None had a Schedule B PDF attached. The fix took minutes, the lesson stuck for good. When you are buried in production, the small things are the big things, and Schedule B is one of those small things that decides whether your filing clears or rejects.
If you have prior‑year foreign tax credit amounts, you use Schedule B to keep those carryovers honest by basket and by year, and to make sure only the right dollars land on Form 1116, Part III, line 10. The rule set is simple on paper, one‑year carryback, ten‑year carryforward, oldest used first, but it is unforgiving in practice, especially when categories, AMT, and documentation split in different directions. The good news, once you lock a clean workflow, reviews move faster and e‑file errors disappear.
Key takeaways
- You use Schedule B to reconcile prior‑year foreign tax carryovers by separate category, then the total from Schedule B, line 3, column (xiv), flows to Form 1116, Part III, line 10. Attach Schedule B when you enter a prior‑year carryover or generate a carryover this year.
- Carry timing rules are fixed, use a one‑year carryback then a ten‑year carryforward, apply the oldest first, and never carry for section 951A category income.
- If Form 1116 line 10 is non‑zero, most software enforces an e‑file rule that requires a Schedule B PDF, or the return rejects with business rule F1116‑004‑02.
- Translate foreign taxes using IRS exchange‑rate rules, paid uses the rate on the date paid, accrual generally uses the average rate for the tax year if conditions are met, and keep the proof.
- The post‑2022 creditability landscape still reflects TD 9959, with temporary relief under Notice 2023‑55 as modified by Notice 2023‑80 and reflected in Pub. 514. Confirm your positions against current guidance.
What Schedule B actually does
Schedule B, officially the Foreign Tax Carryover Reconciliation Schedule, is a running ledger that connects what you brought into the year, what changed after last year’s filing, what you can use now under the limitation, what expires, and what you will carry into next year. Think of it as the control panel for Form 1116 line 10, organized by separate category. In the current instructions, IRS is explicit, use a separate Schedule B for each category you file on Form 1116, and report all figures in U.S. dollars and in English. The amount available for line 10 comes from Schedule B, line 3, column (xiv).
Schedule B also records whether you generated new excess foreign taxes this year. If you did, it shows the piece you plan to carry back to the immediately preceding year, and the remainder that will carry forward. That forward balance becomes the opening balance on next year’s Schedule B, which is why clean year‑over‑year mapping matters.
You can skip Schedule B only in a narrow case, if you are carrying back to the current year and do not otherwise have a carryover to or from the current year. Otherwise, attach it whenever you bring prior‑year amounts onto line 10, or you generate a new carryover this year.
Who must complete it
You must complete Schedule B when you have a foreign tax carryover in the prior year, the current year, or both, for any separate category you report on Form 1116. Create separate Schedules B for each category you are filing. Do not complete a Schedule B for section 951A category income, because carrybacks and carryforwards are not allowed for that category.
If you made the election to claim the foreign tax credit without filing Form 1116 in a given year, you cannot carry from or into that election year, and the carry period is not extended just because of the election. This rule is spelled out in the Form 1116 instructions.
Why firms get tripped up
In my experience, the same handful of issues cause most rejections or mismatches.
- The team keys a number directly on Form 1116, line 10, instead of letting Schedule B feed it, so software business rules trigger.
- The return includes a non‑zero line 10, but no Schedule B PDF is attached, so the e‑file rejects with rule F1116‑004‑02 until you attach a PDF labeled as required.
- Separate categories or AMT are netted together, which Schedule B and Form 1116 do not allow.
Carryback and carryforward, in plain English
The carry periods are statutory. If your qualified foreign taxes exceed the limit this year, you first carry the excess back to the immediately preceding year, then carry any remaining balance forward for up to ten years. You always apply the oldest vintage first within the same separate category, and you cannot use carryovers for section 951A category income.
Below is a simple timeline you can hand to your reviewers.
Quick timeline, oldest first
| Vintage year on Schedule B | What happens this year | Where the math shows |
| 10th preceding year | Expires if still unused | Schedule B line 5, column (i) |
| 9th to 2nd preceding years | Use as allowed by this year’s limitation | Schedule B line 4, columns (ii) to (ix), total to line 4, column (xiv) |
| 1st preceding year | May receive a carryback from the current year if it was an excess limitation year | Schedule B line 7, and amended prior‑year return if you actually carry back |
| Current year | If you have excess foreign taxes, create a new carryover | Schedule B line 6, then line 7 for the carryback piece, and line 8 for the forward piece |
As you update Schedule B, the amount available for this year’s Form 1116 line 10 is the total on Schedule B, line 3, column (xiv). The Form 1116 instructions spell out that linkage and remind you to file an amended return for the earlier year if you actually carry back.
