Does Form 1116 Schedule B make the documentation and tracking of Foreign Tax Credit carryovers mandatory?
I have never bothered to enter any carryovers on F1116, Part III, Line 10 for any previous tax years or submitted any calculations of carryovers because I knew that my foreign taxes paid each year would always be more than my foreign tax credit limitations. Plus, I didn't use tax software for my US return until 5 years ago. So, I didn't feel it was worth all the manual effort and bookkeeping.
Now, there is a new F1116 Schedule B, which states "With respect to each separate category of income, if you are filing Form 1116 that has a foreign tax carryover in the prior tax year, the current tax year, or both, you must file Schedule B for that separate category of income.
I read the filing requirement above to mean that the F1116 Schedule B is only required if you include carryovers in your Form 1116 Part III calculations by entering an amount carried forward on Line 10 in the current year's F1116 or an amount carried backward on Line 10 of the previous year's F1116 or both. (*** Does anyone disagree with my interpretation? ***)
I will probably continue filing my Forms 1116 without using carryovers by deleting the data TTax transfer from the prior year's file and just omit the Schedule B from my paper filing.
But, if I were to decide to start filing F1116 Schedule B, should I only track my excess foreign tax carryovers beginning with last year, since I never entered the running total on Line 10 in Part III? Or should I enter all 10 years of old data into the F1116 worksheet? (*** Which option is the right choice from a compliance perspective? ***)