive income * 4,507 41,042 High withholding tax interest -- * 1,041 Financial services income 9,762,719 27,311,191 Shipping income ** ** Dividends from noncontrolled section 902 corp * 199 88,550 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 208,814 1,169,698 SERVICES All income types 4,773,067 4,061,074 Passive income * 4,246 71,965 High withholding tax interest -- -- Financial services income * 874 * 108,192 Shipping income -- * 20,423 Dividends from noncontrolled section 902 corp -- * 2,461 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- * 17,274 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 4,767,947 3,840,759 Foreign income and taxes reported on Form 1118 Gross income (less loss) Oil and gas extraction Foreign Industrial division and income type income branch (less income (4) loss) (4) (9) (10) ALL INDUSTRIES All income types 21,013,968 88,607,770 Passive income -- 187,088 High withholding tax interest -- * 359,043 Financial services income -- 46,970,762 Shipping income -- * 3,638,420 Dividends from noncontrolled section 902 corp -- * 2,471 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 21,013,968 37,449,987 AGRICULTURE, FORESTRY, AND FISHING All income types -- * 673 Passive income -- -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- * 673 MINING All income types 2,037,440 3,126,813 Passive income -- * 2,022 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,037,440 3,124,791 CONSTRUCTION All income types -- * 83,784 Passive income -- -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- * 83,784 MANUFACTURING All income types 18,743,589 27,638,925 Passive income -- 182,711 High withholding tax interest -- * 410 Financial services income -- * 505,418 Shipping income -- * 34,629 Dividends from noncontrolled section 902 corp -- * 1,219 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 18,743,589 26,914,538 TRANSPORTATION AND PUBLIC UTILITIES All income types * 41,616 4,476,116 Passive income -- * 9 High withholding tax interest -- * 21 Financial services income ** ** Shipping income -- * 3,603,791 Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 41,616 869,527 WHOLESALE AND RETAIL TRADE All income types * 21,791 2,983,585 Passive income -- * 626 High withholding tax interest -- * 10 Financial services income -- * 274,325 Shipping income ** ** Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 21,791 2,708,624 FINANCE, INSURANCE, AND REAL ESTATE All income types 169,532 46,773,056 Passive income -- * 26 High withholding tax interest -- * 358,309 Financial services income -- 46,188,249 Shipping income ** ** Dividends from noncontrolled section 902 corp -- * 1,252 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 169,532 225,221 SERVICES All income types -- 3,524,818 Passive income -- * 1,695 High withholding tax interest -- * 293 Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income -- 3,522,830 Foreign income and taxes reported on Form 1118 Gross income Deductions (less loss) Speci- fically allocable Industrial division and income type income Total [section 863(b)] (4) (11) (12) ALL INDUSTRIES All income types 24,971,121 201,909,309 Passive income 16,983 2,255,063 High withholding tax interest * 135,978 906,179 Financial services income 2,825,988 72,903,477 Shipping income * 2,104,614 10,414,571 Dividends from noncontrolled section 902 corp * 9,576 770,800 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- 44,960 Certain distributions from a FSC or former FSC (2) -- 3,160,787 General limitation income 19,877,982 111,453,471 AGRICULTURE, FORESTRY, AND FISHING All income types * 92,236 * 98,061 Passive income -- * 3,598 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 1,086 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 92,236 * 79,640 MINING All income types * 378,536 5,133,029 Passive income * 10,937 24,236 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 7,305 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 366,463 5,098,389 CONSTRUCTION All income types * 40,924 294,026 Passive income -- * 1,880 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 461 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 40,924 249,103 MANUFACTURING All income types 17,567,896 85,811,444 Passive income * 3,178 1,752,167 High withholding tax interest -- 45,303 Financial services income -- 3,423,787 Shipping income -- 504,692 Dividends from noncontrolled section 902 corp * 458 470,660 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- 15,565 Certain distributions from a FSC or former FSC (2) -- 2,853,457 General limitation income 17,564,260 76,745,814 TRANSPORTATION AND PUBLIC UTILITIES All income types 2,615,529 16,849,056 Passive income * 18 61,163 High withholding tax interest -- 9,747 Financial services income ** ** Shipping income 2,104,614 9,794,483 Dividends from noncontrolled section 902 corp -- 94,928 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 506,995 6,806,748 WHOLESALE AND RETAIL TRADE All income types 196,739 8,143,471 Passive income * 13 231,366 High withholding tax interest * 2,218 29,872 Financial services income -- 1,371,162 Shipping income ** ** Dividends from noncontrolled section 902 corp -- 17,249 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 194,508 6,486,254 FINANCE, INSURANCE, AND REAL ESTATE All income types 3,040,235 70,715,971 Passive income * 2,582 71,728 High withholding tax interest * 132,624 808,082 Financial services income 2,822,086 67,898,438 Shipping income ** ** Dividends from noncontrolled section 902 corp * 9,049 151,092 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- * 72,776 General limitation income * 73,893 1,707,619 SERVICES All income types 1,039,026 14,864,252 Passive income * 254 108,925 High withholding tax interest -- 12,453 Financial services income -- 154,633 Shipping income -- * 105,580 Dividends from noncontrolled section 902 corp * 69 28,020 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- * 55 Certain distributions from a FSC or former FSC (2) -- * 174,681 General limitation income 1,038,703 14,279,905 Foreign income and taxes reported on Form 1118 Deductions Deductions allocable to specific types of income Rental, royalty, and licensing expenses Depre- ciation, deple- Industrial division and income type Total tion, and amorti- zation (13) (14) ALL INDUSTRIES All income types 107,480,799 1,257,812 Passive income 759,775 5,752 High withholding tax interest 82,995 * 4 Financial services income 25,566,714 561,435 Shipping income 9,707,115 * 155,955 Dividends from noncontrolled section 902 corp 88,682 * 620 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 28,723 -- Certain distributions from a FSC or former FSC (2) 3,149,741 * 7,367 General limitation income 68,097,054 526,679 AGRICULTURE, FORESTRY, AND FISHING All income types * 59,042 -- Passive income -- -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 45,304 -- MINING All income types 4,199,314 117,568 Passive income 13,830 * 3,344 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 4,185,255 114,224 CONSTRUCTION All income types 228,015 * 349 Passive income * 184 * 141 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 105 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 185,171 * 208 MANUFACTURING All income types 48,178,233 298,396 Passive income 629,523 * 1,049 High withholding tax interest 12,029 -- Financial services income 1,946,883 * 4,486 Shipping income 403,850 * 84,878 Dividends from noncontrolled section 902 corp 30,263 * 620 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 4,728 -- Certain distributions from a FSC or former FSC (2) 2,853,381 -- General limitation income 42,297,578 207,362 TRANSPORTATION AND PUBLIC UTILITIES All income types 14,832,180 33,657 Passive income 24,919 -- High withholding tax interest * 373 -- Financial services income ** ** Shipping income 9,203,762 * 8,817 Dividends from noncontrolled section 902 corp * 26,312 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 5,500,531 4,801 WHOLESALE AND RETAIL TRADE All income types 5,880,777 8,652 Passive income 45,419 * 63 High withholding tax interest * 9,078 -- Financial services income * 564,538 -- Shipping income ** ** Dividends from noncontrolled section 902 corp * 218 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 5,258,794 8,589 FINANCE, INSURANCE, AND REAL ESTATE All income types 24,358,750 551,075 Passive income 32,950 * 150 High withholding tax interest 61,108 * 4 Financial services income 22,968,615 536,909 Shipping income ** ** Dividends from noncontrolled section 902 corp 25,985 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 62,066 * 7,367 General limitation income 1,199,792 6,644 SERVICES All income types 9,744,488 248,114 Passive income 12,951 * 1,005 High withholding tax interest * 392 -- Financial services income * 35,083 -- Shipping income * 91,182 * 62,259 Dividends from noncontrolled section 902 corp * 5,800 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 31 -- Certain distributions from a FSC or former FSC (2) * 174,421 -- General limitation income 9,424,628 184,850 Foreign income and taxes reported on Form 1118 Deductions Deductions allocable to specific types of income Rental, royalty, and licensing expenses Service Industrial division and income type Other expenses (15) (16) ALL INDUSTRIES All income types 7,358,799 13,663,474 Passive income 55,715 10,830 High withholding tax interest * 5,840 * 609 Financial services income 1,826,735 740,505 Shipping income * 35,384 * 3,816,460 Dividends from noncontrolled section 902 corp * 7,155 * 11,855 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 5,427,970 9,083,216 AGRICULTURE, FORESTRY, AND FISHING All income types * 521 -- Passive income -- -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 521 -- MINING All income types 66,502 1,266,808 Passive income * 1,151 -- High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 65,352 1,266,794 CONSTRUCTION All income types * 1,281 131,860 Passive income -- -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 1,281 131,860 MANUFACTURING All income types 3,113,488 2,125,735 Passive income 15,640 * 7,374 High withholding tax interest -- -- Financial services income * 303,956 -- Shipping income * 35,300 * 9,389 Dividends from noncontrolled section 902 corp * 1,779 * 1,138 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,756,813 2,107,835 TRANSPORTATION AND PUBLIC UTILITIES All income types * 60,222 5,797,057 Passive income (3) * 238 High withholding tax interest -- -- Financial services income ** ** Shipping income * 84 * 3,807,071 Dividends from noncontrolled section 902 corp -- * 743 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 60,138 1,976,082 WHOLESALE AND RETAIL TRADE All income types 315,244 159,090 Passive income * 24,465 * 82 High withholding tax interest * 40 -- Financial services income -- -- Shipping income ** ** Dividends from noncontrolled section 902 corp (3) -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 290,738 159,008 FINANCE, INSURANCE, AND REAL ESTATE All income types 1,551,966 1,008,729 Passive income 11,279 * 281 High withholding tax interest * 5,800 * 203 Financial services income 1,495,140 726,886 Shipping income ** ** Dividends from noncontrolled section 902 corp * -5 * 9,974 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 39,752 271,385 SERVICES All income types 2,249,574 3,174,195 Passive income * 3,180 * 2,856 High withholding tax interest -- * 392 Financial services income * 27,640 * 696 Shipping income -- -- Dividends from noncontrolled section 902 corp * 5,381 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,213,374 3,170,251 Foreign income and taxes reported on Form 1118 Deductions Deductions not allo- cable to specific types of income Other deductions allocable Industrial division and income type to specific Total types of income (17) (18) ALL INDUSTRIES All income types 85,200,714 94,428,510 Passive income 687,478 1,495,288 High withholding tax interest 76,541 823,185 Financial services income 22,438,039 47,336,763 Shipping income 5,699,316 707,456 Dividends from noncontrolled section 902 corp 69,053 682,118 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 28,723 16,236 Certain distributions from a FSC or former FSC (2) 3,142,374 * 11,046 General limitation income 53,059,189 43,356,417 AGRICULTURE, FORESTRY, AND FISHING All income types * 58,521 * 39,019 Passive income -- * 3,598 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 1,086 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 44,783 * 34,336 MINING All income types 2,748,435 933,715 Passive income * 9,335 10,407 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 7,305 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,738,886 913,134 CONSTRUCTION All income types 94,524 66,011 Passive income * 43 * 1,696 