Special notes on the relief period and creditability
Since January 4, 2022, TD 9959 has been the base for creditability and related rules. In July 2023 the IRS issued Notice 2023‑55 with temporary relief, and in December 2023, Notice 2023‑80 extended and modified that relief, including guidance for partnerships and an extension until further notice. Publication 514 consolidates those references for individual filers. If your carryovers involve taxes affected by those rules, align your positions with the current notices before you lock Schedule B.
Section 951A category reminder
Do not enter a carryover on a Form 1116 filed for section 951A category income. The instructions tell you to leave line 10 blank for that category because no carrybacks or carryforwards are allowed.
Eligible vs. ineligible foreign taxes for carryover
Schedule B preserves only amounts that are legally creditable. You are generally looking at foreign income taxes, including withholding, that meet section 901 or 903 requirements and are imposed on you. Refundable amounts, or taxes that are not your legal liability, or amounts tied to excluded income, do not belong in the carryover. Always check the “eligible” and “not eligible” sections in the current Form 1116 instructions and Publication 514 when you reconcile.
A few quick examples we see in reviews:
- Withholding on dividends often qualifies, but holding period and related‑party limits can disallow part of it, and disallowed pieces never carry.
- If you deducted foreign taxes in a year rather than claimed a credit, you cannot carry a credit back into that deduction year, and you must reduce carry computations as described by the instructions.
- If you made the simplified election in a year to claim the credit without Form 1116, you cannot carry to or from that election year. The carry period is not extended.
Practical tip, label every prior‑year row with the source of the tax, for example 1099‑DIV, K‑3, foreign return receipt, then note any adjustments under section 905(c) in the “adjustments” lines so your reviewer can track changes year to year.
Building a clean Schedule B workflow you can trust
When returns get busy, you need a simple way to keep line 10 clean, repeatable, and fast to review. Here is the workflow we teach new team members on day one. It assumes you already know which separate categories you will file on Form 1116.
Step by step, from intake to e‑file
1.Gather your inputs
- Pull prior year Form 1116 and Schedule B PDFs, plus any workpapers that tracked carryovers by year.
- Collect current year documents that create foreign taxes, 1099‑DIV, K‑1 or K‑3, broker statements, foreign tax receipts, and client FX support.
- Confirm whether the client made the simplified election in any year inside the carry window. If they did, do not carry to or from that year.
- Set up the year
- Create a separate Form 1116 for each income category you need, passive, general, treaty resourced, and so on.
- For each category you file, open a fresh Schedule B, regular tax, and, if applicable, a separate Schedule B for AMT.
- Load the prior years
- Enter the 10th through 1st preceding years on Schedule B exactly as your prior‑year workpapers show them, taxes paid, disallowed, claimed, and remaining carryover.
- Do not net buckets. Keep regular tax and AMT in their own lanes, and keep each category separate.
- Enter current year numbers on Form 1116
- Complete Part I for foreign source income and Part II for foreign taxes paid or accrued, using the correct exchange rate method for your client’s accounting treatment.
- Compute the limitation in Part III. Do not type directly on line 10. Let Schedule B feed it.
- Reconcile carryback and carryforward on Schedule B
- If this year generates excess foreign taxes, Schedule B will show a one‑year carryback to the immediately preceding year, then a ten‑year carryforward for what remains.
- If last year had excess limitation, decide whether an actual carryback makes sense, and plan your amended return if you will use it.
- Validate and attach
- Confirm the total available for line 10 equals Schedule B’s stated total.
- Generate the Schedule B PDF for each category and regime that has a carry to or from the current year, then attach the PDFs before you create the e‑file.
Quick win, do a five‑minute “tick and tie.” Read line 10 on Form 1116 out loud, then point to the exact total on Schedule B that feeds it. If you cannot point to it, reviewers will get stuck too.
