Schedule M (5471) Transactions Between Controlled Foreign Corporation and

1

Tax Year 2007 Work Request Notification

2007 Schedule M (Form 5471)
To:

Symbols:

1.Scanned by:

SE:W:CAR:MP:T: B : C

2. Section Chief: Barbara Bradley
3. Reviewer:

Stephen Becker

Initials:

Date:

SE:W:CAR:MP:T: B: C

BB

8/21/07

SE:W:CAR:MP:T: B : R

SWB

4. Review Chief: Johnny Cervantes

SE:W:CAR:MP:T: B : R Johnny Cervantes

5. Branch Chief: Curtis Freeman

SE:W:CAR:MP:T: B

6. Senior Technical Advisor: Bob Erickson

SE:W:CAR:MP:T

7. *TPCC Circulations Email sent to Distribution List by: Diane K. Creed
8. Initiator (Tax Law Specialist): Diane Regier

SE:W:CAR:MP:T: B : C

L9FCB

8/21/2007
Digitally signed by Johnny Cervantes
DN: cn=Johnny Cervantes, c=US, o=TE/GE Review,
ou=SE:W:CAR:MP:T:T:R, [email protected]
Reason: I am approving this document
Date: 2007.08.22 13:13:34 -04'00'

Digitally signed by L9FCB
DN: cn=L9FCB
Reason: I am the author of this document
Date: 2007.08.22 13:30:48 -04'00'

Digitally signed by recipients, user mailboxes,
raeric00
DN: o=internal revenue service, ou=washington dc,
cn=recipients, cn=user mailboxes, cn=raeric00
Date: 2007.09.04 12:34:27 -04'00'

DKC

09/04/2007

Completed:

Attached is a marked up draft that can be used to develop any necessary Work Requests for
the 2008 processing year. The major changes are as follows:
The following changes have been made since the 1st WRN dated August 15, 2007. At the request of Treasury and
Associate Chief Counsel (International) we are adding new lines 4 and 16 to reflect Regulations section 1.482-7(g) and we
are adding new lines 5 and 17 to reflect Regulations section 1.482-7(d)(1).

This Notification is for changes due to:
✔ Legislation or other Chief Counsel guidance:

A Program change initiated by:

LMSB

✔ We do not anticipate the need for any further changes that would require a Work Request Notification.

We may need to make further changes that would require a subsequent Work Request Notification.
If you have any questions, please contact the TLS shown below, or the reviewer on line 3 (above).
From:

Initials:

Diane Regier
SE:W:CAR:MP:T:B:C

Room:
DR

Date:
08/22/2007

1111 Const., Rm 6411

Phone Number:
(202) 622-3695

Email:
[email protected]

Fax Number:
(202) 622-3262

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I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
SCHEDULE M (FORM 5471), PAGE 1 of 2 (PAGE 2 IS BLANK)
MARGINS: TOP 13mm (1⁄ 2 "), CENTER SIDES.
PRINTS: FACE ONLY
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
FLAT SIZE: 203mm (8") 3 279mm (11")
PERFORATE: (NONE)
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Action

Date

O.K. to print
Revised proofs
requested

Transactions Between Controlled Foreign Corporation
and Shareholders or Other Related Persons

SCHEDULE M
(Form 5471)
(Rev. December 2007)
Department of the Treasury
Internal Revenue Service

©

Name of person filing Form 5471

Name of foreign corporation

Signature

f
o
s
a
7
t
0
f
0
a
2
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D /03
8
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OMB No. 1545-0704

Attach to Form 5471. See Instructions for Form 5471.

Identifying number

Important: Complete a separate Schedule M for each controlled foreign corporation. Enter the totals for each type of transaction that occurred during
the annual accounting period between the foreign corporation and the persons listed in columns (b) through (f). All amounts must be stated in U.S.
dollars translated from functional currency at the average exchange rate for the foreign corporation’s tax year. See instructions.
Enter the relevant functional currency and the exchange rate used throughout this schedule ©
(a) Transactions
of
foreign corporation

(b) U.S. person
filing this return

1 Sales of stock in trade (inventory)
2 Sales of tangible property other
than stock in trade

Insert A

6

7
8
9
10
11
12
13

3 Sales of property rights
(patents, trademarks, etc.)
4 Compensation received for technical, managerial, engineering,
construction, or like services

(c) Any domestic
corporation or
partnership controlled
by U.S. person filing
this return

(d) Any other foreign
(e) 10% or more U.S. (f) 10% or more U.S.
corporation or
shareholder of controlled shareholder of any
partnership controlled
corporation
foreign corporation
by U.S. person filing
controlling the
(other than the U.S.
this return
person filing this return) foreign corporation

5 Commissions received
6 Rents, royalties, and license
fees received
7 Dividends received (exclude
deemed distributions under
subpart F and distributions of
previously taxed income)
8 Interest received
9 Premiums received for insurance or reinsurance
10 Add lines 1 through 9

11

11 Purchases of stock in trade
(inventory)

14
15

12 Purchases of tangible property
other than stock in trade
13 Purchases of property rights
(patents, trademarks, etc.)

Insert B
14
18

19
20
21
22
23
24
25
26

Compensation paid for technical, managerial, engineering,
construction, or like services

15 Commissions paid
16 Rents, royalties, and license
fees paid
17 Dividends paid
18 Interest paid
19 Premiums paid for insurance or
reinsurance

13

23

20 Add lines 11 through 19
21 Amounts borrowed (enter the
maximum loan balance during
the year) — see instructions
22 Amounts loaned (enter the
maximum loan balance during
the year) — see instructions
For Paperwork Reduction Act Notice, see the Instructions for Form 5471.

Note - if necessary carry new lines 25-26
to new page.

Printed on recycled paper

Cat. No. 49963O

Schedule M (Form 5471) (Rev. 12-2007)

Insert A
4 Buy-in payments received . . . . .
5 Cost sharing payments received . . .

Insert B
16 Buy-in payments paid . . . . . . .
17 Cost sharing payments paid . . . . .