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 105 * 356 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 51,822 63,931 MANUFACTURING All income types 42,640,613 37,633,211 Passive income 605,460 1,122,644 High withholding tax interest 12,029 33,274 Financial services income 1,638,440 1,476,905 Shipping income 274,284 100,841 Dividends from noncontrolled section 902 corp 26,726 440,397 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 4,728 * 10,838 Certain distributions from a FSC or former FSC (2) 2,853,381 * 76 General limitation income 37,225,567 34,448,236 TRANSPORTATION AND PUBLIC UTILITIES All income types 8,941,243 2,016,875 Passive income 24,682 36,244 High withholding tax interest * 373 * 9,374 Financial services income ** ** Shipping income * 5,387,789 590,721 Dividends from noncontrolled section 902 corp * 25,569 68,616 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 3,459,510 1,306,217 WHOLESALE AND RETAIL TRADE All income types 5,397,790 2,262,694 Passive income 20,809 185,947 High withholding tax interest * 9,038 20,794 Financial services income * 564,538 * 806,624 Shipping income ** ** Dividends from noncontrolled section 902 corp * 218 17,031 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 4,800,458 1,227,460 FINANCE, INSURANCE, AND REAL ESTATE All income types 21,246,980 46,357,221 Passive income 21,240 38,778 High withholding tax interest 55,101 744,974 Financial services income 20,209,680 44,929,823 Shipping income ** ** Dividends from noncontrolled section 902 corp 16,016 125,107 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 54,699 * 10,710 General limitation income 882,011 507,826 SERVICES All income types 4,072,605 5,119,764 Passive income 5,910 95,974 High withholding tax interest (3) 12,061 Financial services income * 6,747 * 119,550 Shipping income * 28,923 * 14,397 Dividends from noncontrolled section 902 corp * 419 22,220 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 31 * 25 Certain distributions from a FSC or former FSC (2) * 174,421 * 260 General limitation income 3,856,154 4,855,276 Foreign income and taxes reported on Form 1118 Deductions Deductions not allocable to specific types of income Research and Industrial division and income type deve- Interest lopment (19) (20) ALL INDUSTRIES All income types 9,565,637 43,342,264 Passive income 121,376 922,728 High withholding tax interest 3,021 615,070 Financial services income 129,790 28,784,352 Shipping income * 13,478 212,589 Dividends from noncontrolled section 902 corp 21,132 551,970 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 1,156 * 4,275 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 9,275,684 12,251,279 AGRICULTURE, FORESTRY, AND FISHING All income types * 20,993 * 8,934 Passive income * 166 * 3,252 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 299 * 725 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 20,529 * 4,956 MINING All income types * 38,287 302,159 Passive income * 68 4,207 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 5,485 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 38,219 291,044 CONSTRUCTION All income types * 1,015 * 9,348 Passive income -- * 560 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 324 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 1,015 * 8,443 MANUFACTURING All income types 7,834,168 12,397,235 Passive income 118,708 696,692 High withholding tax interest 538 26,925 Financial services income 25,185 1,358,997 Shipping income * 4,896 85,240 Dividends from noncontrolled section 902 corp 19,593 361,015 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 294 * 1,403 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 7,664,954 9,866,963 TRANSPORTATION AND PUBLIC UTILITIES All income types * 57,203 1,002,896 Passive income * 559 34,271 High withholding tax interest -- * 4,378 Financial services income ** ** Shipping income * 8,582 114,097 Dividends from noncontrolled section 902 corp * 4 65,781 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 47,714 779,768 WHOLESALE AND RETAIL TRADE All income types 24,693 1,459,232 Passive income * 531 88,500 High withholding tax interest * 732 16,057 Financial services income -- * 804,470 Shipping income ** ** Dividends from noncontrolled section 902 corp * 12 13,016 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 22,814 534,673 FINANCE, INSURANCE, AND REAL ESTATE All income types * 106,260 27,300,990 Passive income -- 14,379 High withholding tax interest * 1,751 554,583 Financial services income * 104,493 26,556,947 Shipping income ** ** Dividends from noncontrolled section 902 corp (3) 90,675 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 16 84,403 SERVICES All income types 1,483,018 861,470 Passive income * 1,344 80,867 High withholding tax interest -- * 11,735 Financial services income * 28 * 60,716 Shipping income -- * 12,177 Dividends from noncontrolled section 902 corp * 1,224 14,949 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 1,480,423 681,027 Foreign income and taxes reported on Form 1118 Deductions Deductions not allo- cable to specific types of income Deduc- tions from oil and gas Industrial division and income type Other extrac- tion income (5) (21) (22) ALL INDUSTRIES All income types 40,176,836 8,915,360 Passive income 396,393 -- High withholding tax interest 202,520 -- Financial services income 17,944,631 -- Shipping income 478,765 -- Dividends from noncontrolled section 902 corp 101,067 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 2,086 -- Certain distributions from a FSC or former FSC (2) * 11,046 -- General limitation income 21,040,328 8,915,360 AGRICULTURE, FORESTRY, AND FISHING All income types * 9,093 -- Passive income * 180 -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 62 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 8,851 -- MINING All income types 589,613 1,032,644 Passive income * 5,583 -- High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 1,819 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 580,764 1,032,644 CONSTRUCTION All income types * 34,612 -- Passive income * 1,118 -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 32 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 33,455 -- MANUFACTURING All income types 16,818,994 7,836,010 Passive income 301,145 -- High withholding tax interest 4,354 -- Financial services income 90,770 -- Shipping income 10,705 -- Dividends from noncontrolled section 902 corp 55,248 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 422 -- Certain distributions from a FSC or former FSC (2) * 76 -- General limitation income 16,356,274 7,836,010 TRANSPORTATION AND PUBLIC UTILITIES All income types 951,350 35,759 Passive income 1,413 -- High withholding tax interest * 4,996 -- Financial services income ** ** Shipping income * 465,418 -- Dividends from noncontrolled section 902 corp * 2,831 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 475,933 * 35,759 WHOLESALE AND RETAIL TRADE All income types 719,208 * 10,947 Passive income 69,533 -- High withholding tax interest * 3,569 -- Financial services income * 2,154 -- Shipping income ** ** Dividends from noncontrolled section 902 corp 3,844 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 638,390 * 10,947 FINANCE, INSURANCE, AND REAL ESTATE All income types 18,442,444 -- Passive income 8,062 -- High withholding tax interest 188,072 -- Financial services income 17,792,598 -- Shipping income ** ** Dividends from noncontrolled section 902 corp 32,015 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 10,710 -- General limitation income 410,986 -- SERVICES All income types 2,611,521 -- Passive income 9,359 -- High withholding tax interest * 214 -- Financial services income * 58,554 -- Shipping income * 2,220 -- Dividends from noncontrolled section 902 corp 5,215 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 25 -- Certain distributions from a FSC or former FSC (2) * 260 -- General limitation income 2,535,674 -- Foreign income and taxes reported on Form 1118 Taxable Adjust- income ments Industrial division and income type (less loss) to before taxable adjustments income (23) (24) ALL INDUSTRIES All income types 157,989,290 7,715,086 Passive income 5,516,127 272,876 High withholding tax interest 1,049,945 106,148 Financial services income 32,390,150 928,988 Shipping income 1,763,587 732,350 Dividends from noncontrolled section 902 corp 3,532,332 -138,004 Dividends from an IC-DISC or former DISC (1) * 1,029 * -41 Miscellaneous separately calculated limitation 550,740 41,888 Certain distributions from a FSC or former FSC (2) 108,026 15,365 General limitation income 113,077,355 5,755,516 AGRICULTURE, FORESTRY, AND FISHING All income types 139,972 * 4,133 Passive income * 4,107 * 1,129 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 2,260 * 252 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 133,604 * 2,752 MINING All income types 3,159,297 288,600 Passive income 52,039 * 388 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 13,388 * -148 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 3,052,691 288,290 CONSTRUCTION All income types 155,458 * 6,287 Passive income 12,145 -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 10,328 * -200 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 132,874 * 6,487 MANUFACTURING All income types 102,821,437 4,235,398 Passive income 4,383,220 244,344 High withholding tax interest 153,252 1,098 Financial services income 2,960,174 -172,838 Shipping income 87,863 -7,733 Dividends from noncontrolled section 902 corp 1,235,180 -164,380 Dividends from an IC-DISC or former DISC (1) * 1,029 * -41 Miscellaneous separately calculated limitation 57,549 -8,608 Certain distributions from a FSC or former FSC (2) * 58,127 15,634 General limitation income 93,885,045 4,327,921 TRANSPORTATION AND PUBLIC UTILITIES All income types 5,372,629 941,262 Passive income 114,055 -7,552 High withholding tax interest 8,534 * -1,120 Financial services income ** ** Shipping income 1,694,643 772,737 Dividends from noncontrolled section 902 corp 731,528 29,567 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 2,395,920 116,018 WHOLESALE AND RETAIL TRADE All income types 5,777,769 910,079 Passive income 260,060 12,105 High withholding tax interest 92,519 * 58,974 Financial services income * 816,035 * 455,180 Shipping income ** ** Dividends from noncontrolled section 902 corp 34,741 -1,142 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 4,524,501 381,000 FINANCE, INSURANCE, AND REAL ESTATE All income types 31,905,032 717,773 Passive income 521,833 7,506 High withholding tax interest 738,607 46,998 Financial services income 28,556,772 660,579 Shipping income ** ** Dividends from noncontrolled section 902 corp 743,499 -17,085 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 50,160 * 115 General limitation income 1,290,488 29,219 SERVICES All income types 8,657,696 611,554 Passive income 168,669 14,055 High withholding tax interest 16,213 * 127 Financial services income 55,320 * 1,297 Shipping income * -23,529 * -23,529 Dividends from noncontrolled section 902 corp 761,408 15,132 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 17,643 * 2 Certain distributions from a FSC or former FSC (2) * -260 * -260 General limitation income 7,662,232 603,829 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Taxable income Industrial division and income type (less loss) Total after adjustments (25) (26) ALL INDUSTRIES All income types 150,274,204 49,979,466 Passive income 5,243,251 791,754 High withholding tax interest 943,797 353,841 Financial services income 31,461,161 7,607,076 Shipping income 1,031,236 134,447 Dividends from noncontrolled section 902 corp 3,670,337 1,896,351 Dividends from an IC-DISC or former DISC (1) * 1,070 -- Miscellaneous separately calculated limitation 508,852 157,924 Certain distributions from a FSC or former FSC (2) 92,661 * 112 General limitation income 107,321,839 39,037,960 AGRICULTURE, FORESTRY, AND FISHING All income types 135,839 38,313 Passive income * 2,979 * 542 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 2,008 * 1,758 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 130,852 36,013 MINING All income types 2,870,696 1,416,118 Passive income 51,650 * 4,655 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 13,536 * 3,826 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,764,401 1,400,421 CONSTRUCTION All income types 149,171 63,431 Passive income 12,145 835 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 10,528 3,875 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 126,387 58,701 MANUFACTURING All income types 98,586,039 35,792,177 Passive income 4,138,876 652,673 High withholding tax interest 152,154 35,805 Financial services income 3,133,012 1,326,286 Shipping