Roles that keep this moving
| Role | What you do | What you never do |
| Preparer | Load prior‑year rows, enter current year income and taxes, and complete Schedule B | Type on line 10 by hand |
| Senior | Tie Schedule B totals to Form 1116 and confirm categories and AMT are separate | Approve without checking the PDF attachment |
| Reviewer | Recreate the carry math on a scratch sheet and spot‑check FX and disallowed items | Assume last year’s work was perfect |
| E‑file lead | Confirm Schedule B PDFs are attached for every category with a carry and that the return passes schema checks | Send the file without the PDF because “it worked last time” |
Currency conversion, the practical way
- Cash‑basis, translate foreign taxes using the spot rate on the payment date.
- Accrual‑basis, use the rate when the liability accrued, or a consistent annual average that clearly reflects income.
- If taxes were paid in installments, either translate each payment at its payment‑date rate or use a reasonable, consistent averaging method.
- Keep proof for every rate you use, screen captures, broker records, or a rate service printout. Use the original year’s rates for the carryovers on Schedule B, not today’s rate.
Documentation you keep forever
- Prior year Form 1116s, all prior Schedule B PDFs, and any worksheets that show how amounts moved year to year.
- Source documents that created foreign taxes, 1099‑DIV, K‑3, foreign withholding slips, and receipts.
- Your FX support with dates and rates, plus notes if you changed methods.
- Any notices, refunds, or section 905(c) adjustments that changed a prior year.
- A basket index so anyone on the team can find which Schedule B goes with which Form 1116 in under 30 seconds.
Where Accountably fits without taking over your process
If your internal team is stuck in review loops during peak months, a disciplined delivery partner can shoulder the mechanical parts, the data entry, tie‑outs, PDF attachment checks, and carryover aging, while your reviewers keep the judgment work. At Accountably, we plug into your templates and your software, not the other way around, so your line 10 ties still look and feel like your own work. You maintain control, you just get your evenings back.
E‑file setup and software specifics that prevent last‑minute rejects
Let’s turn the scary part into a checklist you can run with a new staffer. The goal is simple, no surprises at transmission.
One rule to remember
If Form 1116, Part III, line 10 is non‑zero for a category, the return needs a Schedule B PDF for that category, regular tax and AMT as applicable. If there is no carry to or from the current year, some software will still let you file without the PDF, but you will spend more time debating that edge case than just attaching it.
Software notes that save time
- Lacerte Create one carryover screen per separate category, Screen 35.x, and use the Schedule B tabs for the 10th through 1st prior years. Turn on Auto Generate and Attach PDFs to EFiles in Options so the Schedule B PDF rides with the return. Do not override line 10.
- UltraTax and CCH Axcess Enter prior‑year rows on the dedicated 1116B input and verify that the category code on the Schedule B matches the Form 1116 you created. Use the “PDF attachments” control in the Electronic Filing dialog to confirm the Schedule B PDFs are present.
- Drake Use the 1116B screen for carryovers, keep exactly one screen per category, and let Drake compute line 10. If you must file with carryovers and no current‑year credit, still create the Form 1116 and the 1116B so the PDF attaches and your carry detail survives.
- ProConnect Tax Use the Foreign Tax Credit section to enter carryover detail by category, then check the Forms tab to make sure Schedule B exists. Add the PDF to the e‑file attachments panel if the program does not auto‑attach.
- Controller and workflow tools If you use Karbon, Canopy, TaxDome, or Jetpack, add a required task called “Attach Schedule B PDFs,” assign it to the e‑file lead, and set it to blocking, the return cannot move to “Ready to transmit” until that box is checked.
Common errors and the quick fix
- Direct entry on line 10 Symptom, totals that do not match your carry ledger. Fix, delete the override, complete Schedule B, and let it feed line 10.
- Multiple carryover inputs for the same category Symptom, totals that double, plus warning notes. Fix, keep one Schedule B input per category per regime.
- Missing PDFs Symptom, e‑file reject near the finish line. Fix, generate and attach the Schedule B PDFs for each category with a carry to or from this year.
- Category mismatch Symptom, the line 10 total exists, but the basket code on Schedule B does not match the Form 1116. Fix, align the category labels and regenerate the PDF.
Team tip, add a review line that literally reads “1116 line 10 equals Schedule B total, PDF attached, category codes match.” Have the reviewer initial it and date it. It takes 30 seconds and prevents most late‑night calls.
