Forms, Schedules, and Instructions for U.S. Tax-Exempt Returns

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Instructions for Schedule C
(Form 1116)
(Rev. December 2025)

Foreign Tax Redeterminations
Section references are to the Internal Revenue Code
unless otherwise noted.

Future Developments
For the latest information about developments related to
Schedule C (Form 1116) and its instructions, such as
legislation enacted after they were published, go to
IRS.gov/Form1116.

What’s New

General Instructions
Continuous-use. Use the December 2025 revision of
Schedule C and these instructions for tax year 2025 and
subsequent years until a superseding revision is issued.

Purpose of Schedule

Schedule C (Form 1116) is used to identify foreign tax
redeterminations that occur in the current tax year in each
separate category, the years to which they relate, and
other information that satisfies your obligation to notify the
IRS of foreign tax redeterminations that occurred in the
current year that relate to prior years.
Use Part I to report foreign income tax redeterminations
that resulted in an increase in the amount of foreign
income taxes accrued and paid by the taxpayer.

Note: If you claim a credit for foreign income taxes on the
cash basis method of accounting (you checked the box for
“Paid” on Form 1116, Part II), and you pay additional
foreign income taxes that relate to a prior tax year, that
isn’t a foreign tax redetermination. You don’t report those
additional foreign income taxes paid in Part I of
Schedule C. You report those as foreign income taxes
paid on Form 1116, Part II, filed for the tax year in which
you paid the additional foreign income taxes. For
contested foreign income taxes, you may also need to
report those additional foreign income taxes paid in Part V
of Schedule C. See Part V, later.
Use Part II to report foreign tax redeterminations that
resulted in a decrease in the amount of foreign income
taxes paid or accrued by the taxpayer.
Use Part III to report foreign tax redeterminations that
resulted in a change in the amount of foreign income taxes
paid or accrued in any relation back year.
Use Part IV to report foreign tax redeterminations that
resulted in a change in the U.S. tax liability for any relation
Oct 27, 2025

Who Must File

Any taxpayer that has a foreign tax redetermination under
section 905(c) must complete this schedule and attach it
to the U.S. income tax return for the tax year in which the
foreign tax redetermination occurs. This schedule must be
filed irrespective of whether the foreign tax
redetermination changed your U.S. tax liability.
Note: If your U.S. tax liability for any year changes by
reason of the foreign tax redetermination, you must file an
amended return for the tax year with respect to which the
U.S. tax liability is adjusted, in addition to filing Schedule C
for the year in which the foreign tax redetermination
occurs. See Foreign Tax Redeterminations in the
Instructions for Form 1116 for additional information
regarding foreign tax redeterminations that result in a
change in U.S. tax liability and the related reporting
requirements.
If a foreign tax redetermination doesn’t change the
amount of U.S. tax due for any tax year, you don’t need to
file an amended return. You satisfy your reporting
requirements under Regulations section 1.905-4(b)(1)(v)
with respect to the foreign tax redetermination by filing a
Schedule C with the return for the tax year in which the
foreign tax redetermination occurs.

Definitions
Foreign tax redetermination. A foreign tax
redetermination means a change in the liability for foreign
income taxes including if:
• Accrued foreign income taxes when paid or later
adjusted differ from the amounts claimed as credits
(including corrections to accrued amounts to reflect final
foreign income tax liability and additional payments of tax
that accrue after the close of the tax year to which the tax
relates);

Instructions for Schedule C (Form 1116) (Rev. 12-2025) Catalog Number 37575M
Department of the Treasury Internal Revenue Service www.irs.gov

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Schedule C has been revised. In Part V, previous
column 9 has been split into the following two columns.
• Column 9 requests tax refunded, if any.
• Column 10 requests additional tax paid, if any.

back year or other affected tax year(s) (for example, by
reason of a change in allowable foreign tax credit
carryovers).
Use Part V to satisfy the annual reporting requirement
under Regulations section 1.905-1(d)(4)(iv) for contested
foreign income taxes for which the taxpayer claimed a
provisional foreign tax credit. For each tax year following
the year in which a provisional foreign tax credit election is
made on Form 7204, Consent To Extend the Time To
Assess Tax Related to Contested Foreign Income
Taxes—Provisional Foreign Tax Credit Agreement, up to
and including the tax year in which the contest is resolved,
the taxpayer must provide the information requested in
Part V.