income 95,595 23,223 Dividends from noncontrolled section 902 corp 1,399,560 950,359 Dividends from an IC-DISC or former DISC (1) * 1,070 -- Miscellaneous separately calculated limitation 66,157 7,917 Certain distributions from a FSC or former FSC (2) 42,492 112 General limitation income 89,557,124 32,795,803 TRANSPORTATION AND PUBLIC UTILITIES All income types 4,431,367 969,683 Passive income 121,607 11,210 High withholding tax interest 9,654 1,776 Financial services income ** ** Shipping income 921,906 110,993 Dividends from noncontrolled section 902 corp 701,961 273,381 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 2,279,903 443,210 WHOLESALE AND RETAIL TRADE All income types 4,867,690 1,894,147 Passive income 247,955 37,293 High withholding tax interest 33,544 22,563 Financial services income * 360,855 * 118,903 Shipping income ** ** Dividends from noncontrolled section 902 corp 35,883 22,263 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 4,143,501 1,675,368 FINANCE, INSURANCE, AND REAL ESTATE All income types 31,187,259 7,370,111 Passive income 514,326 72,828 High withholding tax interest 691,609 282,259 Financial services income 27,896,193 6,147,237 Shipping income ** ** Dividends from noncontrolled section 902 corp 760,584 351,081 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) * 50,045 (3) General limitation income 1,261,269 516,566 SERVICES All income types 8,046,142 2,435,487 Passive income 153,713 11,719 High withholding tax interest 16,086 4,202 Financial services income 54,023 12,672 Shipping income -- * 1 Dividends from noncontrolled section 902 corp 746,276 289,808 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 17,641 * 5,206 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 7,058,403 2,111,878 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Reduction for Industrial division and income type certain Carryover foreign taxes (27) (28) ALL INDUSTRIES All income types 2,516,340 7,416,008 Passive income -- 38,315 High withholding tax interest -- 105,625 Financial services income -- 658,425 Shipping income -- 37,507 Dividends from noncontrolled section 902 corp -- 499,917 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation (3) * 3,730 Certain distributions from a FSC or former FSC (2) -- * 10 General limitation income 2,516,340 6,072,479 AGRICULTURE, FORESTRY, AND FISHING All income types -- * 3,837 Passive income -- * 36 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 1,421 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- * 2,379 MINING All income types 444,333 562,043 Passive income -- * 705 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 9 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 444,333 558,578 CONSTRUCTION All income types -- 15,329 Passive income -- 37 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- 41 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- 15,250 MANUFACTURING All income types 2,059,580 5,450,727 Passive income -- 29,460 High withholding tax interest -- 6,129 Financial services income -- 116,124 Shipping income -- 11,127 Dividends from noncontrolled section 902 corp -- 378,785 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- 535 Certain distributions from a FSC or former FSC (2) -- 10 General limitation income 2,059,580 4,908,557 TRANSPORTATION AND PUBLIC UTILITIES All income types 122 97,772 Passive income -- 607 High withholding tax interest -- 138 Financial services income ** ** Shipping income -- 26,380 Dividends from noncontrolled section 902 corp -- 1,902 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 122 68,436 WHOLESALE AND RETAIL TRADE All income types (3) 237,214 Passive income -- 1,851 High withholding tax interest -- * 427 Financial services income -- * 815 Shipping income ** ** Dividends from noncontrolled section 902 corp -- 7,746 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- 223,180 FINANCE, INSURANCE, AND REAL ESTATE All income types * 12,176 809,000 Passive income -- 4,278 High withholding tax interest -- 95,646 Financial services income -- 540,662 Shipping income ** ** Dividends from noncontrolled section 902 corp -- 91,770 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 12,176 76,645 SERVICES All income types * 129 240,087 Passive income -- * 1,341 High withholding tax interest -- * 535 Financial services income -- * 515 Shipping income -- * 1 Dividends from noncontrolled section 902 corp -- 18,241 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 129 219,454 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Industrial division and income type Total Total (29) (30) ALL INDUSTRIES All income types 45,079,798 16,056,942 Passive income 753,440 207,992 High withholding tax interest 248,216 217,934 Financial services income 6,948,651 4,000,803 Shipping income 96,940 38,917 Dividends from noncontrolled section 902 corp 1,396,434 109,911 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation 154,195 * 136,081 Certain distributions from a FSC or former FSC (2) * 102 (3) General limitation income 35,481,821 11,345,304 AGRICULTURE, FORESTRY, AND FISHING All income types 34,476 12,702 Passive income * 506 * 41 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 337 * 74 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 33,634 * 12,587 MINING All income types 1,298,408 1,018,859 Passive income 3,950 3,185 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 3,817 * 2,824 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 1,286,175 1,010,203 CONSTRUCTION All income types 48,103 32,014 Passive income 798 577 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp 3,834 238 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income 43,450 31,178 MANUFACTURING All income types 32,401,030 9,367,486 Passive income 623,213 156,394 High withholding tax interest 29,676 29,107 Financial services income 1,210,162 243,829 Shipping income 12,096 3,922 Dividends from noncontrolled section 902 corp 571,573 81,520 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation 7,382 1,667 Certain distributions from a FSC or former FSC (2) 102 -- General limitation income 29,946,825 8,851,045 TRANSPORTATION AND PUBLIC UTILITIES All income types 872,033 286,757 Passive income 10,603 3,488 High withholding tax interest 1,638 1,638 Financial services income ** ** Shipping income 84,613 34,986 Dividends from noncontrolled section 902 corp 271,479 5,427 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 374,897 112,415 WHOLESALE AND RETAIL TRADE All income types 1,656,933 535,490 Passive income 35,442 19,531 High withholding tax interest 22,136 18,715 Financial services income * 118,088 * 62,853 Shipping income ** ** Dividends from noncontrolled section 902 corp 14,517 1,963 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 1,452,189 430,356 FINANCE, INSURANCE, AND REAL ESTATE All income types 6,573,288 3,936,806 Passive income 68,550 20,480 High withholding tax interest 186,613 162,140 Financial services income 5,606,575 3,685,426 Shipping income ** ** Dividends from noncontrolled section 902 corp 259,310 15,983 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) (3) (3) General limitation income 452,098 52,769 SERVICES All income types 2,195,529 866,829 Passive income 10,378 4,297 High withholding tax interest 3,667 3,667 Financial services income * 12,157 * 7,027 Shipping income -- -- Dividends from noncontrolled section 902 corp 271,567 1,881 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 5,206 * 5,206 Certain distributions from a FSC or former FSC (2) -- -- General limitation income 1,892,553 844,750 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Taxes withheld at source on-- Taxes withheld Industrial division and income type at source Interest on dividends (31) (32) ALL INDUSTRIES All income types 2,767,327 640,883 Passive income 93,869 24,133 High withholding tax interest 2,516 215,266 Financial services income 324,094 279,275 Shipping income * 2,079 * 244 Dividends from noncontrolled section 902 corp 75,997 * 27 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation 2,252 -- Certain distributions from a FSC or former FSC (2) (3) -- General limitation income 2,266,519 121,939 AGRICULTURE, FORESTRY, AND FISHING All income types 2,521 * 484 Passive income * 39 * 2 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 74 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 2,408 * 482 MINING All income types 53,846 9,917 Passive income * 28 * 692 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp * 2,824 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 50,994 6,577 CONSTRUCTION All income types 1,490 * 490 Passive income 21 * 355 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 211 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 1,258 * 115 MANUFACTURING All income types 2,203,741 140,905 Passive income 78,191 18,226 High withholding tax interest * 134 28,973 Financial services income 27,931 * 1,705 Shipping income * 614 * 117 Dividends from noncontrolled section 902 corp 53,911 * 12 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 125 -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,042,834 91,873 TRANSPORTATION AND PUBLIC UTILITIES All income types 22,552 7,467 Passive income 479 * 477 High withholding tax interest -- 1,638 Financial services income ** ** Shipping income * 1,457 * 127 Dividends from noncontrolled section 902 corp * 5,413 * 14 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 14,278 5,212 WHOLESALE AND RETAIL TRADE All income types 90,146 31,323 Passive income 4,033 1,412 High withholding tax interest * 9 18,705 Financial services income * 18,381 * 3,837 Shipping income ** ** Dividends from noncontrolled section 902 corp 1,963 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 63,687 7,369 FINANCE, INSURANCE, AND REAL ESTATE All income types 319,619 435,813 Passive income 10,023 2,395 High withholding tax interest * 1,909 160,078 Financial services income 276,689 271,045 Shipping income ** ** Dividends from noncontrolled section 902 corp 9,723 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) (3) -- General limitation income 21,267 2,295 SERVICES All income types 73,412 14,485 Passive income 1,055 576 High withholding tax interest * 463 3,204 Financial services income * 168 * 2,688 Shipping income -- -- Dividends from noncontrolled section 902 corp 1,878 * 1 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 55 -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 69,793 8,016 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Taxes Other withheld taxes at paid or source accrued on-- on-- Rents, royal- ties, Branch Industrial division and income type and income license fees (33) (34) ALL INDUSTRIES All income types 2,238,232 6,063,443 Passive income 37,246 13,337 High withholding tax interest -- -- Financial services income 12,994 2,492,839 Shipping income * 2,291 * 14,239 Dividends from noncontrolled section 902 corp * 532 * 456 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 2,185,169 3,542,571 AGRICULTURE, FORESTRY, AND FISHING All income types * 3,076 * 1,724 Passive income -- -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 3,076 * 1,724 MINING All income types 12,595 286,739 Passive income * 1,036 * 78 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 11,559 286,661 CONSTRUCTION All income types 835 * 4,455 Passive income * 123 -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 712 * 4,455 MANUFACTURING All income types 1,580,966 2,945,132 Passive income 20,183 12,428 High withholding tax interest -- -- Financial services income * 3,067 * 22,011 Shipping income -- -- Dividends from noncontrolled section 902 corp * 530 * 456 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 1,557,185 2,910,237 TRANSPORTATION AND PUBLIC UTILITIES All income types 21,541 36,575 Passive income -- -- High withholding tax interest -- -- Financial services income ** ** Shipping income * 2,291 * 14,239 Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 19,251 21,723 WHOLESALE AND RETAIL TRADE All income types 123,960 254,711 Passive income 13,920 * 25 High withholding tax interest -- -- Financial services income -- * 40,631 Shipping income ** ** Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 110,041 214,055 FINANCE, INSURANCE, AND REAL ESTATE All income types 15,362 2,435,572 Passive income * 260 * 329 High withholding tax interest -- -- Financial services income 9,785 2,429,584 Shipping income ** ** Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 5,317 5,659 SERVICES All income types 479,897 98,535 Passive income 1,724 * 478 High withholding tax interest -- -- Financial services income * 142 -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 2 -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 478,028 98,057 