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pdfInstructions for Form 5471
Department of the Treasury
Internal Revenue Service
(Rev. February 2020)
(Use with the December 2019 revision of Form 5471 and separate Schedules E, I-1,
J, and P, the December 2018 revision of separate Schedules H and M, and the
December 2012 revision of separate Schedule O.)
Information Return of U.S. Persons
With Respect to Certain Foreign Corporations
Section references are to the Internal Revenue
Code unless otherwise noted.
Contents
What’s New . . . . . . . . . . . . . . .
Reminders . . . . . . . . . . . . . . . .
General Instructions . . . . . . . . . .
Purpose of Form . . . . . . . . . . . .
Who Must File . . . . . . . . . . . . .
When and Where To File . . . . . .
Categories of Filers . . . . . . . . . .
Exceptions From Filing . . . . . . . .
Filing Requirements for Categories
of Filers . . . . . . . . . . . . . . .
Additional Filing Requirements . . .
Penalties . . . . . . . . . . . . . . . . .
Other Reporting Requirements . . .
Specific Instructions . . . . . . . . . .
Identifying Information . . . . . . . .
Schedule B . . . . . . . . . . . . . . .
Schedule C . . . . . . . . . . . . . . .
Schedule F . . . . . . . . . . . . . . .
Schedule G . . . . . . . . . . . . . . .
Schedule I . . . . . . . . . . . . . . . .
Worksheet A . . . . . . . . . . . . . .
Worksheet A Instructions . . . . . .
Worksheet B . . . . . . . . . . . . . .
Worksheet B Instructions . . . . . .
Instructions for Separate
Schedules . . . . . . . . . . . . .
Schedule E . . . . . . . . . . . . . . .
Schedule E-1 . . . . . . . . . . . . . .
Schedule H . . . . . . . . . . . . . . .
Schedule I-1 . . . . . . . . . . . . . .
Schedule J . . . . . . . . . . . . . . .
Schedule M . . . . . . . . . . . . . . .
Schedule O . . . . . . . . . . . . . . .
Schedule P . . . . . . . . . . . . . . .
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Future Developments
For the latest information about
developments related to Form 5471, its
schedules, and its instructions, such as
legislation enacted after they were
published, go to IRS.gov/Form5471.
What’s New
Changes to Form 5471. On page 5 of
Form 5471, new questions 20 and 21
have been added to Schedule G to reflect
P.L. 115-97, section 13301, which added
section 163(j) to the Code.
Feb 19, 2020
On page 6 of Form 5471, old line 1c
has been deleted from Schedule I, and
new lines 1c through 1f have been
inserted in its place. These new lines
request various types of subpart F income
of the CFC. Also, line 3 has been
reworded. The old line 3 language has
been deleted to reflect P.L. 115-97,
section 14212(b)(5), which struck section
970(b) from the Code. The new line 3
language requests section 245A eligible
dividends. This new line 3 language was
added to reflect P. L. 115-97, section
14101, which added section 245A.
Changes to separate Schedule E
(Form 5471). On page 1, the column
heading for Schedule E, Part I, column (g),
has been reworded for purposes of clarity.
On pages 2 and 3, seven new columns
have been added to Schedule E-1
(columns (e)(v) through (e)(viii) and
columns (e)(xiii) through (e)(xv)) and most
of the preexisting columns of Schedule E1 have been rearranged to reflect Notice
2019-01, 2019-2 I.R.B. 275, available at
IRS.gov/irb/2019-02_IRB#NOT-2019-01.
Note. Regulations section 1.960-3(c)(2)
includes only ten of the sixteen PTEP
groups listed in Notice 2019-01.
Taxpayers should still complete each
column of the Schedule E-1.
Changes to separate Schedule H
(Form 5471). No changes have been
made to Schedule H (Form 5471). Use the
December 2018 revision.
Changes to separate Schedule I-1
(Form 5471). Line 9 was revised and
line 10 was added to conform Schedule I1 to the final regulations under section
951A. Line 9 (interest expense) was
renumbered as line 9a, and lines 9b
through 9d were added to report qualified
interest expense, tested loss QBAI
amount, and tested interest expense.
Lines 10a through 10c were added to
report interest income, qualified interest
income, and tested interest income.
Schedule I-1 is now completed once. (It is
no longer completed separately for each
applicable category of income.) Therefore,
Schedule I-1 is completed once (for
general category income, passive
Cat. No. 49959G
category income, or both). A Schedule I-1
that includes passive category income
must include the code for passive
category income (PAS) in the entry space
for separate category (at the top of
Schedule I-1). A taxpayer with only
general category income (and no passive
category income) should enter the code
“GEN” in the entry space for separate
category.
Changes to separate Schedule J
(Form 5471). In Part I, column (e), seven
new columns have been added (columns
(e)(v) through (e)(viii) and columns (e)(xiii)
through (e)(xv)) and most of the
preexisting columns have been
rearranged to reflect Notice 2019-01.
Note. Regulations section 1.960-3(c)(2)
includes only ten of the sixteen PTEP
groups listed in Notice 2019-01.
Taxpayers should still complete each
column of the Schedule J.
Changes to separate Schedule M
(Form 5471). No changes have been
made to Schedule M (Form 5471). Use
the December 2018 revision.
Changes to separate Schedule O
(Form 5471). No changes have been
made to Schedule O (Form 5471). Use the
December 2012 revision.
Changes to separate Schedule P
(Form 5471). Part II is new. It is identical
to Part I except that previously taxed E&P
must now be reported in functional
currency (Part I) and U.S. dollars (Part II).
Seven new columns have been added
to Part I and Part II (columns (e) through
(h) and columns (n) through (o)) and most
of the preexisting columns have been
rearranged to reflect Notice 2019-01.
Note. Regulations section 1.960-3(c)(2)
includes only ten of the sixteen PTEP
groups listed in Notice 2019-01.
Taxpayers should still complete each
column of the Schedule P.
Changes to Instructions for Form 5471
and separate schedules. The
instructions have been updated for each
of the aforementioned changes to Form
5471 and separate schedules. In addition:
• Changes have been made throughout
these instructions to reflect Rev. Proc.
2019-40, 2019-43 I.R.B. 982, available at
IRS.gov/irb/2019-43_IRB#REVPROC-2019-40 which generally provides
relief to U.S. persons that directly,
indirectly, or constructively own stock in
foreign corporations that are CFCs as a
result of the repeal of section 958(b)(4).
• Changes have been made throughout
these instructions based on final
regulations under section 960 (T. D. 9882,
84 FR 69022, December 17, 2019).
• In the Instructions for Schedule I,
several lines have been added to
Worksheet A to assist shareholders in
determining their pro rata share of the
components of subpart F income specified
on new lines 1c through 1f of Form 5471,
Schedule I.
• In the instructions for Schedule I,
Worksheet C (U.S. Shareholder's Pro
Rata Share of Previously Excluded Export
Trade Income of a CFC Withdrawn From
Investment in Export Trade Assets) has
been deleted to reflect P.L. 115-97,
section 14212(b)(5), which struck section
970(b) of the Code.
Reminders
If the filer is described in more than one
filing category, do not duplicate
information. However, complete all items
that apply. For example, if you are the sole
owner of a CFC (i.e., you are described in
Categories 4 and 5), complete all six
pages of Form 5471 and separate
Schedules E, H, I-1, J, M, and P.
Note. Complete a separate Form 5471
and all applicable schedules for each
applicable foreign corporation.
When and Where To File
Attach Form 5471 to your income tax
return (or, if applicable, partnership or
exempt organization return) and file both
by the due date (including extensions) for
that return.