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• Accrued foreign income taxes aren’t paid within 24
months after the close of the tax year to which they relate;
or
• Any foreign income tax paid is fully or partially
refunded.
Relation back year. Relation back year means the U.S.
tax year in which the foreign income taxes being
redetermined were originally taken into account.
Example. In U.S. tax year 1, you took into account $2
million of Country X foreign income taxes accrued with
respect to the foreign tax year that ended within U.S. tax
year 1. In year 3, Country X assessed an additional $1
million of foreign income taxes with respect to the foreign
tax year that ended within U.S. tax year 1. The relation
back year is U.S. tax year 1.

Functional currency. Functional currency means the
dollar, or in the case of a qualified business unit (QBU),
the currency of the economic environment in which a
significant part of such unit’s activities are conducted and
which is used by such unit in keeping its books and
records. See section 985(b).
Reference ID number for contested tax. See the
Instructions for Form 7204 for the definition of and
requirements for the reference ID number for contested
foreign income tax.

Specific Instructions
Important: All information reported on Schedule C must
be in English. All amounts must be stated in U.S. dollars,
unless otherwise specified on the schedule.
If there are more than three payor entities for a relation
back year, attach a statement that lists all information
requested on Schedule C for those payor entities following
the format of Schedule C. If there are more than 2 relation
back years (Parts I, II, III, or IV), there are other affected
years in addition to the relation back years (Part IV), or
more than 5 relation back years (Part V), attach a
statement that lists all information requested on
Schedule C for those years following the format of
Schedule C.
Checkboxes at top of page 1. Use a separate
Schedule C for each applicable category of income and
check the corresponding box. Check only one box for
each completed Schedule C.
See Categories of Income in the Instructions for Form
1116 for additional information regarding separate
categories. For country codes on lines (h) and (i), see
IRS.gov/CountryCodes for the code to use.
Parts I, II, III, and IV, column 1. In this column, enter the
ending date of the relation back year or affected year (Part
IV).
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Part I
Columns 4 and 5. Enter the date(s) the additional
foreign income taxes were paid and the ending date of the
foreign tax year to which such taxes relate.
Column 7. Enter the amounts of additional foreign
income tax accrued in the local currency in which the tax
is payable.
Column 8. Enter the amounts of the additional foreign
income tax denominated in the functional currency of the
payor that accrued the additional foreign income tax.
Column 13. Enter the reference ID number for the
contested foreign income tax, if applicable, using the
reference ID number reported on Form 7204 filed with
respect to the contested foreign income tax.

Part II
Columns 4 and 5. Enter the date(s) the foreign income
taxes were refunded or deemed refunded and the ending
date of the foreign tax year to which such taxes relate. If
the foreign income taxes are deemed refunded by reason
of the section 905(c)(2) 2-year rule described in the Note
in the instructions for column 13, enter in column 4 the
date that is 24 months after the close of the tax year to
which the foreign income taxes relate.
Column 7. Enter the amount of the foreign income tax
refunded or deemed refunded in the local currency in
which the foreign income tax is payable.
Column 8. Enter the amount refunded or deemed
refunded denominated in the functional currency of the
payor that paid or accrued the refunded amount.
Column 13. Check the box if the foreign tax
redetermination is a result of the application of the section
905(c)(2) 2-year rule.

Instructions for Schedule C (Form 1116) (Rev. 12-2025)

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Affected tax year. Affected tax year means any tax year
for which the U.S. tax liability is changed as a result of a
foreign tax redetermination. This includes tax years in
which the U.S. tax liability is changed as a result of a
change in a carryover of a tax attribute, such as a foreign
tax credit carryover or a net operating loss carryover, from
a relation back year.

Parts I and II, columns 2a and 2b. In columns 2a and
2b, enter the name and the employer identification number
(EIN) or reference ID of the payor. If you paid the tax
directly, enter your name. If the tax was paid by a
pass-through entity, such as a partnership, in which you
have an ownership interest, enter the information for that
entity.
For additional information on EINs and reference IDs,
see Reference ID numbers in the Instructions for Form
1118.
Parts I and II, column 3. Enter the code for the
country or U.S. possession to which tax is paid using the
country codes provided at IRS.gov/CountryCodes.
Parts I and II, column 6. Enter the payor’s income
subject to tax in the foreign jurisdiction, as reported on the
foreign tax return.
Parts I and II, column 9. Enter the exchange rate
originally used to convert the local currency (in which the
redetermined foreign tax was paid) to U.S. dollars.
Parts I and II, column 11. Enter the U.S. dollar
amount of foreign income tax of each payor that was
reported by the taxpayer on its original or amended return
(not taking into account the foreign tax redetermination).