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Other taxes paid or accrued on-- Speci- fically allo- Industrial division and income type cable Service income income [section 863(b)] (35) (36) ALL INDUSTRIES All income types 29,802 292,786 Passive income * 85 1,931 High withholding tax interest -- -- Financial services income * 40 75,259 Shipping income * 6,744 * 7,372 Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 22,933 208,224 AGRICULTURE, FORESTRY, AND FISHING All income types -- -- Passive income -- -- High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- -- MINING All income types -- * 12,908 Passive income -- -- High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income -- * 12,908 CONSTRUCTION All income types -- 22,826 Passive income -- -- High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- 22,826 MANUFACTURING All income types 15,116 83,972 Passive income * 85 * 24 High withholding tax interest -- -- Financial services income -- * 904 Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 15,031 83,045 TRANSPORTATION AND PUBLIC UTILITIES All income types * 6,887 22,252 Passive income -- * 1,765 High withholding tax interest -- -- Financial services income ** ** Shipping income * 6,744 * 7,372 Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 143 12,985 WHOLESALE AND RETAIL TRADE All income types -- 9,568 Passive income -- * 22 High withholding tax interest -- -- Financial services income -- -- Shipping income ** ** Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income -- 9,546 FINANCE, INSURANCE, AND REAL ESTATE All income types * 40 83,257 Passive income -- * 77 High withholding tax interest -- -- Financial services income * 40 74,168 Shipping income ** ** Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income -- 9,012 SERVICES All income types * 7,759 58,002 Passive income -- * 43 High withholding tax interest -- -- Financial services income -- * 57 Shipping income -- -- Dividends from noncontrolled section 902 corp -- -- Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income * 7,759 57,902 Foreign income and taxes reported on Form 1118 Foreign taxes available for credit Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Other taxes paid or accrued on-- Taxes Industrial division and income type Other deemed income paid (37) (38) ALL INDUSTRIES All income types 4,024,468 29,022,856 Passive income 37,391 545,447 High withholding tax interest * 152 30,281 Financial services income 816,302 2,947,847 Shipping income * 5,948 58,023 Dividends from noncontrolled section 902 corp 32,899 1,286,523 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 133,829 * 18,114 Certain distributions from a FSC or former FSC (2) -- * 102 General limitation income 2,997,948 24,136,517 AGRICULTURE, FORESTRY, AND FISHING All income types * 4,897 21,774 Passive income -- 465 High withholding tax interest -- -- Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 263 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 4,897 21,047 MINING All income types 642,654 279,548 Passive income * 1,351 * 765 High withholding tax interest ** ** Financial services income ** ** Shipping income -- -- Dividends from noncontrolled section 902 corp -- * 993 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) -- -- General limitation income 641,503 275,973 CONSTRUCTION All income types 1,918 * 16,088 Passive income * 78 * 221 High withholding tax interest ** ** Financial services income -- -- Shipping income -- -- Dividends from noncontrolled section 902 corp * 28 * 3,595 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation -- -- Certain distributions from a FSC or former FSC (2) ** ** General limitation income * 1,812 * 12,272 MANUFACTURING All income types 2,397,654 23,033,544 Passive income 27,258 466,819 High withholding tax interest -- * 569 Financial services income * 188,212 966,332 Shipping income * 3,192 * 8,174 Dividends from noncontrolled section 902 corp 26,611 490,053 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 1,542 * 5,715 Certain distributions from a FSC or former FSC (2) -- * 102 General limitation income 2,150,840 21,095,780 TRANSPORTATION AND PUBLIC UTILITIES All income types 169,482 585,276 Passive income * 768 7,115 High withholding tax interest -- -- Financial services income ** ** Shipping income * 2,756 * 49,627 Dividends from noncontrolled section 902 corp -- 266,052 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 38,824 262,482 WHOLESALE AND RETAIL TRADE All income types 25,781 1,121,443 Passive income * 119 15,911 High withholding tax interest -- * 3,421 Financial services income * 4 * 55,235 Shipping income ** ** Dividends from noncontrolled section 902 corp -- 12,554 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) ** ** General limitation income 25,658 1,021,833 FINANCE, INSURANCE, AND REAL ESTATE All income types 647,142 2,636,482 Passive income 7,395 48,071 High withholding tax interest * 152 * 24,474 Financial services income 624,115 1,921,150 Shipping income ** ** Dividends from noncontrolled section 902 corp * 6,261 243,327 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation ** ** Certain distributions from a FSC or former FSC (2) -- -- General limitation income 9,219 399,328 SERVICES All income types 134,739 1,328,700 Passive income * 422 6,081 High withholding tax interest -- -- Financial services income * 3,971 * 5,130 Shipping income -- -- Dividends from noncontrolled section 902 corp -- 269,686 Dividends from an IC-DISC or former DISC (1) -- -- Miscellaneous separately calculated limitation * 5,152 (3) Certain distributions from a FSC or former FSC (2) -- -- General limitation income 125,194 1,047,804 * Data should be used with caution because of the small number of returns on which the, were based. ** Not shown to avoid disclosure of information about specific taxpayers. However, the data are included in the appropriate totals. (1) Interest-Charge Domestic International Sales Corporation (IC-DISC) and Domestic International Sales Corporation (DISC). (2) Foreign Sales Corporation (FSC). (3) Less than $500. (4) Included in gross income (less loss), columns 2-8. (5) Included in deductions, columns 12-21. NOTE: Detail may not add to totals because of rounding. Table 3.--U.S. Corporation Returns with a Foreign Tax Credit: Foreign Income and Tax Reported on Form 1118, by Selected Country to Which Foreign Tax Was Paid [All figures are estimates based on samples--money amounts are in thousands of dollars] Foreign income and taxes reported on Form 1118 Gross income (less loss) Number of Selected country returns Total Dividends (1) (2) (3) All countries 6,569 359,898,600 68,480,746 Canada 2,021 27,612,506 6,957,260 Latin America, total 1,422 38,647,969 7,713,452 Mexico 948 8,609,287 1,524,863 Central America, total 300 1,416,661 306,098 Belize 41 40,118 * 3,008 Costa Rica 152 124,531 18,083 El Salvador 107 188,967 7,689 Guatemala 142 262,725 25,023 Honduras 105 77,093 * 5,878 Nicaragua 59 33,374 * 11 Panama 195 684,831 246,405 Caribbean countries, total 346 3,297,056 1,051,409 Cayman Islands (British) 186 1,721,166 879,227 Dominican Republic 119 299,310 61,966 Haiti 37 74,360 * 5,041 Jamaica 105 143,907 * 5,772 Trinidad and Tobago 107 683,366 29,183 Other Caribbean countries 106 374,948 70,219 South America, total 869 20,250,271 4,831,082 Argentina 470 4,457,984 423,107 Bolivia 93 93,988 * 3,318 Brazil 523 8,641,685 3,114,325 Chile 323 2,249,046 740,818 Colombia 306 1,859,778 140,603 Ecuador 195 308,242 19,463 Paraguay 70 55,853 * 2,171 Peru 228 824,476 73,695 Uruguay 116 214,312 43,331 Venezuela 337 1,425,201 268,234 Other South America 47 119,705 * 2,016 Latin America not allocable 18 5,074,694 -- Other Western Hemisphere, total 347 8,193,575 2,326,003 Bahamas 106 3,197,883 309,171 Bermuda 209 2,863,323 1,582,682 Netherlands Antilles 79 511,562 345,215 Other British West Indies 131 219,256 86,431 All other Western Hemisphere 61 1,401,551 * 2,505 Europe, total 2,570 138,694,624 35,098,049 European Union, total 2,486 121,236,653 28,801,773 Austria 239 906,511 264,758 Belgium 371 5,937,525 1,504,825 Denmark 250 997,811 116,851 Finland 220 724,270 92,424 France 604 8,527,013 1,998,102 Germany 662 15,030,010 3,666,345 Greece 182 840,785 40,748 Ireland 247 4,361,949 895,847 Italy 534 6,114,891 1,408,794 Luxembourg 82 721,433 363,301 Netherlands 826 12,338,820 4,970,694 Portugal 193 539,247 173,616 Spain 542 3,219,432 909,143 Sweden 386 1,998,485 584,443 United Kingdom 1,691 58,929,455 11,811,300 European Union, not allocable 4 * 49,015 * 382 Other West European countries, total 515 12,340,246 5,891,495 Liechtenstein 15 10,995 * 9,600 Monaco 14 17,007 * 83 Norway 223 3,133,427 529,257 Switzerland 394 8,203,643 5,256,597 Turkey 197 899,802 92,341 Other West European countries 69 37,160 * 3,618 West European countries not allocable 4 * 38,211 -- East European countries, total 341 2,917,101 404,531 Romania 57 76,978 * 12,558 Former Soviet Union 217 1,586,555 238,739 Other East Europe 264 1,253,568 153,233 Europe not allocable 29 2,200,624 * 251 Africa, total 504 5,858,919 930,572 North Africa, total 166 1,487,901 72,707 Algeria 32 142,092 * 1,356 Egypt 126 1,242,948 60,934 Libya 5 * 684 -- Morocco 58 50,259 * 5,329 Other North Africa 50 51,918 * 5,088 East Africa, total 129 214,269 26,594 Ethiopia 22 37,990 * 5 Kenya 73 55,810 7,557 Tanzania 23 32,715 * 3,048 Uganda 17 2,422 -- Other East Africa 81 85,332 15,984 West and Central Africa, total 176 3,237,100 696,861 Gabon 45 149,883 * 76,933 Ghana 35 108,778 * 15,617 Liberia 43 241,396 157,694 Nigeria 78 1,864,320 391,881 Zaire 15 69,523 * 2,946 Other West and Central Africa 89 803,200 * 51,790 Southern Africa, total 364 919,237 134,409 Malawi 9 * 2,121 * 952 Zimbabwe 53 35,406 15,803 South Africa (including Namibia) 351 828,446 113,930 Zambia 26 7,635 * 3,100 Other Southern Africa 24 45,629 * 624 Africa not allocable 7 * 412 -- Asia, total 1,988 76,430,221 8,037,560 Middle East, total 478 4,800,957 357,376 Bahrain 64 280,804 * 1,045 Iran 13 8,187 * 1,314 Iraq 5 * 1,008 -- Israel 347 640,765 106,355 Kuwait 79 147,254 * 884 Lebanon 56 68,221 * 875 Qatar 60 201,389 -- Saudi Arabia 158 1,942,925 80,090 United Arab Emirates 120 652,179 57,302 Other areas of the Arabian Peninsula 59 685,416 * 100,035 Other Middle East 97 172,811 9,475 Southern and Southeast Asia, total 859 19,939,786 2,872,321 Bangladesh 34 60,988 -- India 356 1,263,336 51,614 Indonesia 289 5,562,349 551,313 Malaysia 328 2,207,948 281,664 Pakistan 97 400,595 8,667 Philippines 289 1,786,443 261,941 Singapore 463 6,219,800 1,163,645 Sri Lanka 43 32,692 * 1,561 Thailand 312 2,199,920 545,846 Vietnam 59 30,431 -- Other Southern and Southeast Asia 79 175,285 * 6,071 Eastern Asia, total 1,604 48,627,764 4,807,810 China 365 1,939,917 105,042 Hong Kong 539 8,403,379 1,163,343 Japan 1,246 30,105,885 2,882,885 South Korea 417 3,741,513 277,319 Taiwan 408 3,826,384 379,220 Other Eastern Asia 29 610,685 -- Asia not allocable 26 3,061,713 * 53 Oceania, total 812 11,348,972 2,305,933 Australia 748 9,291,969 1,629,277 New Zealand 327 1,514,937 583,627 Other Oceania 68 542,065 93,029 Puerto Rico and U.S. Possessions, total 513 4,389,004 473,020 Puerto Rico 446 3,737,089 448,196 U.S. Possessions, total 175 651,915 24,824 American Samoa 21 11,017 -- Guam 132 332,340 * 9,511 Virgin Islands 81 290,565 * 6,766 Other U.S. Possessions 19 17,992 * 8,546 Country not stated 2,641 45,452,969 1,369,157 Foreign Sales Corporation dividends (2) 81 3,268,813 3,268,712 Interest-Charge Domestic International Sales Corporation dividends (2) 3 * 1,029 * 1,029 Foreign income and taxes reported on Form 1118 Gross income (less loss) Foreign dividend income Rents, resulting royalties, Selected country from Interest and foreign license taxes fees deemed paid (gross-up) (4) (5) (6) All countries 29,020,456 61,505,751 48,610,292 Canada 4,788,555 4,364,665 2,996,418 Latin America, total 2,160,036 10,039,766 3,515,659 Mexico 687,938 1,484,816 1,192,777 Central America, total 48,762 261,021 147,513 Belize * 64 * 586 * 26,331 Costa Rica 3,579 15,080 31,698 El Salvador * 2,965 43,331 14,150 Guatemala 8,462 38,511 19,486 Honduras * 3,795 5,962 5,248 Nicaragua * 5 4,538 1,088 Panama 29,892 153,014 49,513 Caribbean countries, total 112,234 694,369 135,529 Cayman Islands (British) 60,340 625,418 89,272 Dominican Republic 21,320 34,270 14,802 Haiti * 638 * 1,306 * 854 Jamaica * 4,892 14,161 18,618 Trinidad and Tobago * 6,574 13,468 6,615 Other Caribbean countries 18,470 5,746 5,368 South America, total 1,311,101 4,762,498 1,925,249 Argentina 195,085 1,694,589 432,424 Bolivia * 1,960 10,654 7,583 Brazil 908,341 1,896,461 973,054 Chile 40,601 553,376 114,178 Colombia 60,652 140,519 117,100 Ecuador 3,700 40,352 20,817 Paraguay * 716 * 6,039 7,508 Peru 29,047 172,633 46,964 Uruguay 6,521 78,959 