Categories of Filers
Category 1 Filer
This category includes a U.S. shareholder
of a foreign corporation that is a section
965 specified foreign corporation (defined
below) at any time during any tax year of
the foreign corporation, and who owned
that stock on the last day in that year on
which it was an SFC, taking into account
the regulations under section 965.
However, see Certain Category 1 and
Category 5 Filers , later, which may apply.
2017 Tax Reform. On December 22,
2017, Congress enacted the “Tax Cuts
and Jobs Act,” P. L. 115-97, which made
significant changes to U.S. international
tax rules. For a description of such
changes, including corresponding
changes to Form 5471 and separate
schedules, please see the December
2018 Instructions for Form 5471. Please
note that some of the changes to Form
5471 and separate schedules noted in the
December 2018 instructions for Form
5471 have been modified by the What's
New items listed previously in these
December 2019 instructions.
U.S. shareholder. For purposes of
Category 1, a U.S. shareholder is a U.S.
person who owns (directly, indirectly, or
constructively, within the meaning of
sections 958(a) and (b)) 10% or more of
the total combined voting power of all
classes of voting stock of an SFC or, in the
case of a tax year of a foreign corporation
beginning after December 31, 2017, 10%
or more of the total combined voting
power or value of shares of all classes of
stock of an SFC.
General Instructions
U.S. person. See Category 5 Filer, later,
for definition.
Purpose of Form
Section 965 specified foreign corporation (SFC). For purposes of Category 1,
an SFC (as defined in section 965) is:
1. A CFC (see Category 5 Filer, later,
for a definition), or
2. Any foreign corporation with
respect to which one or more domestic
corporations is a U.S. shareholder.
Form 5471 is used by certain U.S.
persons who are officers, directors, or
shareholders in certain foreign
corporations. The form and schedules are
used to satisfy the reporting requirements
of sections 6038 and 6046, and the
related regulations, as well as to report
amounts related to section 965.
Who Must File
Generally, all U.S. persons described in
Categories of Filers below must complete
the schedules, statements, and/or other
information requested in the chart, Filing
Requirements for Categories of Filers,
later. Read the information for each
category carefully to determine which
schedules, statements, and/or information
apply.
However, if a passive foreign
investment company (as defined in
section 1297) with respect to the
shareholder is not a CFC, then such
corporation is not an SFC.
See section 965 and the regulations
thereunder for exceptions.
Note. A U.S. shareholder who is a
Category 1 filer (defined above) must
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continue to file all information required of a
Category 1 filer as long as:
• The section 965 specified foreign
corporation has accumulated E&P related
to section 965 that is reportable on
Schedule J (Form 5471), or
• The U.S. shareholder has previously
taxed E&P related to section 965 that is
reportable on Schedule P (Form 965).
Category 2 Filer
This category includes a U.S. citizen or
resident who is an officer or director of a
foreign corporation in which a U.S. person
(defined below) has acquired (in one or
more transactions):
1. Stock which meets the 10% stock
ownership requirement (described below)
with respect to the foreign corporation, or
2. An additional 10% or more (in value
or voting power) of the outstanding stock
of the foreign corporation.
A U.S. person has acquired stock in a
foreign corporation when that person has
an unqualified right to receive the stock,
even though the stock is not actually
issued. See Regulations section
1.6046-1(f)(1) for more details.
10% stock ownership requirement. For
purposes of Category 2 and Category 3,
the stock ownership threshold is met if a
U.S. person owns:
1. 10% or more of the total value of
the foreign corporation's stock, or
2. 10% or more of the total combined
voting power of all classes of stock with
voting rights.
U.S. person. For purposes of Category 2
and Category 3, a U.S. person is:
1. A citizen or resident of the United
States,
2. A domestic partnership,
3. A domestic corporation, and
4. An estate or trust that is not a
foreign estate or trust as defined in section
7701(a)(31).
See Regulations section 1.6046-1(f)(3)
for exceptions.
Category 3 Filer
This category includes:
• A U.S. person (see Category 2 Filer,
above, for definition) who acquires stock
in a foreign corporation which, when
added to any stock owned on the date of
acquisition, meets the 10% stock
ownership requirement (described above)
with respect to the foreign corporation;
• A U.S. person who acquires stock
which, without regard to stock already
owned on the date of acquisition, meets
the 10% stock ownership requirement with
respect to the foreign corporation;
Instructions for Form 5471 (Rev. February 2020)
• A person who is treated as a U.S.
shareholder under section 953(c) with
respect to the foreign corporation;
• A person who becomes a U.S. person
while meeting the 10% stock ownership
requirement with respect to the foreign
corporation; or
• A U.S. person who disposes of
sufficient stock in the foreign corporation
to reduce his or her interest to less than
the 10% stock ownership requirement.
For more information, see section 6046
and Regulations section 1.6046-1.
Category 4 Filer
This category includes a U.S. person who
had control (defined below) of a foreign
corporation during the annual accounting
period of the foreign corporation.
U.S. person. For purposes of
Category 4, a U.S. person is:
1. A citizen or resident of the United
States;
2. A nonresident alien for whom an
election is in effect under section 6013(g)
to be treated as a resident of the United
States;
3. An individual for whom an election
is in effect under section 6013(h), relating
to nonresident aliens who become
residents of the United States during the
tax year and are married at the close of
the tax year to a citizen or resident of the
United States;
4. A domestic partnership;
5. A domestic corporation; and
6. An estate or trust that is not a
foreign estate or trust as defined in section
7701(a)(31).
See Regulations section 1.6038-2(d)
for exceptions.
Control. A U.S. person has control of a
foreign corporation if, at any time during
that person's tax year, it owns stock
possessing:
1. More than 50% of the total
combined voting power of all classes of
stock of the foreign corporation entitled to
vote, or
2. More than 50% of the total value of
shares of all classes of stock of the foreign
corporation.
A person in control of a corporation
that, in turn, owns more than 50% of the
combined voting power, or the value, of all
classes of stock of another corporation is
also treated as being in control of such
other corporation.
Example. Corporation A owns 51% of
the voting stock in Corporation B.
Corporation B owns 51% of the voting
stock in Corporation C. Corporation C
owns 51% of the voting stock in
Corporation D. Therefore, Corporation D
is controlled by Corporation A.
For more details on “control,” see
Regulations sections 1.6038-2(b) and (c).
Category 5 Filer
This category includes a U.S. shareholder
who owns stock in a foreign corporation
that is a CFC at any time during any tax
year of the foreign corporation, and who
owned that stock on the last day in that
year on which it was a CFC. However, see
Certain Category 1 and Category 5 Filers,
later, which may apply.
U.S. shareholder. For purposes of
Category 5, a U.S. shareholder is a U.S.
person who:
1. Owns (directly, indirectly, or
constructively, within the meaning of
sections 958(a) and (b)) 10% or more of
the total combined voting power of all
classes of voting stock of a CFC or, in the
case of a tax year of a foreign corporation
beginning after December 31, 2017, 10%
or more of the total combined voting
power or value of shares of all classes of
stock of a CFC; or
2. Owns (either directly or indirectly,
within the meaning of section 958(a)) any
stock of a CFC (as defined in sections
953(c)(1)(B) and 957(b)) that also is a
captive insurance company.
U.S. person. For purposes of
Category 5, a U.S. person is:
1. A citizen or resident of the United
States,
2. A domestic partnership,
3. A domestic corporation, and
4. An estate or trust that is not a
foreign estate or trust as defined in
section 7701(a)(31).
See section 957(c) for exceptions.
CFC. A CFC is a foreign corporation that
has U.S. shareholders that own (directly,
indirectly, or constructively, within the
meaning of sections 958(a) and (b)) on
any day of the tax year of the foreign
corporation, more than 50% of:
1. The total combined voting power of
all classes of its voting stock, or
2. The total value of the stock of the
corporation.
