Schedule J (Form 5 Accumulated Earnings and Profits (E&P) and Taxes of Cont

Note: The draft you are looking for begins on the next page.

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. Do not file draft forms and do
not rely on draft forms, instructions, and publications for filing. We generally do
not release draft forms until we believe we have incorporated all changes, but
sometimes unexpected issues arise, or legislation is passed. Also, forms generally
are subject to OMB approval before they can be officially released. Drafts of
instructions and publications usually have some changes before their final release.
Early release drafts are at IRS.gov/DraftForms and may remain there even after
the final release is posted at IRS.gov/LatestForms. All information about all
forms, instructions, and pubs is at IRS.gov/Forms.
Almost every form and publication also has a page on IRS.gov with a friendly
shortcut. For example, the Form 1040 page is at IRS.gov/Form1040; the Pub. 501
page is at IRS.gov/Pub501; 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 a Search box.
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)
(Rev. December 2019)

DRAFT AS OF
August 26, 2019
DO NOT FILE
Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporation

Department of the Treasury
Internal Revenue Service

▶

▶

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

Reference ID number (see instructions)

EIN (if any)

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

OMB No. 1545-0123

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

.
.

▶
▶

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)(i), (e)(ii), (e)(iv), and (e)(x) through (e)(xii) (see instructions).
Important: Enter amounts in functional currency.

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

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

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

Balance at beginning of year (as reported on prior
year Schedule J) . . . . . . . . . . .
Beginning balance adjustments (attach statement)
Adjusted beginning balance (combine lines 1a and 1b)
Reduction for taxes unsuspended under anti-splitter rules
Disallowed deduction for taxes suspended under
anti-splitter rules . . . . . . . . . . .
Current year E&P (or deficit in E&P) . . . . .
E&P attributable to distributions of previously
taxed E&P from lower-tier foreign corporation .
E&P carried over in nonrecognition transaction .
Reclassify deficit in E&P as hovering deficit after
nonrecognition transaction . . . . . . . .
Other adjustments (attach statement) . . . .
Total current and accumulated E&P (combine lines
1c through 6) . . . . . . . . . . . .
Amounts reclassified to section 959(c)(2) E&P from
section 959(c)(3) E&P
. . . . . . . . .
Actual distributions . . . . . . . . . .
Amounts reclassified to section 959(c)(1) E&P from
section 959(c)(2) E&P
. . . . . . . . .
Amounts included as earnings invested in U.S. property
and reclassified to section 959(c)(1) E&P (see instructions)
Other adjustments (attach statement) . . . .
Hovering deficit offset of undistributed posttransaction E&P (see instructions) . . . . .
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) (Rev. 12-2019)

DRAFT AS OF
August 26, 2019
DO NOT FILE

Schedule J (Form 5471) (Rev. 12-2019)

Part I

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

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

Page 2

Accumulated E&P of Controlled Foreign Corporation (continued)

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

(iv) Section 951A
Inclusion
(section 959(c)(1)(A))

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

(v) Section 245A(e)(2)
Inclusion
(section 959(c)(1)(A))

(e) Previously Taxed E&P (see instructions)
(vii) Section 964(e)(4)
Inclusion
(section 959(c)(1)(A))

(vi) Section 959(e)
(section 959(c)(1)(A))

(e) Previously Taxed E&P (see instructions)
(xiii) Section 245A(e)(2)
(xiv) Section 959(e)
Inclusion
(section 959(c)(2))
(section 959(c)(2))

(viii) Section 951(a)(1)(A)
Inclusion
(section 959(c)(1)(A))

(xv) Section 964(e)(4)
Inclusion
(section 959(c)(2))

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

(xvi) Section 951(a)(1)(A)
Inclusion
(section 959(c)(2))

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

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

1a
b
c
2a
b
3
4
5a
b
6
7
8
9
10
11
12
13
14
Schedule J (Form 5471) (Rev. 12-2019)

DRAFT AS OF
August 26, 2019
DO NOT FILE

Schedule J (Form 5471) (Rev. 12-2019)

Part II

Version A, Cycle 6
Page 3

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

Important: Enter amounts in functional currency.
1

Balance at beginning of year

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

▶

1

2

Additions (amounts subject to future recapture)

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

▶

2

3

Subtractions (amounts recaptured in current year)

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

▶

3

4

Balance at end of year (combine lines 1 through 3)

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

.

▶

.

.

.

.

.

4

Schedule J (Form 5471) (Rev. 12-2019)