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Official form guide
Form 8991: Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts
IRS Form 8991 is the Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts. It calculates a corporation’s base erosion minimum tax and must be attached to the income tax return and filed by the return’s due date (including extensions).
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IRS Form 8991 - Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts
IRS Form 8991 is the Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts. It calculates a corporation’s base erosion minimum tax and must be attached to the income tax return and filed by the return’s due date (including extensions).
Risk Radar
Scan points- 1Skipping required parts by answering “No” on line 2p when the tax applies.
- 2Entering “No” on line 2p when the corporation is subject, causing required parts to be omitted.
- 3Leaving any entry space blank or writing “See Attached” instead of the required data.
- 4Combining base‑erosion tax benefits that have different withholding rates on Schedule A.
- 5Failing to attach Schedule B when deductions are being waived for the tax year.
Plain English
Form 8991 tells the IRS how much tax a large corporation owes because of payments that lower its U.S. tax bill. It reports the payments, the tax benefits you get from them, and your modified taxable income. The form is sent with your regular tax return.
Submission Date
- Filing date: 2026-01-16 17:10:53
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when a corporation (not a RIC, REIT, or S corporation) has annual gross receipts of at least $500 million in one or more of the three preceding tax years and needs to calculate its base erosion minimum tax.
- Do not use it when the filer is a regulated investment company, a real estate investment trust, or an S corporation.
- Check Form 5472 instead when reporting information required of a 25% foreign‑owned U.S. corporation.
Form selector
Use this form or another form?
Corporation with gross receipts under $500 million
Base erosion filing not required
✓ Verify gross receipts threshold
25% foreign‑owned U.S. corporation required to report information
Separate information return for foreign ownership
✓ Confirm foreign ownership status
Corporation filing Form 1120‑C with Schedule K items related to base erosion
Includes specific questions/items referenced for gross receipts determination
✓ Confirm related Schedule K items
Deadline or filing window
The filing is triggered when the taxpayer files the income‑tax return. The form must be attached and filed by the return’s due date, including any extensions granted for that return. No separate extension period is provided for Form 8991.
Checklist
What you need before filling it out
Part I lines 1a‑1g (gross receipts)
Annual gross receipts figures for the past 3 years · Form 1120, Schedule K items
Schedule A line 2 (cost‑sharing payments)
Details of cost‑sharing transactions per Reg 1.482‑7(b)(1)(i) · Corporation’s cost‑sharing agreements
Schedule B (deductions waived)
List of deductions being waived for the tax year · Internal accounting records
Corrected Form indicator
Statement identifying changes and “Corrected” label · Prior filed Form 8991 copy
Filer’s name and EIN on attachments
Employer Identification Number and legal name · Form 8991 header
Before you submit
- 1Verify the form edition is the December 2024 revision.
- 2Confirm the corporation meets the $500 million gross receipts threshold.
- 3Complete every applicable entry space; do not use “See Attached”.
- 4Enter the filer’s name and EIN on the form and all attachments.
- 5Attach Schedule A and Schedule B with required details.
- 6Include any required supporting statements, ensuring name and EIN appear on each.
- 7If filing a corrected return, write “Corrected” at the top and attach a change statement.
- 8Attach Form 8991 to the income tax return (or exempt organization return) and file by the due date (including extensions).
How to file this form
- 1Determine eligibility based on the $500 million gross receipts test.
- 2Gather required financial data and complete Part I, Schedule A, and Schedule B on Form 8991.
- 3Attach any supporting statements, ensuring the filer’s name and EIN appear on each.
- 4If amending, mark “Corrected” at the top and attach a statement identifying changes.
- 5Attach Form 8991 to the corporate income tax return (or exempt organization business income tax return).
- 6Submit the return with Form 8991 by the due date (including extensions) and retain a copy for records.
Known limitations
- 1Corporations that are regulated investment companies (RICs) are not required to file Form 8991 — Instructions p.4
- 2Real estate investment trusts (REITs) are not required to file Form 8991 — Instructions p.4
- 3S corporations are not required to file Form 8991 — Instructions p.4
- 4Corporations with annual gross receipts below $500 million in each of the three preceding tax years are not required to file Form 8991 — Instructions p.4
- 5If the filer checks “No” on line 1g, the corporation is not subject to the tax and does not complete the remaining lines — Instructions p.5
Field map
Compact field-by-field guide
Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
Almost done reviewing the fields?