Certain Category 1 and Category 5
Filers
Rev. Proc. 2019-40 provides relief for
certain types of Category 5 filers. These
instructions clarify that this relief is
extended to similarly-situated Category 1
filers.
Unrelated section 958(a) U.S. shareholder. For purposes of Category 1 and
Category 5, an unrelated section 958(a)
Instructions for Form 5471 (Rev. February 2020)
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U.S. shareholder is a U.S. shareholder
with respect to a foreign-controlled
corporation who:
1. Owns, within the meaning of
section 958(a), stock of a
foreign-controlled corporation; and
2. Is not related (using principles of
section 954(d)(3)) to the foreign-controlled
corporation.
Related constructive U.S. shareholder.
For purposes of Category 1 and Category
5, a related constructive U.S. shareholder
is a U.S. shareholder with respect to a
foreign-controlled corporation who:
1. Does not own, within the meaning
of section 958(a), stock of the
foreign-controlled corporation; and
2. Is related (using principles of
section 954(d)(3)) to the foreign-controlled
corporation.
Foreign-controlled corporation. For
purposes of Category 1 and Category 5, a
foreign-controlled corporation is a foreign
corporation that is a CFC or SFC that
would not be a CFC or SFC, if the
determination were made without applying
subparagraphs (A), (B), and (C) of section
318(a)(3) so as to consider a U.S. person
as owning stock which is owned by a
foreign person.
Exceptions From Filing
Multiple filers of same information.
One person may file Form 5471 and the
applicable schedules for other persons
who have the same filing requirements. If
you and one or more other persons are
required to furnish information for the
same foreign corporation for the same
period, a joint information return that
contains the required information may be
filed with your tax return or with the tax
return of any one of the other persons. For
example, a U.S. person described in
Category 5 may file a joint Form 5471 with
a Category 4 or another Category 5 filer.
However, for Category 3 filers, the
required information may only be filed by
another person having an equal or greater
interest (measured in terms of value or
voting power of the stock of the foreign
corporation).
The person that files Form 5471 must
complete Form 5471 in the manner
described in the instructions for Item F. All
persons identified in Item F must attach a
statement to their income tax return that
includes the information described in the
instructions for Item F.
Domestic corporations. Shareholders
are not required to file the information
checked in the chart, later, for a foreign
insurance company that has elected
(under section 953(d)) to be treated as a
domestic corporation and has filed a U.S.
income tax return for its tax year under
that provision. See Rev. Proc. 2003-47,
2003-28 I.R.B. 55, available at
IRS.gov/irb/2003-28_IRB#RP-2003-47 for
procedural rules regarding the election
under section 953(d).
Constructive owners.
• A U.S. person described in Category 1,
3, 4, or 5 (“shareholder”) does not have to
file Form 5471 if all of the following
conditions are met.
1. The shareholder does not own a
direct interest in the foreign corporation;
2. The shareholder is required to
furnish the information requested solely
because of constructive ownership (as
determined under Regulations section
1.958-2, 1.6038-2(c), or 1.6046-1(i)) from
another U.S. person; and
3. The U.S. person through which the
shareholder constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the required
information.
No statement is required to be attached
to tax returns for persons claiming the
constructive ownership exception.
• A Category 2 filer does not have to file
Form 5471 if:
1. Immediately after a reportable
stock acquisition, three or fewer U.S.
persons own 95% or more in value of the
outstanding stock of the foreign
corporation and the U.S. person making
the acquisition files a return for the
acquisition as a Category 3 filer, or
2. The U.S. person(s) for which the
Category 2 filer is required to file Form
5471 does not directly own an interest in
the foreign corporation but is required to
furnish the information solely because of
constructive stock ownership from a U.S.
person and the person from whom the
stock ownership is attributed furnishes all
of the required information.
• A Category 1, 4 or 5 filer does not have
to file Form 5471 if the shareholder:
1. Does not own a direct or indirect
interest in the foreign corporation, and
2. Is required to file Form 5471 solely
because of constructive ownership from a
nonresident alien.
• A Category 1 or 5 filer does not have to
file Form 5471 if no U.S. shareholder
(including such U.S. person) owns, within
the meaning of section 958(a), stock in the
foreign corporation on the last day in the
year of the foreign corporation in which it
was an SFC or CFC, and the foreign
corporation is an SFC or CFC solely
because one or more U.S. persons is
considered to own the stock of the foreign
corporation owned by a foreign person
under section 318(a)(3). Furthermore, a
Category 1 or 5 filer does not have to file
Form 5471 if all of the following conditions
are met.
1. The filer is a U.S. shareholder that
owns stock, within the meaning of section
958(b), in the foreign corporation;
2. The filer is not related, using
principles of section 954(d)(3), to the
foreign corporation; and
3. The foreign corporation is a
foreign-controlled CFC . See Rev. Proc.
2019-40 for more details.
with the related persons described in
Regulations section 1.6046-1(b)(11); and
2. The name, address, identifying
number, and number of shares subscribed
to by each subscriber to the foreign
corporation's stock.
Foreign sales corporations (FSCs).
• Category 2 and Category 3 filers who
are shareholders, officers, and directors of
a FSC (as defined in section 922, as in
effect before its repeal) must file Form
5471 and a separate Schedule O to report
changes in the ownership of the FSC.
• Category 4 and 5 filers are not subject
to the subpart F rules for:
1. Exempt foreign trade income;
Additional Filing
Requirements
Category 3 filers. Category 3 filers must
attach a statement that includes:
1. The amount and type of any
indebtedness the foreign corporation has
Filing Requirements for Categories of Filers
Table of Required Information
Category of Filer
11
Required Information*
2
3
4
51
Unrelated
Related
section
Constructive
958(a) U.S.
U.S.
Shareholder Shareholder
The identifying information on page 1 of
Form 5471 above Schedule A, see Specific
Instructions
Schedule A
Schedule B, Part I
Schedule B, Part II
Schedules C and F
Separate Schedule E
2
Schedule E-1 (included with separate
Schedule E)
3
2
Schedule G
Separate Schedule H
Schedule I
Separate Schedule I-1
Separate Schedule J
Separate Schedule M
Separate Schedule O, Part I
Separate Schedule O, Part II
Separate Schedule P
*See also Additional Filing Requirements on this page.
1. Certain Category 1 and Category 5 filers may meet the requirements to file under the last two columns of this chart.
See Certain Category 1 and Category 5 Filers.
2. Schedules E and E-1 are required for an unrelated section 958(a) U.S. Shareholder only if the filer claims deemed
paid foreign income taxes of the foreign-controlled corporation under section 960 for the filer’s taxable year. See Rev.
Proc. 2019-40 for more details.
3. Related constructive U.S. shareholders only need to complete Schedule E (they can leave Schedule E-1 blank). See
Rev. Proc. 2019-40 for more details.
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Instructions for Form 5471 (Rev. February 2020)
2. Deductions that are apportioned or
allocated to exempt foreign trade income;
3. Nonexempt foreign trade income
(other than section 923(a)(2) nonexempt
income, within the meaning of
section 927(d)(6), as in effect before its
repeal); and
4. Any deductions that are
apportioned or allocated to the nonexempt
foreign trade income described above.
• Category 4 and 5 filers are subject to
the subpart F rules for:
1. All other types of FSC income
(including section 923(a)(2) nonexempt
income within the meaning of
section 927(d)(6), as in effect before its
repeal);
2. Investment income and carrying
charges (as defined in sections 927(c) and
927(d)(1), as in effect before their repeal);
and
3. All other FSC income that is not
foreign trade income or investment
income or carrying charges.