Carryback and carryforward rules with clear examples
The rules are firm, carry back one year, then carry forward ten. The trick is to keep each separate category in its own lane and to apply the oldest amounts first. Here is a hands‑on walkthrough you can use during reviews.
Example, how a current year excess becomes a carryback and a carryforward
Assume you file a passive category Form 1116 in 2025. Your client has 2025 qualified foreign taxes of 2,400 and a 2025 limitation of 1,900. That creates 500 of excess foreign taxes in 2025.
- First, check 2024, the one year immediately preceding. If 2024 was an excess limitation year in the passive basket, you can carry back up to 500 into 2024, but only to the extent of 2024’s passive limitation. If 2024’s remaining limitation was 300, you carry back 300 and reduce the 2025 excess to 200.
- The remaining 200 becomes a new carryforward, which Schedule B ages across the next ten years, 2026 through 2035, oldest used first.
On Schedule B for 2025 you will see the 300 labeled as a carryback to the prior year, and the 200 tagged as a carryforward. If you plan to actually use the carryback, you prepare an amended 2024 return. If not, you still record the theoretical carryback in 2025 and then carry forward what remains.
Example, applying older carryforwards first
Assume you brought in prior‑year carryforwards in the passive category from 2016 through 2024 totaling 2,200. Your 2025 limitation allows you to use 1,500 on line 10. You must draw down the carry in oldest‑first order.
| Vintage year | Opening balance | Used in 2025 | Remaining |
| 2016 | 300 | 300 | 0 |
| 2017 | 250 | 250 | 0 |
| 2018 | 250 | 250 | 0 |
| 2019 | 300 | 300 | 0 |
| 2020 | 300 | 300 | 0 |
| 2021 | 300 | 100 | 200 |
| 2022‑2024 | 500 | 0 | 500 |
| Total | 2,200 | 1,500 | 700 |
In this example, everything from 2016 through 2020 is fully used. You partially use 2021. You still have 700 to carry forward after 2025, which will start with the remainder of 2021, then move to 2022, and so on. Your Schedule B will show the used and remaining columns for each year, and the total used will match the amount feeding Form 1116, line 10.
AMT vs regular, never net them
Treat AMT as its own world. If your engagement requires an AMT Form 1116, you also need an AMT Schedule B, with its own ten‑year ladder. Keep AMT carryovers separate from regular tax carryovers by category and by vintage year. A quick desk check that catches most errors, compare the total regular carryover column to the total AMT carryover column. They should almost never be identical.
Eligible vs ineligible taxes, a quick filter before you post
- Eligible, foreign income taxes imposed on you, commonly dividend withholding that meets the holding period rules, and taxes paid in lieu of income taxes.
- Ineligible, anything refundable to you, amounts that are not your legal liability, taxes tied to excluded income, and any portion disallowed by related‑party or holding period limits.
- Election year reminder, if you claimed the foreign tax credit without filing Form 1116 in a given year, you do not carry to or from that year. That year sits outside the carry chain.
Exchange rates and timing, keep it consistent
Carryovers use the exchange rate from the original year the tax was paid or accrued. For cash‑basis taxpayers, use the spot rate on the date of payment. For accrual‑basis taxpayers, use the rate on the accrual date or an average rate where permitted, but be consistent year to year. In reviews, note the rate source on each prior‑year row so new staff can retrace it without guesswork.
Step‑by‑step data entry for the current year
Here is a checklist that makes data entry boring and accurate, which is exactly what you want for foreign tax credit work.
Set the foundation
- Choose the correct country and separate category on Form 1116. The category drives every limit and linkage in Parts I through III.
- Enter gross foreign income in Part I as foreign source only. Tie each line to a source document and keep a note with the allocation logic if you had to split income between U.S. and foreign.
Record foreign taxes in Part II
- Separate withholding from taxes you paid directly. Label each item with the document it came from, for example, 1099‑DIV or K‑3.
- Choose paid or accrued consistently with your client’s method. If you switch methods, document the year of change and the reason, then update carryovers as required.
Compute the limitation in Part III
- Let the software compute lines 9 through 15.
- Pull prior‑year carryovers from Schedule B to Form 1116, Part III, line 10 automatically. Do not type a number on line 10.
- Check that the fraction on line 9 is using the right category and the right source income. If this fraction is off, the rest will not make sense.
Validate and attach
- Open Schedule B and confirm the total used equals the number on line 10. Say it out loud. This catches more typos than you think.
