5471 Schedule J Accumulated Earnings and Profits (E&P) of Controlled For

Caution: DRAFT—NOT FOR FILING
This is an early release draft of an IRS tax form, instructions, or
publication, which the IRS is providing for your information as a courtesy.
Do not file draft forms. Also, do not rely on draft forms, instructions, and
publications for filing. We generally do not release drafts of forms until we
believe we have incorporated all changes. However, unexpected issues
sometimes arise, or legislation is passed, necessitating a change to a draft
form. In addition, forms generally are subject to OMB approval before they
can be officially released. Drafts of instructions and publications usually
have at least some changes before being officially released.
Early release drafts are at IRS.gov/DraftForms, and may remain there
even after the final release is posted at IRS.gov/DownloadForms. All
information about all forms, instructions, and pubs is at IRS.gov/Forms.
Almost every form and publication also has its own page on IRS.gov. For
example, the Form 1040 page is at IRS.gov/Form1040; the Publication 17
page is at IRS.gov/Pub17; the Form W-4 page is at IRS.gov/W4; and the
Schedule A (Form 1040) page is at IRS.gov/ScheduleA. If typing in a link
above instead of clicking on it, be sure to type the link into the address bar
of your browser, not in a Search box. Note that these are friendly shortcut
links that will automatically go to the actual link for the page.
If you wish, you can submit comments about draft or final forms,
instructions, or publications at IRS.gov/FormsComments. We cannot
respond to all comments due to the high volume we receive. Please note that
we may not be able to consider many suggestions until the subsequent
revision of the product.

SCHEDULE J
(Form 5471)
(December 2018)

DRAFT AS OF
September 27, 2018
DO NOT FILE
Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporation

Department of the Treasury
Internal Revenue Service

▶

▶

OMB No. 1545-0704

Attach to Form 5471.

Go to www.irs.gov/Form5471 for instructions and the latest information.

Identifying number

Name of person filing Form 5471
Name of foreign corporation

a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . .
b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions)

Part I

Reference ID number (see instructions)

EIN (if any)

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

▶
▶

Accumulated E&P of Controlled Foreign Corporation

Check the box if person filing return does not have all U.S. Shareholders’ information to complete amount for columns (e)(ii)–(e)(iv) and (e)(vii)–(ix) (see instructions).
Important: Enter amounts in functional currency.

(a)
Post-2017 E&P Not
Previously Taxed
(post-2017 section
959(c)(3) balance)

(b)
Post-1986
Undistributed Earnings
(post-1986 and
pre-2018 section
959(c)(3) balance)

(c)
Pre-1987 E&P Not
Previously Taxed
(pre-1987 section
959(c)(3) balance)

(d)
Hovering Deficit
and Deduction
for Suspended
Taxes

(e) Previously Taxed E&P (see instructions)

(i) Earnings Invested
in U.S. Property
(section 959(c)(1)(A))

(ii) Section 965(a)
Inclusion
(section 959(c)(1)(A))

1a Balance at beginning of year (as reported on prior
year Schedule J) . . . . . . . . . . . .
1b Beginning balance adjustments (attach statement)
1c Adjusted beginning balance (combine lines 1a and 1b)
2a Reduction for taxes unsuspended under anti-splitter rules
2b Disallowed deduction for taxes suspended under
anti-splitter rules . . . . . . . . . . . .
3 Current year E&P (or deficit in E&P)
. . . . .
4 E&P attributable to distributions of previously taxed
E&P from lower-tier foreign corporation . . . .
5a E&P carried over in nonrecognition transaction . .
5b Reclassify deficit in E&P as hovering deficit after
nonrecognition transaction . . . . . . . .
6 Other adjustments (attach statement) . . . . .
7 Total current and accumulated E&P (combine lines
1c through 6) . . . . . . . . . . . . .
8 Amounts reclassified to section 959(c)(2) E&P from
section 959(c)(3) E&P . . . . . . . . . .
9 Actual distributions . . . . . . . . . . .
10 Amounts reclassified to section 959(c)(1) E&P from
section 959(c)(2) E&P . . . . . . . . . .
11 Amounts included as earnings invested in U.S. property
and reclassified to section 959(c)(1) E&P (see instructions)
12 Other adjustments (attach statement) . . . . .
13 Hovering
deficit
offset
of
undistributed
posttransaction E&P (see instructions)
. . . .
14 Balance at beginning of next year (combine lines 7
through 13) . . . . . . . . . . . . .
For Paperwork Reduction Act Notice, see the Instructions for Form 5471.

Cat. No. 21111K

Schedule J (Form 5471) (12-2018)

DRAFT AS OF
September 27, 2018
DO NOT FILE

Schedule J (Form 5471) (12-2018)

Part I

(e) Previously Taxed E&P (see instructions)

(iii) Section 965(b)(4)(A)
(section 959(c)(1)(A))

1a
1b
1c
2a
2b
3
4
5a
5b
6
7
8
9
10
11
12
13
14

Part II

Page 2

Accumulated E&P of Controlled Foreign Corporation (continued)
(iv) Section 951A
Inclusion
(section 959(c)(1)(A))

(v) Earnings Invested in
Excess Passive Assets
(section 959(c)(1)(B))

(vii) Section 965(a)
Inclusion
(section 959(c)(2))

(vi) Subpart F Income
(section 959(c)(2))

(ix) Section 951A
Inclusion
(section 959(c)(2))

(viii) Section 965(b)(4)(A)
(section 959(c)(2))

(f)
Total Section 964(a) E&P
(combine columns (a), (b),
(c), and (e)(i) through (e)(ix))

Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (section 952(c)(2))

Enter amounts in functional currency.
1
2
3
4

Balance at beginning of year . . . . . . .
Additions (amounts subject to future recapture) .
Subtractions (amounts recaptured in current year)
Balance at end of year (combine lines 1 through 3)

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

.
.
.
.

▶
▶
▶
▶
Schedule J (Form 5471) (12-2018)