• Category 4 and 5 filers are not required
to file a Form 5471 (in order to satisfy the
requirements of section 6038) if the FSC
has filed a Form 1120-FSC. See
Temporary Regulations section
1.921-1T(b)(3). However, these filers may
be required to file Form 5471 if they are
subject to the subpart F rules with respect
to certain types of FSC income (see
above).
Section 338 election. If a section 338
election is made with respect to a qualified
stock purchase of a foreign target
corporation for which a Form 5471 must
be filed:
• A purchaser (or its U.S. shareholder)
must attach a copy of Form 8883, Asset
Allocation Statement Under Section 338,
to the first Form 5471 for the new foreign
target corporation (see the Instructions for
Form 8883 for details);
• A seller (or its U.S. shareholder) must
attach a copy of Form 8883 to the last
Form 5471 for the old foreign target
corporation.
Reportable transaction disclosure
statement. If a U.S. shareholder of a
CFC is considered to have participated in
a reportable transaction under the rules of
Regulations section 1.6011-4(c)(3)(i)(G),
the shareholder is required to disclose
information for each reportable
transaction. Form 8886, Reportable
Transaction Disclosure Statement, must
be filed for each tax year indicated in
Regulations section 1.6011-4(c)(3)(i)(G).
The following are reportable transactions.
1. Any listed transaction, which is a
transaction that is the same as or
substantially similar to one of the types of
transactions that the IRS has determined
to be a tax avoidance transaction and
identified by notice, regulation, or other
published guidance as a listed
transaction.
2. Any transaction offered under
conditions of confidentiality for which the
corporation (or a related party) paid an
advisor a fee of at least $250,000.
3. Certain transactions for which the
corporation (or a related party) has
contractual protection against
disallowance of the tax benefits.
4. Certain transactions resulting in a
loss of at least $10 million in any single
year or $20 million in any combination of
years.
5. Any transaction identified by the
IRS by notice, regulation, or other
published guidance as a “transaction of
interest.” See Notice 2009-55, 2009-31
I.R.B. 170, available at IRS.gov/irb/
2009-31_IRB#NOT-2009-55.
For more information, see Regulations
section 1.6011-4. Also see the Instructions
for Form 8886.
Penalties. The U.S. shareholder may
have to pay a penalty if it is required to
disclose a reportable transaction under
section 6011 and fails to properly
complete and file Form 8886. Penalties
also may apply under section 6707A if the
U.S. shareholder fails to file Form 8886
with its income tax return, fails to provide a
copy of Form 8886 to the Office of Tax
Shelter Analysis (OTSA), or files a form
that fails to include all the information
required (or includes incorrect
information). Other penalties, such as an
accuracy-related penalty under section
6662A, also may apply. See the
Instructions for Form 8886 for details on
these and other penalties.
Reportable transactions by material
advisors. Material advisors to any
reportable transaction must disclose
certain information about the reportable
transaction by filing Form 8918, Material
Advisor Disclosure Statement, with the
IRS. For details, see the Instructions for
Form 8918.
Reporting other foreign financial assets. If you have other foreign financial
assets, you may be required to file Form
8938, Statement of Specified Foreign
Financial Assets. However, you are not
required to report any items otherwise
reported on Form 5471 on that form. See
the Instructions for Form 8938 for more
information.
Penalties
Failure to file information required by
section 6038(a) (Form 5471 and
Schedule M).
• A $10,000 penalty is imposed for each
annual accounting period of each foreign
corporation for failure to furnish the
information required by section 6038(a)
Instructions for Form 5471 (Rev. February 2020)
-5-
within the time prescribed. If the
information is not filed within 90 days after
the IRS has mailed a notice of the failure
to the U.S. person, an additional $10,000
penalty (per foreign corporation) is
charged for each 30-day period, or
fraction thereof, during which the failure
continues after the 90-day period has
expired. The additional penalty is limited
to a maximum of $50,000 for each failure.
• Any person who fails to file or report all
of the information required within the time
prescribed will be subject to a reduction of
10% of the foreign taxes available for
credit under sections 901, 902 (with
respect to foreign corporate tax years
beginning before January 1, 2018), and
960. If the failure continues 90 days or
more after the date the IRS mails notice of
the failure to the U.S. person, an additional
5% reduction is made for each 3-month
period, or fraction thereof, during which
the failure continues after the 90-day
period has expired. See section 6038(c)
(2) for limits on the amount of this penalty.
Failure to file information required by
section 6046 and the related regulations (Form 5471 and
Schedule O). Any person who fails to file
or report all of the information requested
by section 6046 is subject to a $10,000
penalty for each such failure for each
reportable transaction. If the failure
continues for more than 90 days after the
date the IRS mails notice of the failure, an
additional $10,000 penalty will apply for
each 30-day period or fraction thereof
during which the failure continues after the
90-day period has expired. The additional
penalty is limited to a maximum of
$50,000.
Criminal penalties. Criminal penalties
under sections 7203, 7206, and 7207 may
apply for failure to file the information
required by sections 6038 and 6046.
Note. Any person required to file
Form 5471 and Schedule J, M, or O who
agrees to have another person file the
form and schedules for him or her may be
subject to the above penalties if the other
person does not file a correct and proper
form and schedule.
Section 6662(j). Penalties may be
imposed for undisclosed foreign financial
asset understatements. No penalty will be
imposed with respect to any portion of an
underpayment if the taxpayer can
demonstrate that the failure to comply was
due to reasonable cause with respect to
such portion of the underpayment and the
taxpayer acted in good faith with respect
to such portion of the underpayment. See
sections 6662(j) and 6664(c) for additional
information.
Inapplicability of certain penalties.
Certain penalties under sections 6038 and
6662 may be waived for certain persons
under Rev. Proc. 2019-40. See Section 7
of Rev. Proc. 2019-40 for more details.
Other Reporting
Requirements
Reporting exchange rates on Form
5471. When translating amounts from
functional currency to U.S. dollars, you
must use the method specified in these
instructions. For example, when
translating amounts to be reported on
Schedule E, you generally must use the
average exchange rate as defined in
section 986(a). But, regardless of the
specific method required, all exchange
rates must be reported using a “divide-by
convention” rounded to at least four
places. That is, the exchange rate must be
reported in terms of the amount by which
the functional currency amount must be
divided in order to reflect an equivalent
amount of U.S. dollars. As such, the
exchange rate must be reported as the
units of foreign currency that equal one
U.S. dollar, rounded to at least four
places. Do not report the exchange rate
as the number of U.S. dollars that equal
one unit of foreign currency.
Note. You must round the result to more
than four places if failure to do so would
materially distort the exchange rate or the
equivalent amount of U.S. dollars.
Example. During its annual
accounting period, the foreign corporation
paid income taxes of 30,255,400 Yen to
Japan. The Schedule E instructions
specify that the foreign corporation must
translate these amounts into U.S. dollars
at the average exchange rate for the tax
year to which the tax relates in
accordance with the rules of section
986(a). The average exchange rate is
118.5050 Japanese Yen to one U.S. dollar
(0.00843846) U.S. dollars to one
Japanese Yen. The foreign corporation
divides 30,255,400 Yen by 118.5050 to
determine the U.S. dollar amount to enter
in column (i) of Schedule E, Part I. Line 1
of Schedule E, Part I is completed in
relevant part as follows.
• Enter the name of the foreign
corporation in column (a).
• Enter the foreign corporation's EIN or
reference ID number in column (b).
• Enter "Japan" in column (c).
• Enter "30,255,400 Yen" in column (g).
• Enter "118.5050" in column (h).
• Enter "255,309" in column (i).