- Create the Schedule B PDF for every category with a carry to or from the current year. Attach those PDFs before you create the e‑file.
- If there is no current‑year credit but you are preserving carry detail for next year, still generate the Form 1116 and the Schedule B so the PDF attaches and your ledger survives.
Reconciling prior‑year carryovers, the micro‑anecdote that sold me
I once inherited a file where the prior preparer entered a clean 1,200 on line 10 with no Schedule B. It looked tidy until the IRS notice arrived. We rebuilt ten years of rows, discovered that 400 had expired and 150 was disallowed by holding period rules. The fix was simple, the lesson was loud. If you cannot prove where line 10 came from, do not put it on the form.
Common errors, plus the fixes your team can apply in minutes
You already know the big three, typing on line 10, missing PDFs, and mixing categories. Here are the rest of the traps we see in busy seasons, along with the fastest way to clear them without a fire drill.
The “harmless” override that multiplies work
Problem, a preparer overrides a number to make the return balance. Result, reviewers spend an hour proving a mystery total that never ties to Schedule B. Fix, remove the override, complete Schedule B by vintage year, and let the software feed line 10. If you need to adjust a prior year, do it on Schedule B, not on the form.
Duplicated inputs that double totals
Problem, two carryover screens exist for the same separate category, often after a proforma year. Fix, keep exactly one input screen per category per regime. Merge the rows, delete the extra screen, then re‑generate the Schedule B PDF.
The simplified election that breaks the chain
Problem, a year inside the carry window used the simplified election to claim the credit without filing Form 1116. Fix, do not carry to or from that year. Note the election on Schedule B’s memo line so a future reviewer understands the break in the chain.
AMT missing or netted
Problem, AMT is overlooked or netted with regular tax. Fix, create a separate AMT Form 1116 and a separate AMT Schedule B. If the client does not owe AMT in the current year but has AMT carryovers, still create the forms so the PDF preserves the ledger.
Exchange rates applied inconsistently
Problem, prior‑year rows are translated at this year’s rate or at mixed sources. Fix, use the original year’s rate for each prior‑year row, paid or accrued method as applicable. Note the source next to each row so a new team member can retrace it in seconds.
Reviewer cue, if you cannot answer “which document, which rate, which line” for a single row in under 30 seconds, the return is not ready to file.
Documentation and records you should keep on every engagement
Think of Schedule B as the headline, and your binder as the proof. When notices show up, the teams that win have receipts for every number, and they can show the story year by year.
What to keep, and why it matters
- Prior Form 1116s and Schedule B PDFs, you need them to seed the 10th through 1st preceding years accurately.
- Source documents, 1099‑DIV, K‑1 or K‑3, foreign withholding slips, broker statements, local country receipts, these tie the tax to the taxpayer.
- FX support, a brief note with the method, the rate, and the rate source. Include a screenshot or service printout.
- Adjustment notes, for example, if a dividend fails the holding period or a section 905(c) adjustment changed a prior year, document it in plain language.
- A basket index, a one‑page map that lists each separate category, the related Form 1116, and the matching Schedule B file name.
How to label files so your future self thanks you
Use a simple pattern every time, for example, “ClientName_1116_Passive_SchedB_2025.pdf” and “ClientName_1116_General_SchedB_AMT_2025.pdf.” Put the basket in the name. Put AMT in the name. Put the year in the name. Reviewers will stop guessing.
Internal notes that reduce review time
Add a short “carry story” at the top of the workpaper, two or three sentences that explain what changed this year. Example, “Used 1,500 of older passive carryovers, created 200 of new excess, carried back 150 to 2024, carrying forward 50.” Reviewers can now audit the detail with context.
Quality control checklist for reviewers
Here is the ten‑point checklist we train on. It turns a 30‑minute review into a 7‑minute pass.
- Form 1116, line 10 equals the total used on Schedule B for the same category, regular or AMT.
- Separate category codes match between Form 1116 and Schedule B.
- No overrides on line 10.
- One Schedule B input per category per regime.
- PDF attachments exist for every category with a carry to or from the year.
- The 10th preceding year expired amounts are dropped.
- Current year excess shows the split, carryback to the prior year and carryforward to future years.
- Exchange rates on prior‑year rows use the original year’s rate, with a source noted.
- If the simplified election was made in a carry year, no carry to or from that year.
- The memo line explains any material change from last year.