14,951 Venezuela 62,798 168,762 189,583 Other South America * 1,680 * 154 * 1,108 Latin America not allocable -- * 2,837,062 * 114,590 Other Western Hemisphere, total 181,696 1,937,062 70,374 Bahamas 13,101 1,074,725 5,938 Bermuda 113,162 757,135 29,872 Netherlands Antilles 33,526 69,810 8,387 Other British West Indies 20,307 30,150 21,876 All other Western Hemisphere * 1,599 * 5,243 4,301 Europe, total 15,241,896 23,947,037 21,143,159 European Union, total 14,005,507 22,797,042 19,509,169 Austria 128,066 70,600 240,670 Belgium 706,151 717,541 787,061 Denmark 85,067 49,927 243,554 Finland 29,814 75,884 253,614 France 1,091,350 750,162 2,562,930 Germany 2,458,264 1,256,570 3,816,546 Greece 22,158 507,113 76,695 Ireland 109,915 198,496 2,533,007 Italy 1,073,049 1,061,272 1,162,699 Luxembourg 189,300 32,014 65,118 Netherlands 2,511,824 499,714 2,123,467 Portugal 52,957 14,758 167,725 Spain 534,569 439,952 881,579 Sweden 300,474 180,430 486,407 United Kingdom 4,712,471 16,942,608 4,105,740 European Union, not allocable * 78 -- * 2,358 Other West European countries, total 1,128,819 845,439 1,023,511 Liechtenstein * 264 * 2 * 30 Monaco * 36 * 1,235 * 9 Norway 256,494 203,069 146,432 Switzerland 827,963 248,926 720,656 Turkey 43,037 377,615 144,416 Other West European countries * 1,024 14,592 9,271 West European countries not allocable -- -- * 2,697 East European countries, total 107,569 304,550 572,214 Romania * 11,200 14,340 9,100 Former Soviet Union * 21,287 224,095 171,891 Other East Europe 75,082 66,115 391,223 Europe not allocable -- * 6 * 38,265 Africa, total 322,168 350,788 509,306 North Africa, total 24,027 103,845 49,853 Algeria * 274 * 1,227 * 3,449 Egypt 16,859 79,624 42,642 Libya -- * 397 -- Morocco * 3,557 2,660 2,860 Other North Africa * 3,337 * 19,937 901 East Africa, total 12,301 38,965 27,224 Ethiopia -- * 1,353 * 266 Kenya * 4,295 11,985 7,203 Tanzania * 901 * 541 * 1,004 Uganda -- * 224 * 1,323 Other East Africa * 7,105 24,862 17,429 West and Central Africa, total 208,553 110,578 64,268 Gabon * 879 * 48,205 * 751 Ghana * 9,857 * 590 * 83 Liberia * 14,762 29,097 -- Nigeria 161,996 7,810 28,209 Zaire * 1,429 * 81 * 5,978 Other West and Central Africa * 19.631 24,796 29,246 Southern Africa, total 77,286 97,400 367,772 Malawi * 809 * 1 * 1 Zimbabwe * 11,906 * 939 2,712 South Africa (including Namibia) 62,853 93,164 327,155 Zambia * 1,434 * 332 * 1,447 Other Southern Africa * 285 * 2,964 * 36,457 Africa not allocable -- -- * 189 Asia, total 5,048,513 10,407,296 13,522,718 Middle East, total 152,430 569,577 386,318 Bahrain * 177 256,758 1,781 Iran (1) (1) * 79 Iraq -- -- * -289 Israel 43,604 41,525 164,781 Kuwait * 275 * 2,272 27,406 Lebanon * 72 * 12,337 21,095 Qatar -- * 33,741 8,597 Saudi Arabia 35,795 98,330 82,468 United Arab Emirates * 231 104,509 27,163 Other areas of the Arabian Peninsula * 71,538 * 5,274 47,198 Other Middle East * 738 14,832 6,038 Southern and Southeast Asia, total 1,034,817 3,670,226 2,634,071 Bangladesh -- * 15,718 * 840 India 26,997 417,794 101,465 Indonesia 370,595 443,457 215,006 Malaysia 86,993 316,667 250,292 Pakistan 6,228 234,721 6,804 Philippines 125,538 382,875 139,920 Singapore 228,854 1,285,333 1,715,839 Sri Lanka * 723 * 9,792 * 1,927 Thailand 187,739 447,779 196,076 Vietnam -- 13,599 1,424 Other Southern and Southeast Asia * 1,151 102,491 4,479 Eastern Asia, total 3,861,258 6,167,239 10,373,000 China 22,572 126,834 611,189 Hong Kong 188,975 2,180,477 639,933 Japan 3,372,016 2,273,587 7,373,485 South Korea 168,230 831,796 1,062,889 Taiwan 109,465 747,231 672,996 Other Eastern Asia -- * 7,314 * 12,507 Asia not allocable * 7 * 254 * 129,330 Oceania, total 924,224 1,646,360 1,322,050 Australia 677,609 1,458,557 1,026,064 New Zealand 236,054 177,744 283,897 Other Oceania * 10,562 10,059 12,088 Puerto Rico and U.S. Possessions, total 83,810 1,087,862 471,543 Puerto Rico 80,897 865,176 441,404 U.S. Possessions, total 2,913 222,686 30,139 American Samoa -- * 5,862 * 930 Guam * 1,109 82,073 23,061 Virgin Islands * 1,222 128,804 5,252 Other U.S. Possessions * 583 * 5,947 * 895 Country not stated 269,455 7,724,915 5,059,066 Foreign Sales Corporation dividends (2) * 102 -- -- Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- Foreign income and taxes reported on Form 1118 Gross income (less loss) Oil and gas extraction Selected country Service Other income income income (less loss) (3) (7) (8) (9) All countries 31,387,624 120,893,731 21,013,968 Canada 1,138,265 7,367,344 * 725,158 Latin America, total 4,279,820 10,939,237 1,345,580 Mexico 474,223 3,244,670 * 4,496 Central America, total 92,059 561,208 -- Belize * 3,333 6,797 -- Costa Rica 17,882 38,209 -- El Salvador 5,501 115,331 -- Guatemala 25,436 145,807 -- Honduras 5,827 50,383 -- Nicaragua * 319 27,414 -- Panama 33,761 172,245 -- Caribbean countries, total 249,453 1,054,062 * 508,768 Cayman Islands (British) * 7,479 59,430 -- Dominican Republic 27,283 139,668 -- Haiti * 6,054 60,468 -- Jamaica 18,423 82,040 -- Trinidad and Tobago 41,403 586,121 * 508,768 Other Caribbean countries 148,810 126,334 -- South America, total 1,650,362 5,769,978 832,316 Argentina 482,221 1,230,558 * 240,629 Bolivia 34,412 36,061 -- Brazil 231,423 1,518,081 * 430 Chile 159,338 640,735 * 4 Colombia 158,645 1,242,259 * 469,286 Ecuador 28,869 195,040 * 104,223 Paraguay 8,245 31,174 -- Peru 47,507 454,630 * 102 Uruguay 34,446 36,104 -- Venezuela 461,339 274,505 * 17,641 Other South America 3,917 110,831 -- Latin America not allocable * 1,813,724 309,318 -- Other Western Hemisphere, total 1,457,840 2,220,599 * 59,063 Bahamas 15,098 1,779,850 * 12 Bermuda 61,043 319,430 * 59,051 Netherlands Antilles * 4,695 49,930 -- Other British West Indies 9,154 51,338 -- All other Western Hemisphere 1,367,851 20,053 -- Europe, total 5,777,798 37,486,684 7,898,566 European Union, total 4,963,599 31,159,562 6,023,088 Austria 17,263 185,153 -- Belgium 189,981 2,031,965 * 99 Denmark 30,782 471,630 * 274,567 Finland 17,541 254,994 -- France 267,571 1,856,898 * 1,937 Germany 479,106 3,353,178 * 481 Greece 64,212 129,859 -- Ireland 99,959 524,723 -- Italy 217,138 1,191,940 (1) Luxembourg * 14,167 57,533 -- Netherlands 224,141 2,008,981 * 1,175,166 Portugal 24,700 105,291 -- Spain 55,464 398,725 -- Sweden 67,408 379,322 -- United Kingdom 3,194,164 18,163,172 4,570,839 European Union, not allocable -- * 46,197 -- Other West European countries, total 379,006 3,071,976 * 1,467,404 Liechtenstein * 881 * 219 -- Monaco * 8,810 * 6,833 -- Norway 103,187 1,894,988 * 1,467,404 Switzerland 213,129 936,371 -- Turkey 51,657 190,736 -- Other West European countries * 1,341 7,314 -- West European countries not allocable -- * 35,515 -- East European countries, total 429,191 1,099,047 * 408,073 Romania * 6,516 23,263 * -352 Former Soviet Union 126,223 804,321 * 408,425 Other East Europe 296,452 271,462 -- Europe not allocable *6,003 2,156,099 -- Africa, total 1,084,205 2,661,880 1,312,129 North Africa, total 402,611 834,857 * 425,590 Algeria * 243,313 -107,528 * 45,555 Egypt 143,017 899,871 * 382,850 Libya -- * 287 -- Morocco * 1,756 34,098 -- Other North Africa * 14,526 8,129 * -2,814 East Africa, total 5,440 103,744 -- Ethiopia * 1 36,365 -- Kenya * 5,787 18,983 -- Tanzania * 27 27,195 -- Uganda * 4 875 -- Other East Africa * -376 20,327 -- West and Central Africa, total 602,749 1,554,091 * 886,015 Gabon * 18,559 4,557 * 75,299 Ghana * 2,237 80,394 -- Liberia * 33,022 * 6,821 -- Nigeria 197,844 1,076,580 * 668,261 Zaire * 13 * 59,075 * 55,601 Other West and Central Africa 351,073 326,664 * 86,854 Southern Africa, total 73,405 168,966 * 524 Malawi * 43 * 316 -- Zimbabwe * 521 3,525 -- South Africa (including Namibia) 70,205 161,140 * 524 Zambia * 8 1,314 -- Other Southern Africa * 2,628 2,671 -- Africa not allocable -- * 222 -- Asia, total 10,840,068 28,574,065 4,536,151 Middle East, total 893,348 2,441,908 * 1,231,069 Bahrain 20,470 574 -- Iran -- * 6,794 -- Iraq -- * 1,296 -- Israel 36,272 248,227 -- Kuwait 82,721 33,696 -- Lebanon * 3,359 30,483 -- Qatar 42,734 116,318 * -1,036 Saudi Arabia 552,443 1,093,799 * 524,247 United Arab Emirates 76,569 386,403 * 232,369 Other areas of the Arabian Peninsula 60,805 400,565 * 475,489 Other Middle East 17,975 123,753 -- Southern and Southeast Asia, total 1,609,260 8,119,092 3,092,178 Bangladesh 15,917 28,513 -- India 254,320 411,146 -- Indonesia 372,962 3,609,017 1,748,954 Malaysia 139,970 1,132,361 * 750,752 Pakistan 31,562 112,613 * 23,238 Philippines 137,450 738,719 * -96 Singapore 459,569 1,366,560 * 7 Sri Lanka * 4,028 14,662 -- Thailand 155,848 666,631 * 569,501 Vietnam 14,365 1,043 * -178 Other Southern and Southeast Asia 23,266 37,827 -- Eastern Asia, total 8,307,868 15,110,589 * 212,904 China 403,524 670,755 * 196,148 Hong Kong 580,775 3,649,875 -- Japan 6,570,001 7,633,910 * 16,756 South Korea 316,517 1,084,764 -- Taiwan 419,534 1,497,938 -- Other Eastern Asia * 17,517 573,347 -- Asia not allocable * 29,593 2,902,476 -- Oceania, total 588,839 4,561,567 * 1,506,590 Australia 316,233 4,184,230 * 1,438,421 New Zealand 32,775 200,840 * -6 Other Oceania 239,831 176,496 * 68,175 Puerto Rico and U.S. Possessions, total 489,794 1,782,974 -- Puerto Rico 425,735 1,475,681 -- U.S. Possessions, total 64,059 307,293 -- American Samoa * 1,616 2,609 -- Guam 27,703 188,883 -- Virgin Islands 33,251 115,269 -- Other U.S. Possessions * 1,489 532 -- Country not stated 5,730,995 25,299,381 3,630,730 Foreign Sales Corporation dividends (2) -- -- -- Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- Foreign income and taxes reported on Form 1118 Specifi- cally Foreign allocable Selected country branch income Total income [section deductions (3) 863(b)] (3) (10) (11) (12) All countries 88,607,771 24,971,121 201,909,309 Canada 2,618,225 1,445,918 11,705,951 Latin America, total 11,214,336 2,037,512 22,367,820 Mexico 1,933,731 852,632 4,028,595 Central America, total 344,403 24,856 798,420 Belize * 2,872 547 37,729 Costa Rica * 1,942 6,078 72,464 El Salvador * 27,788 2,960 108,836 Guatemala * 106,448 3,152 155,885 Honduras * 19,523 2,160 52,947 Nicaragua * 7,412 3,113 15,069 Panama 173,506 6,846 353,942 Caribbean countries, total 656,591 65,929 1,830,242 Cayman Islands (British) 186,856 5,162 776,739 Dominican Republic 135,041 11,734 130,781 Haiti * 14,450 * 453 58,777 Jamaica 50,348 20,671 92,546 Trinidad and Tobago 113,220 2,445 541,337 Other Caribbean countries * 156,676 25,463 230,063 South America, total 6,417,710 1,087,288 12,013,533 Argentina 1,654,036 565,017 2,681,917 Bolivia * 25,832 6,880 60,422 Brazil 2,352,381 291,672 5,034,096 Chile 527,528 79,601 1,248,534 Colombia 712,930 61,989 1,176,849 Ecuador 59,597 17,834 177,991 Paraguay * 60,631 1,682 51,125 Peru 452,738 25,467 523,044 Uruguay 124,216 5,872 138,526 Venezuela 397,065 30,807 873,598 Other South America 50,755 468 47,430 Latin America not allocable * 1,861,901 * 6,807 3,697,030 Other Western Hemisphere, total 3,140,218 16,095 5,091,089 Bahamas 1,347,831 38,618 2,290,342 Bermuda 339,117 16,713 1,164,777 Netherlands Antilles * 64.874 758 342,841 Other British West Indies 22,942 3,341 127,613 All other Western Hemisphere * 1,365,454 1,711 1,165,517 Europe, total 34,728,658 5,604,072 71,980,216 European Union, total 31,129,589 5,082,947 61,563,138 Austria 134,412 21,518 518,782 Belgium 1,873,225 165,801 3,229,699 Denmark 407,832 16,156 577,419 Finland * 26,870 96,630 421,593 France 1,172,824 243,395 4,663,220 Germany 2,287,800 457,391 6,476,201 Greece 595,548 10,305 525,540 Ireland 137,860 35,449 1,796,177 Italy 1,296,027 326,107 3,078,235 Luxembourg * 6,956 * 515 279,069 Netherlands 2,757,305 230,266 3,731,761 Portugal 79,926 20,484 252,838 Spain 485,060 97,764 1,368,428 Sweden 158,410 42,198 875,443 United Kingdom 19,664,135 3,318,966 33,723,692 European Union, not allocable * 45,398 -- * 45,042 Other West European countries, total 2,773,405 241,009 7,243,334 Liechtenstein -- (1) 2,672 Monaco * 5,844 * 3 17,452 Norway 1,547,063 14,957 968,656 Switzerland 859,454 180,711 5,634,796 Turkey 359,786 43,409 576,996 Other West European countries * 711 1,929 18,733 West European countries not allocable * 546 -- * 24,030 East European countries, total 779,731 222,646 1,782,458 Romania * 30,088 * 1,046 72,699 Former Soviet Union 390,270 163,333 984,252 Other East Europe 359,373 58,266 725,507 Europe not allocable * 45,933 * 57,471 1,391,286 Africa, total 1,233,350 149,986 2,709,675 North Africa, total 536,124 40,417 891,286 Algeria * 131,789 * 872 86,890 Egypt 336,388 31,978 738,432 Libya -- -- * 7,160 Morocco * 22,465 5,025 21,240 Other North Africa 45,482 2,541 37,564 East Africa, total 73,178 1,367 158,158 Ethiopia * 13,674 * 60 39,076 Kenya * 38,721 511 41,138 Tanzania * 2,662 * 386 35,798 Uganda -- * 152 2,276 Other East Africa * 18,122 * 258 39,870 West and Central Africa, total 