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Note: Under section 905(c)(2), if accrued foreign income
taxes aren’t paid on or before the date that is 24 months
after the close of the tax year to which they relate (2-year
rule), there is a resulting foreign tax redetermination that is
accounted for as if the unpaid portion of the foreign
income taxes were refunded on that date. Credit may be
claimed for those taxes if and when they are ultimately
paid. Foreign income taxes that first accrue after the date
24 months after the close of the tax year to which the
taxes relate may not be claimed as a credit until paid.

Part III
Columns 2 and 3. Enter the redetermined foreign
income taxes paid or accrued and the foreign income
taxes paid or accrued per your original or previously
amended return.
Columns 4 and 5. Enter the total amount of foreign tax
credit claimed in the separate category on your original or
previously amended return and the total amount of foreign
tax credit claimed after the foreign tax redetermination.
Columns 2 through 4. Enter the total redetermined U.S.
tax liability, the total U.S. tax liability reported on your
original or previously amended return, and the difference
(subtracting column 3 from column 2) for each affected tax
year.

Part V
Column 1. For taxpayers that claim credits on the accrual
basis, enter the relation back year. For taxpayers that
claim credits on the cash basis, enter the year in which the
contested foreign income tax was remitted to the foreign
country. The tax year entered on column 1 should
correspond with the tax year entered on line 1 on Form
7204 that was filed in order to claim a provisional credit for
the contested foreign income tax.
Column 2. Enter the name of the payor. If you paid the
tax directly, enter your name. If the tax was paid by a
pass-through entity, such as a partnership, in which you
have an ownership interest, enter the name of that entity.
Column 3. Enter the reference ID number for the
contested foreign income tax that was used on Form
7204.
Columns 4 and 5. Enter the code of the country or U.S.
possession to which the tax was paid using the country

Instructions for Schedule C (Form 1116) (Rev. 12-2025)

Columns 6 and 7. Check the box in column 6 if the
contest is still ongoing and check the box in column 7 if
the contest was resolved.
Columns 8, 9, and 10. Enter in column 8 the date the
contest was resolved. Enter in column 9 the amount of tax
refunded, if any. Enter in column 10 the amount of
additional tax paid, if any. Any portion of a contested
foreign income tax for which a provisional credit is claimed
that is subsequently refunded results in a foreign tax
redetermination that must be reported on Schedule C and,
if applicable, an amended return for the tax year(s) for
which the U.S. tax liability changes as a result of such
foreign tax redetermination. Any additional foreign income
tax paid is a foreign tax redetermination only if you're an
accrual-basis taxpayer or if you elected to claim your
foreign tax credit on an accrual basis. See Note, earlier,
for more information about additional foreign income tax
payments when you claim a credit for foreign income
taxes on the cash basis method of accounting.

Additional Information

For more information, see section 905(c) and Regulations
sections 1.905-1, 1.905-3, 1.905-4, and 1.905-5.

Paperwork Reduction Act Notice.

We ask for the information on Schedule C to carry out the
Internal Revenue laws of the United States. You’re
required to provide this information. You’re not required to
provide the information requested on a form that is subject
to the Paperwork Reduction Act unless the form displays a
valid OMB control number. Books or records relating to a
form or its instructions must be retained as long as their
contents may become material in the administration of any
Internal Revenue law. Generally, tax returns and return
information are confidential, as required by Internal
Revenue Code section 6103. The time needed to
complete and file this form will vary depending on
individual circumstances. The estimated burden for
individual filers is approved under OMB control number
1545-0074, for tax-exempt filers under OMB control
number 1545-0047, and for trust filers under OMB control
number 1545-0092. For the estimated averages, see the
instructions for your income tax return.

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Part IV

codes provided at IRS.gov/CountryCode and the amount
of contested foreign income tax that was provisionally
claimed as credit.