Computer-Generated
Form 5471 and Schedules
Generally, all computer-generated forms
must receive prior approval from the IRS
and are subject to an annual review.
However, see the Exception below.
Requests for approval may be submitted
electronically to [email protected],
or requests may be mailed to:
Internal Revenue Service
Attention: Substitute Forms Program
SE:W:CAR:MP:P:TP
1111 Constitution Ave. NW,
Room 6554
Washington, DC 20224
Exception. If a computer-generated
Form 5471 and its schedules conform to
and do not deviate from the official form
and schedules, they may be filed without
prior approval from the IRS.
Important. Be sure to attach the approval
letter to Form 5471. However, if the
computer-generated form is identical to
the IRS prescribed form, it does not need
to go through the approval process, and
an attachment is not necessary.
Every year, the IRS issues a revenue
procedure to provide guidance for filers of
computer-generated forms. In addition,
every year the IRS issues Pub. 1167,
General Rules and Specifications For
Substitute Forms and Schedules, which
reprints the most recent applicable
revenue procedure. Pub. 1167 is available
at IRS.gov/forms-pubs/aboutpublication-1167.
Dormant Foreign Corporations
Rev. Proc. 92-70, 1992-2 C.B. 435,
provides a summary filing procedure for
filing Form 5471 for a dormant foreign
corporation (defined in section 3 of Rev.
Proc. 92-70). This summary filing
procedure will satisfy the reporting
requirements of sections 6038 and 6046.
If you elect the summary procedure,
complete only page 1 of Form 5471 for
each dormant foreign corporation as
follows.
• The top margin of the summary return
must be labeled “Filed Pursuant to Rev.
Proc. 92-70 for Dormant Foreign
Corporation.”
• Include filer information such as name
and address, Items A through C, and tax
year.
• Include corporate information such as
the dormant corporation's annual
accounting period (below the title of the
form) and Items 1a, 1b, 1c, and 1d.
For more information, see Rev. Proc.
92-70.
File this summary return in the manner
described in When and Where To File,
earlier.
Treaty-Based Return Positions
You generally are required to file
Form 8833, Treaty-Based Return Position
Disclosure Under Section 6114 or
7701(b), to disclose a return position that
any treaty of the United States (such as an
-6-
income tax treaty, an estate and gift tax
treaty, or a friendship, commerce, and
navigation treaty):
• Overrides or modifies any provision of
the Internal Revenue Code; and
• Causes, or potentially causes, a
reduction of any tax incurred at any time.
See Form 8833 for exceptions.
Failure to make a required disclosure
may result in a $1,000 penalty ($10,000
for a C corporation). See section 6712.
Section 362(e)(2)(C) Elections
The transferor and transferee in certain
section 351 transactions may make a joint
election under section 362(e)(2)(C) to limit
the transferor's basis in the stock received
instead of the transferee's basis in the
transferred property. The election is made
by a statement as provided in Notice
2005-70, 2005-41 I.R.B. 694, available at
IRS.gov/irb/2005-41_IRB#NOT-2005-70
and regulations under section 362(e)(2).
!
Do not attach the statement
described above to Form 5471.
CAUTION
Section 108(i) Elections
If the controlling domestic shareholder(s)
of a CFC made an election in 2009 or
2010 to defer income from cancellation of
debt in connection with the CFC’s
reacquisition of an applicable debt
instrument, a statement must be filed (in
the manner specified in the Caution
below) beginning with the tax year
following the tax year for which the
controlling domestic shareholder of the
CFC made the election, and ending the
first tax year all income deferred has been
included in income. In addition, a copy of
the election statement it filed to make the
election to defer income must be filed
annually (also in the manner specified in
the Caution below). For details, see
section 108(i) and Rev. Proc. 2009-37,
2009-36 I.R.B. 309, available at
IRS.gov/irb/2009-36_IRB#RP-2009-37.
Do not attach the statements
described above to Form 5471.
CAUTION Instead, if the foreign corporation
is required to file a U.S. income tax return
(for example, Form 1120-F), attach the
statements to that return.
!
Corrections to Form 5471
If you file a Form 5471 that you later
determine is incomplete or incorrect, file a
corrected Form 5471 with an amended tax
return, using the amended return
instructions for the return with which you
originally filed Form 5471. Write
"Corrected" at the top of the form and
attach a statement identifying the
changes.
Instructions for Form 5471 (Rev. February 2020)
Specific Instructions
Important. If the information required in a
given section exceeds the space provided
within that section, do not write “See
attached” in the section and then attach all
of the information on additional sheets.
Instead, complete all entry spaces in the
section and attach the remaining
information on additional sheets. The
additional sheets must conform with the
IRS version of that section.
Identifying Information
Annual Accounting Period
Enter, in the space provided below the title
of Form 5471, the annual accounting
period of the foreign corporation for which
you are furnishing information. Except for
information contained on Schedule O,
report information for the tax year of the
foreign corporation that ends with or within
your tax year. When filing Schedule O,
report acquisitions, dispositions, and
organizations or reorganizations that
occurred during your tax year.
Section 898 specified foreign corporation (SFC). The annual accounting
period of an SFC (as defined in section
898) generally is required to be the tax
year of the corporation's majority U.S.
shareholder. If there is more than one
majority shareholder, the required tax year
will be the tax year that results in the least
aggregate deferral of income to all U.S.
shareholders of the foreign corporation.
For these purposes, section 898(b)
defines an SFC as any foreign
corporation:
1. That is treated as a CFC under
subpart F, and
2. In which more than 50% of the total
voting power or value of all classes of
stock of the corporation is treated as
owned by a U.S. shareholder.
For more information, see section 898
and Rev. Proc. 2002-37, 2002-22 I.R.B.
1030, available at IRS.gov/pub/irs-irbs/
irb02-22.pdf and Rev. Proc. 2002-39,
2002-22 I.R.B. 1046, available at
IRS.gov/pub/irs-irbs/irb02-22.pdf as
modified by Notice 2002-72, 2002-46
I.R.B. 843, available at IRS.gov/pub/irsirbs/irb02-46.pdf.
Name of Person Filing this
Return
The name of the person filing Form 5471
is generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing this return.” Be sure to list
each U.S. shareholder of the foreign
corporation in Schedule B, Part I.
Name change. If the name of either the
person filing the return or the corporation
whose activities are being reported
changed within the past 3 years, show the
prior name(s) in parentheses after the
current name.
Address
Include the suite, room, or other unit
number after the street address. If the post
office does not deliver mail to the street
address and the U.S. person has a P.O.
box, show the box number instead.
Foreign address. Enter the information
in the following order: city, province or
state, and country. Follow the country's
practice for entering the postal code, if
any. Do not abbreviate the country name.
Item A—Identifying Number
The identifying number of an individual is
his or her social security number (SSN).
The identifying number of all others is their
employer identification number (EIN). If a
U.S. corporation that owns stock in a
foreign corporation is a member of a
consolidated group, list the common
parent as the person filing the return and
enter its EIN in Item A.
Item B—Category of Filer
Complete Item B to indicate the category
or categories that describe the person
filing this return. If more than one category
applies, check all boxes that apply.
Item C—Percentage of Voting
Stock Owned
Enter the total percentage of the foreign
corporation's voting stock you owned
directly, indirectly, or constructively at the
end of the corporation's annual accounting
period.
Item D—Final Year
Check the Item D checkbox only if this is
the final year of the foreign corporation's
existence as a corporation for federal tax
purposes. For instance, if a reorganization
has occurred, a complete liquidation has
occurred, or an election to treat the foreign
corporation as a disregarded entity has
been made. If this Item D is checked,
complete Schedule O.