465,011 64,061 1,162,771 Gabon * 8,408 * 1,001 27,607 Ghana * 1 * 1,161 39,684 Liberia * 23,219 * 770 82,462 Nigeria * 120,178 20,050 448,026 Zaire (1) * 103 48,542 Other West and Central Africa 313,206 40,975 516,449 Southern Africa, total 159,036 44,071 497,167 Malawi -- * 190 * 913 Zimbabwe * 49 * 73 12,562 South Africa (including Namibia) * 158,887 37,377 434,025 Zambia * 5 * 90 4,240 Other Southern Africa * 95 * 6,341 45,427 Africa not allocable -- * 71 * 293 Asia, total 28,721,909 4,155,921 47,131,215 Middle East, total 1,801,216 312,574 3,018,761 Bahrain * 293,198 5,772 192,911 Iran -- * -2 741 Iraq -- -- * 321 Israel 24,612 36,844 334,589 Kuwait 27,161 8,716 107,066 Lebanon * 12,432 16,343 43,495 Qatar * 10,797 44,992 199,078 Saudi Arabia 697,076 170,982 1,334,211 United Arab Emirates 370,377 24,269 464,079 Other areas of the Arabian Peninsula * 252,772 2,822 237,360 Other Middle East 112,792 1,837 104,910 Southern and Southeast Asia, total 7,922,309 562,045 10,625,951 Bangladesh * 51,168 * 275 30,957 India 863,055 36,692 826,903 Indonesia 1,491,488 72,997 2,368,040 Malaysia 1,123,313 76,331 1,145,748 Pakistan 360,147 1,859 248,636 Philippines 753,168 302,884 949,698 Singapore 2,296,590 10,064 3,648,273 Sri Lanka * 9,504 578 17,850 Thailand 819,428 49,713 1,228,242 Vietnam * 17,653 1,000 33,545 Other Southern and Southeast Asia * 136,794 9,652 128,056 Eastern Asia, total 18,992,540 3,083,675 30,656,975 China 544,251 180,522 1,384,166 Hong Kong 4,749,874 1,004,967 5,845,110 Japan 10,223,373 1,503,549 18,129,173 South Korea 1,388,307 164,426 2,192,599 Taiwan 2,069,224 218,458 2,690,865 Other Eastern Asia * 17,510 * 11,752 415,062 Asia not allocable * 5,844 * 197,627 2,829,529 Oceania, total 3,431,333 288,082 5,079,838 Australia 2,902,988 264,675 4,231,573 New Zealand 237,773 18,021 471,724 Other Oceania * 290,572 5,386 376,541 Puerto Rico and U.S. Possessions, total 1,913,921 198,533 3,016,124 Puerto Rico 1,606,314 171,564 2,555,011 U.S. Possessions, total 307,607 26,969 461,114 American Samoa * 5,862 * 1,744 9,173 Guam 221,005 23,147 261,177 Virgin Islands 73,371 * 2,056 178,373 Other U.S. Possessions * 7,369 * 21 12,390 Country not stated 1,605,818 11,107,191 29,666,594 Foreign Sales Corporation dividends (2) -- -- 3,160,787 Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- Foreign income and taxes reported on Form 1118 Foreign taxes paid, accrued, and deemed paid Deduc- tions Taxable from oil income Selected country and gas (less loss) Total extrac- before tion in- adjustments come (4) (13) (14) (15) All countries 8,915,360 157,989,290 45,079,798 Canada 459,331 15,906,555 5,655,560 Latin America, total 898,475 16,280,149 4,295,619 Mexico * 3,192 4,580,692 1,098,347 Central America, total * -32 618,242 100,219 Belize -- 2,390 * 318 Costa Rica -- 52,067 14,356 El Salvador -- 80,131 7,742 Guatemala * -32 106,841 25,936 Honduras -- 24,145 7,997 Nicaragua -- 18,306 494 Panama -- 330,890 41,724 Caribbean countries, total * 454,045 1,466,814 183,402 Cayman Islands (British) -- 944,427 60,340 Dominican Republic -- 168,529 37,331 Haiti -- 15,584 * 6,644 Jamaica -- 51,361 12,554 Trinidad and Tobago * 454,045 142,029 47,038 Other Caribbean countries -- 144,885 19,496 South America, total 441,271 8,236,737 2,897,805 Argentina * 119,217 1,776,068 467,406 Bolivia * 132 33,566 5,803 Brazil * 539 3,607,589 1,565,006 Chile -- 1,000,511 265,777 Colombia 243,895 682,929 315,351 Ecuador * 63,202 130,251 14,125 Paraguay * 1,860 4,727 9,007 Peru * 599 301,432 111,359 Uruguay -- 75,785 12,532 Venezuela * 11,827 551,603 113,242 Other South America -- 72,275 * 18,195 Latin America not allocable -- 1,377,664 * 15,846 Other Western Hemisphere, total * -14,931 3,102,456 188,052 Bahamas -- 907,541 13,101 Bermuda * -15,442 1,698,546 113,162 Netherlands Antilles -- 168,722 36,326 Other British West Indies -- 91,643 22,449 All other Western Hemisphere * 511 236,035 * 3,013 Europe, total 2,863,553 66,714,408 20,036,867 European Union, total 2,272,049 59,673,515 17,615,094 Austria * -343 387,729 159,034 Belgium * 201 2,707,827 904,440 Denmark * 143,727 420,392 139,772 Finland -- 302,678 44,511 France * 325 3,863,793 1,321,863 Germany * 230 8,553,809 2,794,842 Greece * 53 315,246 34,423 Ireland * 70 2,565,771 117,440 Italy * 11,821 3,036,657 1,406,620 Luxembourg -- 442,364 203,177 Netherlands -- 8,607,060 2,762,987 Portugal * 112 286,410 82,585 Spain -- 1,851,004 732,516 Sweden 2,021,989 1,123,042 343,309 United Kingdom -- 25,205,763 6,567,123 Other European Economic Community * 449,701 * 3,972 * 152 Other West European countries, total -- 5,096,912 2,198,268 Liechtenstein -- 8,324 * 264 Monaco * 449,701 -445 * 158 Norway -- 2,164,771 955,912 Switzerland -- 2,568,847 1,118,716 Turkey -- 322,807 121,479 Other West European countries -- 18,427 1,739 West European countries not allocable * 141,803 * 14,182 -- East European countries, total * 17,497 1,134,643 221,210 Romania * 124,306 4,279 17,722 Former Soviet Union -- 602,304 98,346 Other East Europe -- 528,061 105,142 Europe not allocable 533,293 809,337 * 2,295 Africa, total * 334,403 3,149,243 938,103 North Africa, total * 23,230 596,615 223,591 Algeria * 304,512 55,202 18,454 Egypt -- 504,516 192,662 Libya -- * -6,476 -- Morocco * 6,661 29,019 7,460 Other North Africa * 8 14,354 * 5,015 East Africa, total -- 56,111 21,566 Ethiopia * 8 -1,085 * 2,012 Kenya -- 14,672 10,481 Tanzania -- -3,084 * 1,164 Uganda -- 146 * 200 Other East Africa * 198,837 45,462 7,708 West and Central Africa, total * 8,858 2,074,330 565,998 Gabon -- 122,276 * 2,980 Ghana -- 69,094 * 10,635 Liberia * 81,164 158,934 * 14,762 Nigeria * 41,368 1,416,294 405,220 Zaire * 67,447 20,981 * 7,878 Other West and Central Africa * 44 286,752 124,523 Southern Africa, total -- 422,070 126,948 Malawi -- * 1,208 * 809 Zimbabwe * 44 22,844 14,998 South Africa (including Namibia) -- 394,422 102,836 Zambia -- 3,395 * 1,752 Other Southern Africa -- 202 * 6,553 Africa not allocable -- * 118 -- Asia, total 1,897,901 29,299,006 10,228,323 Middle East, total * 801,751 1,782,197 608,311 Bahrain -- 87,893 * 179 Iran -- 7,446 (1) Iraq -- * 686 -- Israel -- 306,176 81,493 Kuwait * 8,306 40,188 8,043 Lebanon -- 24,727 971 Qatar * 5,135 2,311 * 2,744 Saudi Arabia * 501,889 608,714 267,264 United Arab Emirates * 167,307 188,100 65,182 Other areas of the Arabian Peninsula * 119,115 448,055 177,593 Other Middle East -- 67,901 4,842 Southern and Southeast Asia, total 1,007,014 9,313,835 2,910,136 Bangladesh * 260 30,031 * 6,164 India * 1 436,433 179,096 Indonesia 554,961 3,194,309 1,451,437 Malaysia * 315,229 1,062,199 255,562 Pakistan * 5,729 151,959 52,571 Philippines * 571 836,744 269,933 Singapore * 49 2,571,526 359,282 Sri Lanka -- 14,842 2,751 Thailand * 129,705 971,678 319,447 Vietnam * 509 -3,114 568 Other Southern and Southeast Asia -- 47,229 * 13,324 Eastern Asia, total * 89,136 17,970,789 6,709,839 China * 89,047 555,751 67,950 Hong Kong -- 2,558,269 616,411 Japan * 88 11,976,713 5,105,043 South Korea -- 1,548,915 597,712 Taiwan -- 1,135,519 322,723 Other Eastern Asia -- 195,624 (1) Asia not allocable -- 232,184 * 36 Oceania, total 558,489 6,269,134 1,959,607 Australia * 517,700 5,060,397 1,619,917 New Zealand * 11 1,043,213 286,467 Other Oceania * 407,78 165,524 53,224 Puerto Rico and U.S. Possessions, total * 68 1,372,879 292,760 Puerto Rico -- 1,182,078 260,022 U.S. Possessions, total * 68 190,801 32,738 American Samoa -- 1,843 * 770 Guam * 68 71,163 19,036 Virgin Islands -- 112,192 12,183 Other U.S. Possessions -- 5,602 * 750 Country not stated 1,719,182 15,786,375 1,484,789 Foreign Sales Corporation dividends (2) -- 108,026 * 102 Interest-Charge Domestic International Sales Corporation dividends (2) -- * 1,029 -- Foreign income and taxes reported on Form 1118 Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Taxes withheld at source on-- Selected country Total Dividends Interest (16) (17) (18) All countries 16,056,942 2,767,327 640,883 Canada 866,979 337,193 42,976 Latin America, total 2,135,588 382,548 221,276 Mexico 410,408 7,774 40,062 Central America, total 51,457 4,687 826 Belize * 254 200 -- Costa Rica 10,777 2,344 * 305 El Salvador 4,777 * 54 * 107 Guatemala 17,474 * 384 * 290 Honduras 4,202 * 867 * 27 Nicaragua * 489 -- * 65 Panama 11,832 785 * 31 Caribbean countries, total 71,168 4,962 * 406 Cayman Islands (British) -- -- -- Dominican Republic 16,011 * 1,819 * 45 Haiti * 6,006 * 650 -- Jamaica 7,662 * 431 * 230 Trinidad and Tobago 40,464 * 2,062 * 94 Other Caribbean countries 1,025 (1) * 37 South America, total 1,586,709 365,124 170,094 Argentina 272,321 1,138 32,576 Bolivia 3,843 * 126 * 350 Brazil 656,665 289,759 127,490 Chile 225,176 61,619 5,931 Colombia 254,704 11,546 * 380 Ecuador 10,426 * 393 * 207 Paraguay 8,291 * 37 * 78 Peru 82,311 -- 740 Uruguay 6,011 -- -- Venezuela 50,444 * 506 2,342 Other South America * 16,516 -- -- Latin America not allocable * 15,846 -- * 9,888 Other Western Hemisphere, total 6,356 * 1,083 -- Bahamas -- -- -- Bermuda -- -- -- Netherlands Antilles * 2,800 * 1,065 -- Other British West Indies 2,142 * 15 -- All other Western Hemisphere * 1,414 * 3 -- Europe, total 4,794,348 1,392,987 99,250 European Union, total 3,609,501 1,118,104 67,496 Austria 30,968 22,278 * 37 Belgium 198,289 25,978 16,120 Denmark 54,701 6,592 -- Finland 14,698 3,768 * 26 France 230,514 71,751 1,456 Germany 336,549 133,058 * 68 Greece 12,265 * 256 (1) Ireland 7,525 1,820 * 501 Italy 333,571 25,762 29,212 Luxembourg 13,877 13,498 -- Netherlands 251,159 149,731 * 858 Portugal 29,917 5,602 * 228 Spain 197,947 94,000 1,576 Sweden 42,835 32,071 * 20 United Kingdom 1,854,613 531,939 17,392 Other European Economic Community * 73 -- -- Other West European countries, total 1,068,912 269,294 30,105 Liechtenstein (1) (1) -- Monaco * 122 -- -- Norway 699,419 10,103 * 42 Switzerland 290,215 258,344 2,637 Turkey 78,442 * 844 * 27,427 Other West European countries * 714 * 2 -- West European countries not allocable -- -- -- East European countries, total 113,640 5,476 * 1,649 Romania 6,522 * 77 * 500 Former Soviet Union 77,059 1,544 * 281 Other East Europe 30,059 3,854 * 867 Europe not allocable * 2,295 * 113 -- Africa, total 615,935 11,833 * 961 North Africa, total 199,564 * 1,229 * 724 Algeria * 18,179 * 947 -- Egypt 175,803 -- * 709 Libya -- -- -- Morocco 3,904 * 282 * 15 Other North Africa * 1,678 -- -- East Africa, total 9,264 970 * 201 Ethiopia * 2,012 -- -- Kenya 6,185 * 747 * 128 Tanzania * 263 -- -- Uganda * 200 -- -- Other East Africa * 603 * 223 * 73 West and Central Africa, total 357,444 5,482 * 36 Gabon * 2,101 * 319 -- Ghana * 778 * 688 (1) Liberia -- -- -- Nigeria 243,223 * 1,547 * 36 Zaire * 6,450 * 315 -- Other West and Central Africa 104,892 * 2,614 -- Southern Africa, total 49,662 4,152 -- Malawi -- -- -- Zimbabwe 3,093 * 2,553 -- South Africa (including Namibia) 39,983 978 -- Zambia * 318 * 112 -- Other Southern Africa * 6,268 * 510 -- Africa not allocable -- -- -- Asia, total 5,178,054 465,167 165,211 Middle East, total 455,881 19,487 604 Bahrain * 3 -- -- Iran -- -- -- Iraq -- -- -- Israel 37,889 9,205 508 Kuwait 7,768 -- -- Lebanon * 899 * 45 -- Qatar * 2,744 -- -- Saudi Arabia 231,469 * 135 * 96 United Arab Emirates 64,951 * 10,092 -- Other areas of the Arabian Peninsula 106,055 -- -- Other Middle East 4,104 * 9 -- Southern and Southeast Asia, total 1,875,316 108,186 26,071 Bangladesh *6,164 -- -- India 152,099 882 * 553 Indonesia 1,080,843 44,719 8,981 Malaysia 168,568 3,587 1,336 Pakistan 46,343 3,324 * 57 Philippines 144,395 43,011 11,259 Singapore 130,425 1,895 1,365 Sri Lanka 2,029 * 233 -- Thailand 131,708 10,535 2,519 Vietnam 568 -- -- Other Southern and Southeast Asia * 12,173 -- -- Eastern Asia, total 2,846,828 337,494 138,535 China 45,378 47,007 6,237 Hong Kong 425,864 6,698 * 115,164 Japan 1,733,027 256,096 10,033 South Korea 429,313 * 5 4,347 Taiwan 213,246 27,668 2,754 Other Eastern Asia (1) -- -- Asia not allocable * 29 -- -- Oceania, total 1,035,383 43,276 11,644 Australia 942,308 32,651 10,424 New Zealand 50,413 8,458 1,085 Other Oceania 42,663 * 2,167 * 135 Puerto Rico and U.S. Possessions, total 208,950 10,380 15,217 Puerto Rico 179,125 10,380 7,433 U.S. Possessions, total 29,825 -- * 7,784 American Samoa * 770 -- -- Guam 17,927 -- -- Virgin Islands 10,961 -- * 7,778 Other U.S. Possessions * 168 -- * 6 Country not stated 1,215,334 122,853 84,347 Foreign Sales Corporation dividends (2) (1) (1) -- Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- Foreign income and taxes reported on Form 1118 Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Taxes Other taxes paid withheld or accrued on-- at source on-- Specifi- Rents, cally royalties Branch allocable Selected country and income income license [section fees 863(b)] (19) (20) (21) All countries 2,238,232 6,063,443 29,802 