Pro tip, initial and date this checklist, then file it right behind the Schedule B PDF. If you are ever asked who checked what, you have a clear answer.
Security, compliance, and workflow integrity
Foreign tax credit work is rich with sensitive data, account numbers, and country‑specific statements. Keep controls tight.
Practical controls inside your process
- Role‑based access in your tax and document systems, preparers can view what they need, reviewers approve, and e‑file leads transmit.
- Zero local storage, require staff to work inside your DMS or VDI so nothing lives on a laptop.
- Audit logs and signoffs, keep the who and when for every attachment and change.
- Background‑verified staff, especially for peak contractors or offshore teams.
- NDA and confidentiality reminders at start of peak season, short, clear, and signed.
Where a disciplined partner helps
If you are scaling and your team is stuck in review loops, a structured offshore delivery partner can help with the heavy lift, aging carryovers, building the PDFs, and running the checklists, while your partners focus on strategy and client conversations. The key is that the work runs in your systems, your templates, and your controls, so quality and security stay yours.
Frequently asked questions about Form 1116 Schedule B
Is Schedule B needed for foreign bank accounts or FBAR?
No. Schedule B is only for foreign tax credit carryovers that tie to Form 1116, Part III, line 10. Foreign accounts raise separate FBAR and FATCA filings, FinCEN Form 114 and Form 8938, based on asset thresholds. Handle those on their own tracks.
What goes on Schedule B, exactly?
Each prior year’s row includes foreign taxes paid, any disallowed amounts, the portion claimed in prior filings, and the remaining carryover by separate category, regular and AMT. The schedule then shows what you used this year, what you carried back to the immediately preceding year, and what you will carry forward.
Who must complete Form 1116 in the first place?
Most individuals who claim a foreign tax credit above the simplified election threshold must file Form 1116. Estates and trusts generally must file. Nonresident and dual status filers have special rules, so check status early in the engagement.
When do I have to attach the Schedule B PDF?
Attach it when there is a carry to or from the current year for any category, which will also make Form 1116 line 10 non‑zero. Many e‑file systems will reject the return if line 10 is non‑zero and the PDF is missing.
How do I handle a year that used the simplified election?
You do not carry to or from that year. Note the election in the workpapers, keep the carry ladder intact for other years, and do not try to fill the gap with an override on line 10.
What if I discover an expired carry in the tenth preceding year?
Drop it. Schedule B has a spot to show expired amounts. You cannot revive expired amounts, and you should remove them to keep the ledger clean.
Do I need a separate Schedule B for AMT?
Yes, if AMT applies, keep a separate Schedule B for AMT by category. Do not net AMT with regular tax. Even if AMT is zero this year, preserve AMT carryovers with a Schedule B so you do not lose the history.
Can I post to line 10 if the software is being stubborn?
No. Fix the inputs. The moment you type on line 10, you break the review chain, you risk an e‑file error, and you will spend more time undoing the override than fixing the cause.
Templates and quick references you can drop into your process
Schedule B intake checklist
- Prior year Form 1116 and Schedule B PDFs for every category
- Current year 1099‑DIV, K‑1 or K‑3, foreign receipts, and broker statements
- Exchange rates with dates and sources
- Prior‑year notes on disallowed pieces and election years
- AMT applicability notes
Five‑minute reviewer script
- “Form 1116 line 10 equals Schedule B total, category matches”
- “One input screen per category per regime, no overrides”
- “PDF attached for every category with a carry”
- “Oldest carryovers used first, year 10 dropped if not used”
- “FX method noted, sources attached”
Naming pattern for attachments
Use “ClientName_1116_[Category]SchedB[RegOrAMT]_TaxYear.pdf.” The point is clarity, not creativity. Everyone finds the right file on the first try.
Final checklist before you transmit
- Category set correctly on each Form 1116, passive, general, treaty resourced, or other.
- Schedule B completed for each category that has a carry to or from the year, regular and AMT where applicable.
- No direct entries on Form 1116 line 10.
- Carryback piece identified and, if you will use it, an amended prior year planned.
- Ten‑year ladder reviewed, year 10 expired amounts dropped.
- Exchange rates documented for every prior‑year row, with method and source.
- Schedule B PDFs generated and attached, file names include category and regime.
- Reviewer initials on the ten‑point QC checklist, dated.
- E‑file validation passed in software, no final overrides.