Item E—Excepted Specified
Foreign Financial Assets
Check the Item E checkbox if any
excepted specified foreign financial assets
are reported on Form 5471. If this is the
case, you do not have to also report these
assets on Form 8938, Statement of
Specified Foreign Financial Assets. It is
only necessary to complete Form 8938,
Part IV, line 3. For more information, see
the Instructions for Form 8938, generally,
and in particular, Duplicative Reporting
Instructions for Form 5471 (Rev. February 2020)
-7-
and the specific instructions for Part IV,
Excepted Specified Foreign Financial
Assets.
Item F—Person(s) on Whose
Behalf This Information Return
Is Filed
One person may file Form 5471 and the
applicable schedules for other persons
who have the same filing requirements.
See Multiple filers of same information,
earlier. The person that files the required
information on behalf of other persons
must complete a joint Form 5471
according to the applicable column(s) of
the Filing Requirements for Categories of
Filers chart on page 4. This includes
completing Item F on page 1 of the form.
When completing item F with respect to
members of a consolidated group, identify
only the direct owners in item F
(constructive owners are not required to
be listed).
A separate Schedule I must be filed for
each person described in Category 4 or 5.
Also, unrelated section 958(a) U.S.
shareholders are required to file
Schedule I for foreign-controlled
corporations. See Certain Category 1 and
Category 5 Filers under Categories of
Filers. For each Category 4 or Category 5
filer that is required to file a Schedule I,
send a copy of their separate Schedule I
to them to assist them in completing their
tax return.
Filing requirements for persons identified in Item F. Except for members of the
filer's consolidated return group, all
persons identified in Item F must attach a
statement to their tax returns that includes
the following information.
• The name, address, and EIN (or
reference ID number) of the foreign
corporation(s).
• A statement that their filing
requirements with respect to the foreign
corporation(s) have been or will be
satisfied.
• The name, address, and identifying
number of the taxpayer on the return with
which the information was or will be filed.
• The IRS Service Center where the
return was or will be filed. If the return was
or will be filed electronically, enter “e-file.”
Exception. If the person who is filing
Form 5471 on behalf of others is married
to a person identified in item F and they
are filing Form 1040 jointly, the statement
described above does not have to be
attached to the jointly filed Form 1040.
All persons identified in Item F
must complete a separate
CAUTION Schedule P (Form 5471) if the
person is a U.S. shareholder described in
Category 1, 4, or 5. In such a case, the
Schedule P must be attached to the
statement described above.
!
Item 1b(2)—Reference ID
Number
A reference ID number (defined below) is
required on line 1b(2) only in cases where
no EIN was entered on line 1b(1) for the
foreign corporation. However, filers are
permitted to enter both an EIN on
line 1b(1) and a reference ID number on
line 1b(2). If applicable, enter the
reference ID number you have assigned to
the foreign corporation identified on
line 1a.
A "reference ID number" is a number
established by or on behalf of the U.S.
person identified at the top of page 1 of
the form that is assigned to a foreign
corporation with respect to which Form
5471 reporting is required. These
numbers are used to uniquely identify the
foreign corporation in order to keep track
of the corporation from tax year to tax
year.
The reference ID number must meet
the requirements set forth below.
Note. Because reference ID numbers are
established by or on behalf of the U.S.
person filing Form 5471, there is no need
to apply to the IRS to request a reference
ID number or for permission to use these
numbers.
Note. The reference ID number assigned
to a foreign corporation on Form 5471
generally has relevance only on Form
5471, its schedules, and any other form
that is attached to or associated with Form
5471, and generally should not be used
with respect to that foreign corporation on
any other IRS forms. However, the foreign
corporation’s reference ID number also
should be entered on Form 8858 if the
foreign corporation is listed as a tax owner
of a foreign disregarded entity (FDE) or
foreign branch (FB) on Form 8858. See
the instructions for Form 8858, line 3c(2),
for more information.
Requirements. The reference ID number
that is entered in Item 1b(2) must be
alphanumeric (defined later) and no
special characters or spaces are
permitted. The length of a given reference
ID number is limited to 50 characters.
The same reference ID number must
be used consistently from tax year to tax
year with respect to a given foreign
corporation. If for any reason a reference
ID number falls out of use (for example,
the foreign corporation no longer exists
due to disposition or liquidation), the
reference ID number used for that foreign
corporation cannot be used again for
another foreign corporation for purposes
of Form 5471 reporting.
For these purposes, the term
“alphanumeric” means the entry can be
alphabetical, numeric, or any combination
of the two.
There are some situations that warrant
correlation of a new reference ID number
with a previous reference ID number when
assigning a new reference ID number to a
foreign corporation. For example:
• In the case of a merger or acquisition, a
Form 5471 filer must use a reference ID
number that correlates the previous
reference ID number with the new
reference ID number assigned to the
foreign corporation; or
• In the case of an entity classification
election that is made on behalf of a foreign
corporation on Form 8832, Regulations
section 301.6109-1(b)(2)(v) requires the
foreign corporation to have an EIN for this
election. For the first year that Form 5471
is filed after an entity classification election
is made on behalf of the foreign
corporation on Form 8832, the new EIN
must be entered on line 1b(1) of Form
5471 and the old reference ID number
must be entered on line 1b(2). In
subsequent years, the Form 5471 filer
may continue to enter both the EIN on
line 1b(1) and the reference ID number on
line 1b(2), but must enter at least the EIN
on line 1b(1).
You must correlate the reference ID
numbers as follows: New reference ID
number [space] Old reference ID number.
If there is more than one old reference ID
number, you must enter a space between
each such number. As indicated above,
the length of a given reference ID number
is limited to 50 characters and each
number must be alphanumeric and no
special characters are permitted.
Note. This correlation requirement
applies only to the first year the new
reference ID number is used.
Items 1f and 1g—Principal
Business Activity
Enter the principal business activity code
number and the description of the activity
from the list at the end of these
instructions.
Item 1h—Functional Currency
Enter the foreign corporation's functional
currency. Regulations sections
1.6038-2(h) and 1.6046-1(g) require that
certain amounts be reported in U.S.
dollars and/or in the foreign corporation's
functional currency. The specific
instructions for the affected schedules
state these requirements.
Special rules apply for foreign
corporations that use the U.S. dollar
approximate separate transactions
method of accounting (DASTM) under
Regulations section 1.985-3. See the
instructions for Schedule C and
Schedule H.
-8-
Schedule B
Part I
Category 3 and 4 filers must complete
Schedule B, Part I, for U.S. persons that
owned (at any time during the annual
accounting period), directly or indirectly
through foreign entities, 10% or more in
value or voting power of any class of the
foreign corporation's outstanding stock.
Column (e). Enter each shareholder's
allocable percentage of the foreign
corporation's subpart F income.
Part II
Category 1, 3, 4, and 5 filers must
complete Part II. However, Category 1 and
5 filers who are unrelated section 958(a)
U.S. shareholders are not required to file
Schedule B, Part II for foreign-controlled
corporations. See Certain Category 1 and
Category 5 Filers under Categories of
Filers.
Report the direct shareholders of the
foreign corporation. In the case of a CFC
owned by a foreign disregarded entity
(FDE), please include the information of
the FDE and the regarded entity owner.
Indicate the regarded entity owner's name
in parentheses after the FDE's name.
Category 4 filers should list all direct
owners of the CFC. Category 1, 3, and 5
filers should list all direct owners of the
CFC through which such filer indirectly
owns the CFC as described in section
958(a)(2). If the filer is a direct owner,
include the filer's direct ownership.
Schedule C
Report all information in the foreign
corporation's functional currency in
accordance with U.S. Generally Accepted
Accounting Principles (GAAP) and
translate using U.S. GAAP translation
principles.
