5471, Schedule E Income, War Profits, and Excess Profits Taxes Paid or Ac

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SCHEDULE E
(Form 5471)

DRAFT AS OF
September 19, 2018
DO NOT FILE
Income, War Profits, and Excess Profits Taxes Paid or Accrued

(September 2018)
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

(f)
Income Subject to Tax
in the Foreign Jurisdiction
(see instructions)

(b)
EIN or Reference
ID Number of
Payor Entity

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.

(g)
Currency in Which Tax Is Payable

(c)
Country or U.S. Possession
to Which Tax Is Paid
(Enter code—see instructions.
Use a separate line for each.)

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Election

(d)
Foreign Tax Year of Foreign Corporation
to Which Tax Relates
(Year/Month/Day)

(e)
U.S. Tax Year of Foreign Corporation
to Which Tax Relates
(Year/Month/Day)

(i)
In U.S. Dollars
(divide column (g) by column (h))

(j)
In Functional Currency
of Foreign Corporation

(h)
Conversion Rate to U.S. Dollars

1
2
3
4
5
6
7
8 Total (combine lines 1 through 7 of column (i)). Report amount on Schedule E-1, line 4 .
9 Total (combine lines 1 through 7 of column (j)). See instructions for Schedule H, line 2g .

Part II

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Taxes for Which a Foreign Tax Credit Is Allowed
(a)
Name of Payor Entity

1
2
3
4
5
6
7

Reference ID number (see instructions)

EIN (if any)

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For tax years beginning after December 31, 2004, has an election been made under section 986(a)(1)(D) to translate taxes using the exchange rate on the date of payment?
If “Yes,” state date of election ▶
Yes
No

Part III

Taxes for Which a Foreign Tax Credit Is Disallowed (Enter in functional currency of foreign corporation.)
(a)
Name of Payor Entity

(b)
EIN or Reference ID
Number of Payor
Entity

(c)
Section 901(j)

(d)
Section 901(k) and (l)

(e)
Section 901(m)

(f)
U.S. Taxes

1
2
3 In functional currency (combine lines 1 and 2) . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4 In U.S. dollars (translated at the average exchange rate, as defined in section 989(b)(3) and related regulations (see instructions)) .
For Paperwork Reduction Act Notice, see instructions.

Cat. No. 71397A

(g)
Other

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(h)
Total

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▶
▶

Schedule E (Form 5471) (9-2018)

DRAFT AS OF
September 19, 2018
DO NOT FILE

Schedule E (Form 5471) (9-2018)

Schedule E-1

Taxes related to:

IMPORTANT: Enter amounts in
U.S. dollars unless otherwise noted
(see instructions).
1a
b
c
2
3a
b
4
5a
b
6
7
8
9
10
11
12
13
14

Page 2

Taxes Paid, Accrued, or Deemed Paid on Accumulated Earnings and Profits (E&P) of Foreign Corporation
(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)
(in functional currency)

(d)
Hovering Deficit and
Suspended Taxes

Balance at beginning of year (as reported in prior year Schedule E-1) . . .
Beginning balance adjustments (attach statement) . . . . . . . . .
Adjusted beginning balance (combine lines 1a and 1b) . . . . . . . .
Adjustment for redetermination of prior year U.S. tax liability . . . . . .
Taxes unsuspended under anti-splitter rules
. . . . . . . . . . .
Taxes suspended under anti-splitter rules . . . . . . . . . . . .
Taxes reported on Schedule E, Part I, line 8, column (i) . . . . . . . .
Taxes carried over in nonrecognition transactions . . . . . . . . . .
Taxes reclassified as related to hovering deficit after nonrecognition transaction
Other adjustments (attach statement) . . . . . . . . . . . . . .
Taxes paid or accrued on accumulated E&P (combine lines 1c through 6) . .
Taxes deemed paid with respect to inclusions under section 951(a)(1) (see instructions)
Taxes deemed paid with respect to inclusions under section 951A (see instructions)
Taxes deemed paid with respect to actual distributions . . . . . . . .
Taxes on amounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P
Other (attach statement) . . . . . . . . . . . . . . . . . .
Taxes related to hovering deficit offset of undistributed post-transaction E&P .
Balance at beginning of next year (combine lines 7 through 13) . . . . .
(e) Taxes related to previously taxed E&P (see instructions)
(i)
(ii)
Earnings Invested in U.S. Section 965(a) Inclusion
Property (section 959(c)(1)(A)) (section 959(c)(1)(A))

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

(iv)
(v)
Section 951A Inclusion Earnings Invested in Excess Passive
(section 959(c)(1)(A))
Assets (section 959(c)(1)(B))

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

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

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

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

1a
b
c
2
3a
b
4
5a
b
6
7
8
9
10
11
12
13
14
Schedule E (Form 5471) (9-2018)