Fillable formOpen in Editor->The current edition is the December 2024 revision of Form 8991; the instructions direct users to the IRS.gov/Form8991 page for the latest information, and note that a new line 2 for cost‑sharing transaction payments has been added.
What changed or needs a fresh check
- Edition date — confirm the form is the December 2024 revision.
- Fee — Not stated in the official source
- Mailing address — Not stated in the official source
- Signature — Not stated in the official source
Quick Facts
Downloads
After you file
- 1Retain a complete copy of the filed Form 8991 with the corporate tax return records
- 2Store the copy for at least three years after the filing year, as required for corporate tax documentation
- 3Expect the IRS to acknowledge receipt through the processing of the attached income tax return
- 4If an error is discovered after filing, file an amended return with a corrected Form 8991 attached
Sources
- SRCInstructions p.4 — RICs, REITs, and S corporations are excluded from filing
- SRCInstructions p.4 — $500 million gross receipts threshold applies
- SRCInstructions p.5 — Checking “No” on line 1g removes filing requirement
- SRCInstructions p.4 — Attach Form 8991 to income tax return and file by the return’s due date
- SRCInstructions p.4 — Do not enter “See Attached” or “Available Upon Request” in entry spaces
- SRCInstructions p.4 — Attach separate sheets using same size and format if more space is needed
- SRCInstructions p.5 — Average gross receipts calculation for entities not existing full three years
- SRCInstructions p.10 — Research credit from Form 3800 is used on Form 8991 line 3
Common confusion points
Do I need to file if I'm a REIT?
The source lists REITs as an exception to filing.
→ Verify that the entity classification is REIT on the corporate charter before skipping the form — Instructions p.4
My corporation’s gross receipts are $480 million; do I still have to file?
The filing threshold is $500 million in any of the three preceding years.
→ Confirm the aggregate gross receipts for each of the three years are below $500 million — Instructions p.4
Should I answer Yes or No on line 1g?
Line 1g determines whether the corporation is subject to the tax; a “No” means no further filing required.
→ Check the response on line 1g; if “No,” stop completing the form — Instructions p.5
How do I calculate average gross receipts if the corporation wasn’t in existence for the full three‑year period?
The instructions require an average based on the period the corporation existed.
→ Use the average gross receipts method described in Regulations section 1.59A-2(d)(2) — Instructions p.5
Can I write “See Attached” in empty entry spaces?
The instructions explicitly prohibit using “See Attached” in place of completing entry spaces.
→ Fill every applicable entry space; do not use placeholder text — Instructions p.4
What if I run out of space on the form?
The instructions allow attaching separate sheets that match the form’s size and format.
→ Attach additional sheets in the same format and continue numbering sequentially — Instructions p.4
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Questions about IRS Form 8991
What is IRS Form 8991 used for?
Form 8991 tells the IRS how much tax a large corporation owes because of payments that lower its U.S. tax bill. It reports the payments, the tax benefits you get from them, and your modified taxable income. The form is sent with your regular tax return.
Who must file IRS Form 8991?
Corporations, including foreign corporations engaged in a U.S. trade or business, that have substantial gross receipts and are subject to the base erosion tax must file Form 8991.
What information does IRS Form 8991 require?
The form collects the taxpayer’s modified taxable income (Part II, line 3a), the amount of base‑erosion payments and related tax benefits (Schedule A), and any deductions waived (Schedule B).
When is IRS Form 8991 due?
File Form 8991 by the due date (including extensions) for the income tax return to which it is attached.
How do I complete IRS Form 8991?
Attach Form 8991 to the appropriate income‑tax return (or exempt‑organization return) and complete every applicable entry space. If line 2p is “Yes,” fill Part II and the required schedules; if “No,” skip Parts II‑IV, complete Part V and Schedule A, and attach Schedule B only if needed. Do not use “See Attached” in any field and sign the return before mailing or e‑filing.
Do I need to file if I'm a REIT?
The source lists REITs as an exception to filing. Verify that the entity classification is REIT on the corporate charter before skipping the form — Instructions p.4
My corporation’s gross receipts are $480 million; do I still have to file?
The filing threshold is $500 million in any of the three preceding years. Confirm the aggregate gross receipts for each of the three years are below $500 million — Instructions p.4
Should I answer Yes or No on line 1g?
Line 1g determines whether the corporation is subject to the tax; a “No” means no further filing required. Check the response on line 1g; if “No,” stop completing the form — Instructions p.5
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