If the foreign corporation uses the U.S.
dollar approximate separate transactions
method of accounting (DASTM) under
Regulations section 1.985-3, the
functional currency column should reflect
local hyperinflationary currency amounts
computed in accordance with U.S. GAAP.
The U.S. dollar column should reflect such
amounts translated into dollars under U.S.
GAAP translation rules. Differences
between this U.S. dollar GAAP column
and the U.S. dollar income or loss figured
for tax purposes under Regulations
section 1.985-3(c) should be accounted
for on Schedule H. See Schedule H,
Special rules for DASTM, later.
Line 8. Enter foreign currency transaction
gain or loss reported on the income
statement. For amounts included in Other
Comprehensive Income (OCI), see the
instructions for Lines 23 and 24. Enter
Instructions for Form 5471 (Rev. February 2020)
unrealized gain or loss on line 8a and
realized gain or loss on line 8b.
Line 16. Enter transactional taxes
excluding items reportable in income tax
expense (benefit). Report income taxes on
line 21.
Line 20. The term “unusual or
infrequently occurring items” is defined by
U.S. GAAP (see FASB Accounting
Standards Codification (ASC) Topic 225
(Income Statement), Subtopic 225-20
(Extraordinary and Unusual Items) or
subsequent guidance). If “prior period
adjustments” are not reported separately
on the income statement, do not report
such amounts on this line item (see ASC
250 (Accounting Changes and Error
Corrections) or subsequent guidance).
Line 21. Enter income tax expense
(benefit) reported in accordance with U.S.
GAAP (ASC 740 (Income Taxes)). Income
tax expense (benefit) includes current and
deferred income tax expense (benefit). It
also may reflect uncertain tax positions
(ASC 740-10) and would not include taxes
paid in respect of uncertain tax positions
recorded in prior years. Enter the current
income tax expense (benefit) on line 21a
and deferred income tax expense (benefit)
on line 21b.
Note. If there is an income tax expense
amount on line 21a or 21b, subtract that
amount from the line 19 net income or
(loss) amount in arriving at line 22 current
year net income or (loss) per the books. If
there is an income tax benefit amount on
line 21a or 21b, add that amount to the
line 19 net income or (loss) amount in
arriving at line 22 current year net income
or (loss) per the books.
Lines 23 and 24. Enter amounts defined
in ASC 220 (Comprehensive Income).
Line 23a. Enter foreign currency
translation adjustments before the income
tax expense (benefit) is allocated.
Line 23b. Enter other comprehensive
income such as foreign currency gains or
losses on certain hedging transactions,
pensions and other post-retirement
benefits, and certain investments
available-for-sale.
Line 23c. Enter the income tax
expense (benefit) allocated to OCI items
in the intraperiod allocation.
Important. Differences between the
functional currency amount of income tax
expense (benefit) reported on line 21 and
the amount of taxes that reduce or
increase U.S. earnings and profits (E&P)
should be accounted for on line 2g of
Schedule H.
Schedule F
Report all information in the foreign
corporation's functional currency in
accordance with U.S. GAAP and translate
using U.S. GAAP translation rules. If the
foreign corporation uses DASTM, the tax
balance sheet on Schedule F should be
prepared and translated into U.S. dollars
according to Regulations section
1.985-3(d), rather than U.S. GAAP.
Lines 3 and 17. Enter the total asset
amount of derivatives on line 3 and total
amount of liability on line 17 reported in
accordance with ASC 815 (Derivatives
and Hedging). Do not net positions.
Include all derivatives, both short-term
and long-term.
Schedule G
Note. Category 5 filers who are unrelated
section 958(a) U.S. shareholders are not
required to file Schedule G for
foreign-controlled corporations. See
Certain Category 1 and Category 5 Filers
under Categories of Filers.
Question 1
If the foreign corporation owned at least a
10% interest, directly or indirectly, in any
foreign partnership, attach a statement
listing the following information for each
foreign partnership.
1. Name and EIN (if any) of the
foreign partnership.
2. Identify which, if any, of the
following forms the foreign partnership
filed for its tax year ending with or within
the corporation's tax year: Form 1042,
1065, or 8804.
3. Name of the partnership
representative (if any).
4. Beginning and ending dates of the
foreign partnership's tax year.
Question 3
Check the “Yes” box if the foreign
corporation is the tax owner of a foreign
disregarded entity (FDE) or a foreign
branch (FB). The “tax owner” of an FDE is
the person that is treated as owning the
assets and liabilities of the FDE for
purposes of U.S. income tax law.
If the foreign corporation is the tax
owner of an FDE or FB and you are a
Category 4 or 5 filer of Form 5471, you are
required to attach Form 8858 to Form
5471.
If the foreign corporation is the tax
owner of an FDE or FB and you are not a
Category 4 or 5 filer of Form 5471, you
must attach the statement described
below in lieu of Form 8858.
Statement in lieu of Form 8858. This
statement must list the name of the FDE,
country under whose laws the FDE was
organized, and EIN (if any) of the FDE.
Instructions for Form 5471 (Rev. February 2020)
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Questions 4b and 4c
Complete lines 4b and 4c if:
1. The foreign corporation is a related
party to the U.S. filer within the meaning of
section 59A(g), and
2. The U.S. filer made or accrued a
base erosion payment to, or has a base
erosion tax benefit with respect to, the
foreign corporation.
The term “base erosion payment”
generally means any amount paid or
accrued by the U.S. filer to a foreign
corporation that is a related party to the
U.S. filer within the meaning of section
59A(g) and with respect to which a U.S.
deduction is allowed under chapter 1 of
the Code. See section 59A(d)(1). Base
erosion payments also include amounts
received or accrued by the foreign
corporation in connection with the
acquisition of depreciable or amortizable
property (section 59A(d)(2)), reinsurance
payments (section 59A(d)(3)), and certain
payments relating to expatriated entities
(section 59A(d)(4)).
The term “base erosion tax benefit”
generally means any U.S. deduction
which is allowed under Chapter 1 for the
tax year with respect to any base erosion
payment. See section 59A(c)(2)(A) and
(B) for further details.
Questions 5a and 5b
Section 267A disallows a deduction for
certain interest and royalty payments or
accruals. In general, section 267A applies
when the following occur.
• The interest or royalty is paid or
accrued to a related party.
• Under its tax laws, the related party
either:
1. Does not include the full amount in
income, or
2. Is allowed a deduction with respect
to the amount.
• The amount is paid or accrued pursuant
to a hybrid transaction or by, or to, a
hybrid entity.
When section 267A applies, the
deduction generally is disallowed to the
extent the related party does not include
the amount in income or is allowed a
deduction with respect to the amount.
However, the deduction is not disallowed
to the extent the amount is included in the
gross income of a U.S. shareholder under
section 951(a).
For definitions of terms, see section
267A.
Question 6
Check the “Yes” box on line 6a if the filer
of this Form 5471 is claiming a deduction
under section 250 with respect to
foreign-derived intangible income (FDII),
and enter the amounts requested on lines
6b, 6c, and 6d. Enter U.S. dollar amounts
on lines 6b, 6c, and 6d, translated from
functional currency at the average
exchange rate for the foreign corporation's
tax year (see section 989(b)). See Form
8993 and its instructions for information on
the section 250 deduction. If no deduction
is being claimed, check the “No” box and
go to line 7.
