1120-F Schedule Q Tax Liability of Qualified Derivatives Dealer (QDD)

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TREASURY/IRS AND OMB USE ONLY DRAFT
SCHEDULE Q
(Form 1120-F)

Tax Liability of Qualified Derivatives Dealer (QDD)

OMB No. 1545-0123

Attach to Form 1120-F.
Go to www.irs.gov/Form1120F for the latest information.

2025

Department of the Treasury
Internal Revenue Service
Name of corporation

Employer identification number

Name of QDD

QI-EIN

QDD Taxable Year (enter month, day, and year for beginning and ending dates)

Beginning

, 20

, and ending

, 20

Indicate the year or portion of the year to which the schedule relates (enter month, day, and year for beginning and ending dates)

Beginning

, 20

, and ending

DRAFT — DO NOT FILE

Schedule Q (Form 1120-F) was amended to reflect Notice 2024-44,
2024-25 I.R.B. 1737, which further delayed the effective/applicability
date of certain rules in the section 871(m) regulations and further
extended the phase-in period provided in Notice 2022-37, 2022-37
I.R.B. 234, for certain provisions of the section 871(m) regulations.

Who Must File
If the corporation or any branch of the corporation was a qualified
derivatives dealer (QDD) (defined below) during the tax year,
Schedule Q must be completed and filed for each of those QDDs.
The corporation must file Schedule Q as an attachment to Form
1120-F even if the QDD has zero tax liability.
Qualified derivatives dealer (QDD). A QDD is a home office or
branch that, in accordance with the qualified intermediary agreement
(QIA) (defined below), qualifies and has been approved for QDD
status and satisfies the requirements of the QIA. See the QIA for
additional information.

(c)
(b)
Withholding Tax Rate Amount of Tax Liability
(column (a) x column (b))

1
2
3
4

5a
5b
5c
5d
6

Number of schedules filed. A QDD may be required to file multiple
Schedules Q, for example, if it has multiple branches that are QDDs
or if it is a fiscal year taxpayer (as explained in General Instructions
above). Indicate the number of each Schedule Q filed, as well as the
total number of Schedules Q being filed by the corporation in the
entry spaces provided.
Column (c), Amount of Tax Liability. The amount in column (c) is
determined by multiplying column (a) by column (b). Exceptions can
be found in the Note that immediately follows this paragraph. This
column is not reduced by any withholding that has occurred.
Note: For calendar years 2018 through 2026, certain information is
not required, as indicated in the line instructions below. However, if
the corporation has a fiscal year (rather than a calendar year) that
begins in 2026 and ends in 2027, information is required for any
amounts paid or accrued on or after January 1, 2027.
Line 1. The gross amount to be entered in column (a) is the sum of
each section 871(m) amount for the QDD for the relevant period. See
section 2.73 of the QIA for the definition of section 871(m) amount.

Qualified intermediary agreement (QIA). The QIA is section 6 of
Rev. Proc. 2022-43, 2022-52 I.R.B. 570.

Note: For calendar years 2019 through 2026, this information is not
required.

General Instructions

Line 2. For calendar years 2019 through 2026, only the gross
amount (column (a)) and tax rate (column (b)) are required.

A separate Schedule Q is required for each QDD. In addition, if a
corporation has a fiscal year rather than a calendar year, the
corporation must provide a separate Schedule Q for each QDD for
each portion of the calendar year that falls within the fiscal year.

Line 3. Column (c) is the sum of each section 3.09(A) amount for the
QDD for the relevant period.

Example: A QDD with a fiscal year beginning September 1 and
ending August 31 would complete two schedules (one for the period
of September 1, 2025 through December 31, 2025, and one for the
period of January 1, 2026 through August 31, 2026).

Note: For calendar years 2019 through 2026, this information is not
required.
Line 4. Enter the information requested in columns (a), (b), and (c).

Specific Instructions

Line 5. In addition to specifying the type of income (for example,
dividends or interest), enter the information requested in columns (a),
(b), and (c) separately for each income type. For dividends, include
all dividends, including dividends separately stated on line 2.

Name of QDD. The name of the QDD should follow the naming
protocol used for applying to be a QDD.

Note: For calendar years 2019 through 2026, do not include
dividends included on line 2.

For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.

Cat. No. 71803X

Schedule Q (Form 1120-F) 2025 Created 7/30/25

DRAFT — DO NOT FILE

Total section 871(m) amount . . . . . . . . . . . .
Total dividends received in equity derivatives dealer capacity . .
Total QDD tax liability pursuant to section 3.09(A) of the Qualified
Intermediary Agreement . . . . . . . . . . . . . .
4
Total QDD tax liability pursuant to section 3.09(B) of the Qualified
Intermediary Agreement . . . . . . . . . . . . . .
5
Total QDD tax liability pursuant to section 3.09(C) of the Qualified
Intermediary Agreement:
a Income Type:
b Income Type:
c Income Type:
d Income Type:
6
Total of line 5 amounts . . . . . . . . . . . . . .

Reminder

of

, 20
(a)
Gross Amount

Summary of QDD Tax Liability
1
2
3

Schedule