Canada 107,054 238,117 * 1,227 Latin America, total 399,454 444,300 * 530 Mexico 109,216 191,862 * 352 Central America, total 15,852 22,742 -- Belize -- * 54 -- Costa Rica 5,066 * 999 -- El Salvador 2,166 * 1,584 -- Guatemala 4,799 * 8,718 -- Honduras 926 * 1,625 -- Nicaragua * 171 * 178 -- Panama 2,723 * 7,984 -- Caribbean countries, total 2,867 23,821 * 170 Cayman Islands (British) -- -- -- Dominican Republic 1,694 * 11,467 * 170 Haiti * 32 * 1,011 -- Jamaica 814 4,794 -- Trinidad and Tobago * 230 * 6,142 -- Other Caribbean countries * 97 * 406 -- South America, total 265,583 205,874 * 8 Argentina 74,345 72,001 -- Bolivia * 217 * 2,391 -- Brazil 96,708 21,257 -- Chile 26,790 * 7,242 -- Colombia 26,346 55,034 -- Ecuador 5,555 * 675 * 8 Paraguay * 434 * 7,732 -- Peru 10,690 5,069 -- Uruguay 3,057 * 2,750 -- Venezuela 21,441 15,209 -- Other South America (1) * 16,515 -- Latin America not allocable * 5,937 -- -- Other Western Hemisphere, total * 171 * 3,051 * 130 Bahamas -- -- -- Bermuda -- -- -- Netherlands Antilles -- * 1,225 -- Other British West Indies * 31 * 555 * 130 All other Western Hemisphere * 140 * 1,271 -- Europe, total 330,447 2,046,379 * 4,759 European Union, total 284,990 1,324,405 * 3,666 Austria 1,339 * 6,331 -- Belgium 5,162 76,062 * 797 Denmark * 33 43,083 -- Finland 7,147 * 166 -- France 68,498 20,878 * 2,082 Germany 1,140 157,090 -- Greece 1,567 10,356 -- Ireland * 1,039 * 669 -- Italy 90,059 158,936 -- Luxembourg -- -- * 132 Netherlands 8,357 35,397 * -355 Portugal 17,218 5,151 -- Spain 70,087 22,956 -- Sweden * 1,705 7,434 -- United Kingdom 11,567 779,896 * 1,010 Other European Economic Community * 73 -- -- Other West European countries, total 25,007 686,528 * 975 Liechtenstein -- -- -- Monaco -- -- -- Norway * 28 657,014 * 2 Switzerland * 212 11,865 * 973 Turkey 24,721 * 17,614 -- Other West European countries * 47 * 35 -- West European countries not allocable -- -- -- East European countries, total 20,332 33,417 * 81 Romania 2,025 * 3,819 -- Former Soviet Union 1,652 25,264 * 81 Other East Europe 16,655 * 4,334 (1) Europe not allocable * 117 * 2,030 * 36 Africa, total 34,280 375,832 -- North Africa, total 2,881 26,645 -- Algeria * 57 * 6,994 -- Egypt 2,566 * 15,326 -- Libya -- -- -- Morocco * 216 * 2,766 -- Other North Africa * 42 * 1,558 -- East Africa, total 1,509 * 6,156 -- Ethiopia -- * 2,012 -- Kenya * 807 * 4,082 -- Tanzania * 263 -- -- Uganda * 200 -- -- Other East Africa * 238 * 62 -- West and Central Africa, total 1,133 340,913 -- Gabon -- * 1,511 -- Ghana * 90 -- -- Liberia -- -- -- Nigeria * 479 * 239,673 -- Zaire -- -- -- Other West and Central Africa * 564 99,729 -- Southern Africa, total 28,758 2,118 -- Malawi -- -- -- Zimbabwe 439 -- -- South Africa (including Namibia) 22,921 * 1,916 -- Zambia * 4 * 202 -- Other Southern Africa * 5,394 -- -- Africa not allocable -- -- -- Asia, total 1,048,674 2,503,082 * 13,036 Middle East, total 31,083 231,876 * 1,625 Bahrain * 1 -- -- Iran -- -- -- Iraq -- -- -- Israel 25,361 * 439 -- Kuwait * 50 * 4,098 * 142 Lebanon * 36 * 818 -- Qatar -- * 2,444 -- Saudi Arabia 4,794 188,481 * 1,484 United Arab Emirates * 337 30,958 -- Other areas of the Arabian Peninsula * 198 * 1,723 -- Other Middle East 306 * 2,916 -- Southern and Southeast Asia, total 138,190 1,093,519 * 268 Bangladesh -- * 6,164 -- India 9,635 131,869 -- Indonesia 12,431 690,374 * 16 Malaysia 16,879 5,592 * 32 Pakistan * 174 * 41,150 -- Philippines 13,732 66,859 * 136 Singapore 60,400 57,435 -- Sri Lanka * 72 * 1,709 -- Thailand 24,788 79,529 * 80 Vietnam * 69 * 479 * 5 Other Southern and Southeast Asia * 10 * 12,359 -- Eastern Asia, total 879,401 1,177,687 * 11,143 China 62,581 85,059 -- Hong Kong 8,081 119,974 * 2,386 Japan 670,584 687,677 * 8,493 South Korea 29,055 4,571 * 61 Taiwan 109,100 280,406 * 203 Other Eastern Asia (1) -- -- Asia not allocable -- -- -- Oceania, total 95,598 127,147 (1) Australia 67,484 115,105 (1) New Zealand 27,461 10,196 (1) Other Oceania * 654 * 1,846 -- Puerto Rico and U.S. Possessions, total 68,380 73,708 -- Puerto Rico 67,715 57,916 -- U.S. Possessions, total * 665 15,791 -- American Samoa -- * 684 -- Guam * 94 12,612 -- Virgin Islands * 571 2,352 -- Other U.S. Possessions -- * 143 -- Country not stated 154,172 251,829 10,120 Foreign Sales Corporation dividends (2) -- -- -- Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- Foreign income and taxes reported on Form 1118 Foreign taxes paid, accrued, and deemed paid Foreign taxes paid or accrued Other taxes paid or accrued on-- Service Other Taxes Selected country income income deemed paid (22) (23) (24) All countries 292,786 4,024,468 29,022,856 Canada 28,563 111,851 4,788,581 Latin America, total 66,044 619,437 2,160,031 Mexico 14,854 46,289 687,938 Central America, total 3,799 3,551 48,762 Belize -- -- * 64 Costa Rica * 227 * 1,835 3,579 El Salvador * 73 * 794 * 2,965 Guatemala * 2,680 * 603 8,462 Honduras * 700 * 56 * 3,795 Nicaragua * 33 * 42 * 5 Panama * 86 * 222 29,892 Caribbean countries, total 5,357 * 33,586 112,234 Cayman Islands (British) -- -- 60,340 Dominican Republic * 234 * 582 21,320 Haiti -- * 4,313 * 638 Jamaica * 815 * 579 * 4,892 Trinidad and Tobago * 3,822 * 28,112 * 6,574 Other Caribbean countries * 485 -- 18,470 South America, total 44,035 535,989 1,311,097 Argentina 21,018 71,244 195,085 Bolivia * 509 * 249 * 1,960 Brazil 12,872 108,579 908,341 Chile * 1,042 122,552 40,601 Colombia 2,184 159,214 60,648 Ecuador * 378 3,210 3,700 Paraguay -- * 10 * 716 Peru * 863 64,949 29,047 Uruguay * 110 * 95 6,521 Venezuela 5,059 5,888 62,798 Other South America (1) -- * 1,680 Latin America not allocable -- * 22 -- Other Western Hemisphere, total * 264 * 1,657 181,696 Bahamas -- -- 13,101 Bermuda -- -- 113,162 Netherlands Antilles -- * 510 33,526 Other British West Indies * 264 * 1,147 20,307 All other Western Hemisphere -- -- * 1,599 Europe, total 79,993 840,534 15,242,619 European Union, total 74,563 736,276 14,005,593 Austria -- * 983 128,066 Belgium * 2,213 71,956 706,151 Denmark * 4,819 * 174 85,071 Finland * 6 * 3,585 29,814 France 3,906 61,943 1,091,349 Germany 16,228 28,965 2,468,293 Greece * 85 -- 22,158 Ireland * 3,143 * 353 109,915 Italy * 2,540 27,062 1,073,049 Luxembourg * 247 -- 189,300 Netherlands * 1,506 55,664 2,511,828 Portugal * 250 * 1,467 52,967 Spain 1,319 8,010 534,569 Sweden * 1,050 554 300,474 United Kingdom 37,249 475,561 4,712,510 Other European Economic Community -- -- * 78 Other West European countries, total 3,086 53,915 1,129,357 Liechtenstein -- -- * 264 Monaco * 122 -- * 36 Norway * 478 * 31,752 256,494 Switzerland * 1,591 14,594 828,501 Turkey * 895 * 6.940 43,037 Other West European countries -- * 629 * 1,024 West European countries not allocable -- -- -- East European countries, total 2,344 50,342 107,569 Romania * 98 * 3 * 11,200 Former Soviet Union * 867 * 47,369 * 21,287 Other East Europe * 1,378 * 2,970 75,082 Europe not allocable -- -- -- Africa, total 10,589 182,439 322,168 North Africa, total 831 * 167,255 24,027 Algeria * 137 * 10,044 * 274 Egypt * 621 * 156,582 16,859 Libya -- -- -- Morocco * 69 * 555 * 3,557 Other North Africa * 5 * 73 * 3,337 East Africa, total * 425 * 4 12,301 Ethiopia -- -- -- Kenya * 418 * 4 * 4,295 Tanzania -- -- * 901 Uganda -- -- -- Other East Africa * 7 -- * 7,105 West and Central Africa, total * 1,652 * 8,229 208,553 Gabon -- * 271 * 879 Ghana -- -- * 9,857 Liberia -- -- * 14,762 Nigeria * 1,458 * 30 161,996 Zaire -- * 6,135 * 1,429 Other West and Central Africa * 194 * 1,792 * 19,631 Southern Africa, total * 7,681 * 6,952 77,286 Malawi -- -- * 809 Zimbabwe * 101 -- * 11,906 South Africa (including Namibia) * 7,217 * 6,952 62,853 Zambia -- -- * 1,434 Other Southern Africa * 364 -- * 285 Africa not allocable -- -- -- Asia, total 42,823 940,061 5,050,269 Middle East, total 9,396 161,809 152,430 Bahrain -- * 1 * 177 Iran -- -- (1) Iraq -- -- -- Israel * 10 2,366 43,604 Kuwait * 76 * 3,404 * 275 Lebanon -- -- * 72 Qatar -- * 300 -- Saudi Arabia * 8,733 * 27,744 35,795 United Arab Emirates -- * 23,564 * 231 Other areas of the Arabian Peninsula * 425 * 103,709 * 71,538 Other Middle East * 152 * 721 * 738 Southern and Southeast Asia, total 16,091 492,991 1,034,820 Bangladesh -- (1) -- India 2,963 6,197 26,997 Indonesia 3,329 320,993 370,595 Malaysia 629 140,513 86,993 Pakistan * 181 * 1,457 6,228 Philippines 3,562 5,836 125,538 Singapore 1,400 7,931 228,857 Sri Lanka * 15 -- * 723 Thailand 3,996 10,261 187,739 Vietnam * 17 (1) -- Other Southern and Southeast Asia -- * -196 * 1,151 Eastern Asia, total 17,336 285,232 3,863,012 China 2,232 5,107 22,572 Hong Kong * 440 173,121 190,547 Japan 7,736 92,408 3,372,016 South Korea 2,687 6,476 168,400 Taiwan 4,242 8,121 109,477 Other Eastern Asia -- -- -- Asia not allocable -- * 29 * 7 Oceania, total 7,252 750,466 924,224 Australia 4,800 711,844 677,609 New Zealand * 1,714 1,498 236,054 Other Oceania * 738 * 37,124 * 10,562 Puerto Rico and U.S. Possessions, total 8,809 32,456 83,810 Puerto Rico 7,805 27,875 80,897 U.S. Possessions, total 1,004 4,581 2,913 American Samoa * 86 -- -- Guam * 669 4,552 * 1,109 Virgin Islands * 249 * 10 * 1,222 Other U.S. Possessions -- * 19 * 583 Country not stated 46,449 545,564 269,455 Foreign Sales Corporation dividends (2) -- -- * 102 Interest-Charge Domestic International Sales Corporation dividends (2) -- -- -- * Data should be used with caution because of the small number of returns on which they are based. (1) Less than $500. (2) Dividends from an Interest-Charge Domestic International Sales Corporation or a Foreign Sales Corporation were not reported for specific foreign countries. (3) Included in gross income (less loss), columns 2-8 (4) Included in total deductions, columns 12. NOTE: Detail may not add to totals because of rounding. Figure A U.S. Corporation Returns with a Foreign Tax Credit: Income Subject to U.S. Tax, Foreign-Source Taxable Income, Current-Year Foreign Taxes, and Foreign Tax Credit, Tax Years 1993-1997 (Money amounts are in millions of dollars) U.S. income tax before credits As a Number of Income percentage Tax year U.S. subject to Amount of income corporation U.S. tax (1) subject to returns U.S. tax (1) (2) (3) (4) 1993 6,322 228,688 81,913 35.8 1994 7,199 255,439 90,786 35.5 1995 6,710 303,308 107,996 35.6 1996 6,100 370,049 130,748 35.3 1997 6,569 410,126 144,779 35.3 Foreign-source taxable income Current-year (less loss) (2) foreign taxes As a As a percentage percentage of foreign- Tax year Amount of income Amount source subject to taxable U.S. tax income (3) (5) (6) (7) (8) 1993 94,687 41.4 23,716 25.0 1994 101,521 39.7 26,470 26.1 1995 120,518 39.7 30,930 25.7 1996 150,826 40.8 41,177 27.3 1997 157,989 38.5 45,080 28.5 Foreign tax credit claimed As a percentage Tax year Amount of U.S. income tax before credits (9) (10) 1993 22,895 28.0 1994 25,419 28.0 1995 30,416 28.2 1996 40,255 30.8 1997 42,223 29.2 (1) "Worldwide taxable income" is used interchangeably with "Income subject to U.S. tax." (2) Before adjustments. (3) The percentages shown in this column are not effective tax rates. An effective tax rate would contain a measure of economic income in the denominator and taxes on that income in the numerator. The percentages shown here are simply a tool used to determine what factors contributed to the relatively constant proportion of foreign tax credits to U.S. tax liability over the 1993-1997 period. Figure B U.S. Corporation Returns with a Foreign Tax Credit: Foreign-Source Taxable Income, Current-Year Foreign Taxes, Carryover and Foreign Tax Credit, by Selected Separate Limitation Category, Tax Year 1997 [Money amounts are in thousands of dollars] Foreign-source Selected category taxable income Current-year (less loss) (1) foreign taxes (1) (2) All separate limitation categories (3) 157,989,290 45,079,798 Passive income 5,516,127 753,440 High withholding tax interest 1,049,945 248,216 Financial services income 32,390,150 6,948,651 Shipping income 1,763,587 96,940 General limitation income 113,077,355 35,481,821 Current- year foreign taxes as a per- Foreign centage tax Selected category of Carryover credit foreign- claimed source taxable income (2) (3) (4) (5) All separate limitation categories (3) 28.5 7,416,008 42,222,743 Passive income 13.7 38,315 695,627 High withholding tax interest 23.6 105,625 211,666 Financial services income 21.5 658,425 6,927,742 Shipping income 5.5 37,507 124,862 General limitation income 31.4 6,072,479 32,948,387 (1) Before adjustments. (2) The percentages shown in this column are not effective tax rates. An effective tax rate would contain a measure of economic income in the denominator and taxes on that income in the numerator. (3) Sum of detail does not equal total for these columns because only selected categories are shown. Figure C U.S. Corporation Returns with a Foreign Tax Credit: Foreign-Source Taxable Income, Current-Year Foreign Taxes, and Foreign Tax Credit, by Selected Industrial Group, Tax Year 1997 [Money amounts are in millions of dollars] Foreign- source Current- Foreign Number taxable year tax Selected industrial group of income foreign credit returns (less taxes claimed loss) (1) (1) (2) (3) (4) All industries 6,569 157,989 45,080 42,223 Agriculture, forestry, and fishing 134 140 34 35 Mining 133 3,159 1,298 907 Construction 183 155 48 44 Manufacturing 1,763 102,821 32,401 30,299 Food and kindred products 83 9,057 2,913 2,801 Petroleum (including integrated) and coal products 28 19,801 7,387 6,748 Electrical and electronic equipment 327 13,430 3,205 2,963 Motor vehicles and equipment 27 7,730 2,397 2,381 Transportation and public utilities 159 5,373 872 803 Wholesale and retail trade 1,193 5,778 1,657 1,383 Finance, insurance, and real estate 1,676 31,905 6,573 6,655 Banking 92 13,226 3,281 3,337 Insurance 297 9,722 1,484 1,553 Services 1,329 8,658 2,196 2,097 (1) Before adjustments. NOTE: Industrial group detail may not add to the total for "All industries" because of rounding. Figure D Selected Industry Shares of Total Foreign Tax Credit Claimed, Selected Tax Years Industry's percentage share of foreign tax credit Selected industrial group 1990 1992 1994 1996 1997 (1) (2) (3) (4) (5) All industries 100.0 100.0 100.0 100.0 100.0 Agriculture, forestry, and fishing 0.1 0.2 0.2 0.2 0.1 Mining 3.2 2.8 2.6 2.3 2.1 Construction 0.4 0.4 0.3 0.5 0.1 Manufacturing 83.1 71.4 70.0 72.5 71.8 Food and kindred products 3.7 6.0 5.5 5.7 6.6 Petroleum (including integrated) and coal products 21.5 20.3 17.1 19.0 16.0 Electrical and electronic equipment 4.8 4.1 5.2 5.6 7.0 Motor vehicles and equipment 6.9 1.2 6.7 5.7 5.6 Transportation and public utilities 0.6 2.2 3.8 1.1 1.9 Wholesale and retail trade 3.7 5.8 4.3 3.2 3.3 Finance, insurance, and real estate 6.6 14.7 14.5 15.5 15.8 Banking 2.1 8.1 7.6 6.7 7.9 Insurance 2.5 3.5 4.0 3.6 3.7 Services 2.4 2.6 4.3 4.7 5.0 NOTE: Detail may not add to totals because of rounding. Figure E U.S. Corporation Returns with a Foreign Tax Credit: Foreign Oil and Gas Extraction Gross Income by Selected Industrial Group and Selected Country, Tax Year 1997 [Money amounts are in millions of dollars] Gross Percentage Selected industrial group, country income of total (less loss) Selected industrial group: All industries 21,014 100.0 Petroleum (including integrated) and coal products manufacturing 17,349 82.6 Oil and gas extraction 2,037 9.7 Industrial plastics and synthetic materials manufacturing 1,395 6.6 All other industries 233 1.1 Selected country: All countries 21,014 100.0 United Kingdom 4,571 21.8 Indonesia 1,749 8.3 Norway 1,467 7.0 Australia 1,438 6.8 Netherlands 1,175 5.6 Malaysia * 751 * 3.6 Canada * 725 * 3.5 Nigeria * 668 * 3.2 Thailand * 570 * 2.7 Saudi Arabia * 524 * 2.5 Trinidad and Tobago * 509 * 2.4 Colombia * 469 * 2.2 Former Soviet Union * 408 * 1.9 All other countries 5,990 28.5 * Data should be used with caution because of the small number of returns on which they are based. Figure G U.S. Corporation Returns with a Foreign Tax Credit: Foreign-Source Taxable Income (Less Loss), by Selected Industrial Group and Selected Country, Tax Year 1997 [Money amounts in thousands of dollars] United Selected industrial group All countries Kingdom Canada (1) (2) (3) All industries 157,989,290 25,205,763 15,906,555 Mining 3,159,297 450,420 190,264 Manufacturing 102,821,437 14,471,963 11,217,218 Food and kindred products 9,057,195 3,302,888 491,866 Industrial plastics and synthetic materials 5,807,726 870,459 627,733 Drugs 7,792,900 781,170 278,818 Petroleum (including integrated) and coal products 19,801,407 4,471,913 1,291,767 Office, computing, and accounting equipment 10,424,085 558,679 1,851,630 Electrical and electronic equipment 13,430,204 1,901,263 789,225 Motor vehicles and equipment 7,730,127 390,522 2,485,579 Transportation and public utilities 5,372,629 390,968 508,782 Wholesale and retail trade 5,777,769 719,951 646,716 Finance, insurance, and real estate 31,905,032 8,422,474 2,649,727 Banking 13,225,653 4,286,312 198,576 Insurance 9,722,081 1,206,669 2,213,080 Services 8,657,696 739,088 648,697 Other 295,430 10,899 45,151 Selected industrial group Japan Netherlands (4) (5) All industries 11,976,713 8,607,060 Mining * 2,156 107,892 Manufacturing 8,290,499 6,773,893 Food and kindred products 764,959 512,180 Industrial plastics and synthetic materials 389,755 544,675 Drugs 615,808 694,541 Petroleum (including integrated and coal products 435,419 1,891,428 Office, computing, and accounting equipment 2,150,304 933,701 Electrical and electronic equipment 1,917,387 630,498 Motor vehicles and equipment 394,126 133,366 Transportation and public utilities 17,095 51,451 Wholesale and retail trade 611,128 159,045 Finance, insurance, and real estate 1,584,750 403,484 Banking 417,785 118,289 Insurance 1,082,238 182,532 Services 1,465,464 1,106,764 Other 5,621 4,531 Selected industrial group Germany Rest of world (6) (7) All industries 8,553,809 87,739,390 Mining * 5,458 2,403,107 Manufacturing 6,246,336 55,821,528 Food and kindred products 523,013 3,462,289 Industrial plastics and synthetic materials 770,802 2,604,302 Drugs 777,938 4,644,625 Petroleum (including integrated and coal products 131,167 11,579,713 Office, computing, and accounting equipment 456,220 4,473,551 Electrical and electronic equipment 566,404 7,625,427 Motor vehicles and equipment 622,613 3,703,921 Transportation and public utilities 63,716 4,340,617 Wholesale and retail trade 874,539 2,766,390 Finance, insurance, and real estate 919,917 17,924,680 Banking 359,955 7,844,736 Insurance 145,437 4,892,125 Services 435,114 4,262,569 Other 8,729 220,499 * Data should be used with caution because of the small number of returns on which they were based. Figure I U.S. Corporation Returns with a Foreign Tax Credit: Taxable Income (Less Loss) from Foreign Branches, by Selected Country, Tax Year 1997 [Money amounts in thousands of dollars] Manufacturing Selected country All industries Petroleum All other (1) (2) (3) All countries 56,299,939 9,596,777 6,992,156 Australia 1,946,472 1,259,683 322,296 Bahamas 1,289,206 144,147 354 Brazil 1,312,350 38,401 10,328 Germany 1,291,197 81,159 878,999 Hong Kong 2,722,824 14,091 174,407 Japan 6,588,763 12,118 200,752 Mexico 1,390,768 2,607 837,991 Netherlands 2,383,480 1,659,538 543,369 Singapore 1,685,507 11,545 4,390 United Kingdom 14,557,160 3,206,181 187,186 Selected country Banking Insurance All other (4) (5) (6) All countries 29,214,315 5,828,794 4,667,897 Australia 277,141 25,500 61,852 Bahamas 1,144,666 -- 39 Brazil 1,226,944 -64 36,741 Germany 217,077 11,037 102,925 Hong Kong 2,253,983 60,828 219,515 Japan 1,273,599 4,993,482 108,812 Mexico 422,352 12,706 115,112 Netherlands 81,325 12,641 86,607 Singapore 1,558,983 689 109,900 United Kingdom 9,696,359 213,015 1,254,419 Figure J Coefficients of Variation for Foreign Tax Credit, by Selected Industrial Group, Tax Year 1997 Coefficients of variation for Selected industrial group foreign tax credit (percentages) All industries 0.04 Agriculture, forestry, and fishing 0.77 Mining 0.53 Construction 8.14 Manufacturing 0.02 Food and kindred products 0.01 Industrial, plastics, and synthetic materials 0.05 Drugs 0.05 Petroleum (included integrated) and coal products 0.02 Office, computing and accounting equipment 0.01 Electrical and electronic equipment 0.05 Motor vehicles and equipment (1) Transportation and public utilities 0.52 Wholesale and retail trade 0.50 Finance, insurance, and real estate 0.13 Banking (1) Insurance 0.15 Services 0.37 (1) Less than .005 percent.
Notes and References
[1] See Ward, Nick, "Corporate Foreign Tax Credit, 1996: An Industry and Geographic Focus," Statistics of Income Bulletin, Summer 2000, Volume 20, Number 1.
[2] Because income tax returns for FSC's were not included in the sample used for the statistics, this income category is not included. However, distributions from FSC's or former FSC's are reported on the parent corporation's return and are included in these statistics when provided by the taxpayers. In this study, this particular statutory category is used when corporations report an irregular separate category of income that cannot be redefined for one of the existing categories of income.
[3] No foreign tax credit is allowed for foreign taxes paid to certain sanctioned countries. However, a foreign tax credit limitation is computed for each such country. The sanctioned countries for 1997 are Cuba, Iran, Iraq, Libya, North Korea, Sudan, and Syria.
[4] According to Internal Revenue Code section 999, U.S. persons that participate or cooperate in international boycotts that are not sanctioned by U.S. law, regulation, or executive order are penalized under the boycott provisions. Under these boycott provisions, the penalty includes a reduction of foreign tax credits, an increase in Controlled Foreign Corporation's taxable income under Subpart F, and a reduction in Foreign Sales Corporation (FSC) benefits and Interest-Charge Domestic International Sales Corporations (IC-DISC) benefits, as applicable. For more information on International Boycotts, see Daly, Susan M., "International Boycott Reports, 1997 and 1998," Statistics of Income Bulletin, Winter 2000-2001, Volume 20, Number 3.
[5] U.S. corporations are subject to a graduated tax rate based on their taxable income per Internal Revenue Code section 11 and Internal Revenue Code section 1201. For 1997, the corporation tax rate was 15 percent on the first $50,000 of taxable income, 25 percent on the next $25,000, 34 percent on taxable income between $75,000 and $10 million, and 35 percent on the excess over $10 million. However, a 5-percent tax was imposed on taxable income between $100,000 and $335,000 in order to phase out the benefit of the lower rates for high-income corporations; thus, the total marginal rate in this income range is 39 percent. Similarly, a 3-percent tax was imposed on taxable income between $15 million and $18.3 million resulting in a total marginal rate in this income range of 38 percent.'
[6] U.S. corporations included in the SOI annual study vary from one year to the next. The analysis of the foreign tax credit over time is not based on a panel of corporations. Therefore, "growth" may be due to several factors, including a different makeup of firms in each year.
[7] Current-year foreign taxes as a percentage of foreign-source taxable income should not be construed as a measure of the effective tax rate. An effective tax rate would contain a measure of economic income in the denominator and taxes on that income in the numerator. These percentages are simply a tool used to compare the proportion of taxes to foreign-source taxable income in each statutory group.
[8] The majority of Netherlands-sourced taxable income from non-manufacturing U.S. corporations was from services.
[9] A U.S. corporation, which received actual or constructive dividends from a related foreign subsidiary, is allowed to include a portion of the foreign taxes paid by the subsidiary for purposes of determining the foreign tax credit. Under Internal Revenue Code section 902(a), the portion of foreign taxes deemed paid by a U.S. parent corporation equals the product of the foreign income taxes multiplied by the ratio of dividends to undistributed earnings. The purpose of this formula is to allocate a portion of the foreign income taxes paid by a foreign subsidiary to the dividend distribution. The term "undistributed earnings" refers essentially to the corporation's earnings and profits accumulated through the current year. The foreign taxes paid by the foreign subsidiary are considered to be indirectly, or deemed, paid by the related U.S. corporation.
[10] Four of these countries (Germany, Japan, the Netherlands, and the United Kingdom) were included in the five largest countries in terms of taxable income. Recall that the five largest countries accounted for approximately 42.2 percent of the total taxable income. More than half of U.K.-sourced and Japan-sourced taxable income is from U.S. corporations operating through foreign branches in these countries. As expected, the industry composition for these countries closely resembles the industry composition of the foreign branches operating in these countries.
[11] Internal Revenue Service, Statistics of Income--1997, Corporation Income Tax Returns, Publication 16, Rev. 9-2000.
Kathryn A. Green is a statistician with the Special Studies Returns Analysis Section. Scott Luttrell is an economist with the Special Studies Returns Analysis Section. This article was prepared under the direction of Chris R. Carson, Chief.
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