Question 11
Enter the foreign corporation's reasonably
anticipated benefits (RAB) share of the
total present value of all platform
contributions made by the U.S. taxpayer
during the tax year with respect to the
foreign corporation, even if only a portion
(or none) of the value of those platform
contributions was included in the U.S.
taxpayer's taxable income as platform
contribution transaction (PCT) payments
during the tax year. If possible, include a
reasonable present value estimate for any
PCTs that are priced using a method that
does not involve the calculation of a
present value. Otherwise, attach a brief
statement of the reason(s) it is not
possible to include a present value
estimate for one or more PCTs (for
example, no revenue projections for a
PCT that is priced based on a sales-based
royalty from a comparable uncontrolled
transaction).
Question 12
If the U.S. taxpayer engaged in multiple
PCTs during the tax year with the foreign
corporation and used different methods to
price the PCTs, then check the
appropriate boxes to indicate which
methods were selected as the best
method for one or more of the PCTs
reported in the tax year. See Regulations
section 1.482-7(g) for more information on
the methods applicable to PCTs.
Question 14a
Under section 367(d), a U.S. transferor
must report an annual income inclusion
attributed to the intangible property
transferred to a foreign corporation over
the useful life of the property. Check “Yes”
if the foreign corporation received any
intangible property in a prior year or the
current tax year in an exchange under
section 351 or section 361 from a U.S.
transferor that is required to report a
section 367(d) annual income inclusion for
the tax year. If “Yes,” complete line 14b.
Question 14b
Enter the amount of the E&P reduction
made by the foreign corporation for the
current tax year that equals the amount
required to be included in the income of
the U.S. transferor. See section 367(d).
This amount also should be entered on
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Schedule H, Current Earnings and Profits,
as a net subtraction on line 2i.
Question 15
A foreign corporation may qualify as an
expatriated foreign subsidiary under
Regulations section 1.7874-12(a)(9) if
such foreign corporation is a CFC with
respect to which an expatriated entity as
defined in Regulations section
1.7874-12(a)(8) is a U.S. shareholder.
Certain transactions involving an
expatriated foreign subsidiary and/or its
U.S. shareholders may be subject to
special rules. If the answer to question 15
is "Yes," attach a statement providing the
name and EIN of the domestic corporation
or partnership as defined in Regulations
section 1.7874-12(a)(6) and the
relationship of the foreign corporation to
the domestic corporation or partnership.
Question 19
Check the "Yes" box on line 19 if you
answer “Yes” to any of the 22 questions in
the Schedule G, Line 19 table below. If
"Yes," enter the Corresponding Code(s)
from the table in the entry space provided
on line 19 of the form. Enter the applicable
corresponding code in capital letters.
Enter a space between each code. Also
attach the statement described in the table
below.
Instructions for Form 5471 (Rev. February 2020)
Form 5471
Schedule G, Line 19
Question
See Worksheet A in the If “Yes,”
Code
Schedule I Instructions Corresponding Description
Code to enter
on
Schedule G,
line 19
If “Yes,” content of
statement to be
attached to Form 5471
1
During the tax year, was the sum of the CFC’s foreign base company
income (determined without regard to deductions) and gross
insurance income less than the lesser of 5% of gross income or $1
million?
In other words, is line 7
less than line 8 and less
than $1M?
DM
De minimis
Amount excluded by
reason of the de
minimis rule (but only to
the extent not already
included in amounts
below)
2
During the tax year, did the CFC receive any item of income that was
subject to an effective rate of income tax imposed by a foreign country
greater than 90% of the maximum rate of tax specified in section 11?
In other words, is
line 13g, 14d, 15d, 16d,
18d, or 19d of Worksheet
A greater than zero?
HT
High Tax
Sum of the amounts
from lines 13g, 14d,
15d, 16d, 18d, and 19d
3
During the tax year, was the CFC’s foreign personal holding company
income, foreign base company sales income, or foreign base
company services income reduced so as to take into account any
deductions (including taxes)?
In other words, is
line 13b, 13d, 13e, 14b,
15b, or 16b of Worksheet
A greater than zero?
DED
Deductions
taken into
account
Sum of the amounts
from lines 13b, 13d,
13e, 14b, 15b, and 16b
4
During the tax year, did the CFC have any gains or losses that (i) arise
out of commodity hedging transactions, (ii) are active business gains
or losses from the sale of commodities (and substantially all of the
corporation’s commodities are property described in section 1221(a)
(1), (2), or (8)), or (iii) are foreign currency gains or losses (as defined
in section 988(b)) attributable to any section 988 transactions?
In other words, are any
amounts described in
section 954(c)(1)(C)(i),
(ii), or (iii) excluded from
line 1c of Worksheet A?
AHC
Active/hedging
commodities
Sum of the excluded
amounts described in
section 954(c)(1)(C)(i),
(ii), and (iii)
5
During the tax year, did the CFC have excess foreign currency gains
over foreign currency losses as defined in section 988(b) attributable
to any section 988 transaction directly related to the business needs of
the foreign corporation?
In other words, are any
amounts excluded from
line 1d of Worksheet A by
reason of being
attributable to a
transaction(s) directly
related to the business
needs of the foreign
corporation?
6
During the tax year, did the CFC receive, from a person other than a
In other words, are any
related person within the meaning of section 954(d)(3), rents or
amounts described in
royalties that were derived in the active conduct of a trade or business? section 954(c)(2)(A)
excluded from line 1a of
Worksheet A?
7
During the tax year, did the CFC derive, in the conduct of a banking
business, interest that is export financing interest?
In other words, are any
amounts described in
section 954(c)(2)(B)
excluded from line 1a of
Worksheet A?
8
During the tax year, was the CFC a regular dealer in property
described in section 954(c)(1)(B), forward contracts, option contracts,
or similar financial instruments (including notional principal contracts
and all instruments referenced to commodities)? If so, did the foreign
corporation derive any item of income, gain, deduction, or loss (other
than any item described in section 954(c)(1)(A), (E), or (G)) from any
transaction entered into in the ordinary course of its trade or business
as a regular dealer?
9
During the tax year, was the CFC a securities dealer within the
meaning of section 475? If so, did the foreign corporation derive any
interest or dividend or equivalent amount described in section 954(c)
(1)(E) or (G) from any transaction entered into in the ordinary course of
its trade or business as a securities dealer?
Instructions for Form 5471 (Rev. February 2020)
BN
Active rents/
royalties
Amount excluded
EF
Certain export
financing
Amount excluded
In other words, are any
amounts described in
section 954(c)(2)(C)(i)
excluded from line 1a of
Worksheet A?
RD
Regular dealers Amount excluded
In other words, are any
amounts described in
section 954(c)(2)(C)(ii)
excluded from line 1a of
Worksheet A?
SD
Securities
dealers
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ARR
Business needs Amount excluded
Amount excluded
Form 5471, Schedule G, Line 19, continued
Question
See Worksheet A in the
Schedule I Instructions
If “Yes,”
Corresponding Code
to enter on
Schedule G, line 19
Code
Description
If “Yes,” content of
statement to be
attached to Form 5471
10 During the tax year, did the CFC receive dividends* or
interest** from a related person that (i) is a corporation
created or organized under the laws of the same country
under the laws of which the CFC is created or
organized, and (ii) has a substantial part of its assets
used in its trade or business located in the same foreign
country?
*Dividends (other than dividends with respect to any
stock, which is attributable to earnings and profits of the
distributing corporation, accumulated during any period
during which the person receiving such dividend did not
hold such stock directly or indirectly through a chain of
one or more subsidiaries each of which meets the
requirements (i) and (ii)).
**Interest (other than interest that reduces the payor's
subpart F income or creates or increases a deficit that
may reduce the subpart F income of the payor or
another CFC).
In other words, are any
amounts described in section
954(c)(3)(A)(i) excluded from
line 1a of Worksheet A?
SCDI
Same country
dividends/
interest
Amount excluded
11 During the tax year, did the CFC receive, from a
corporation that is a related person, rents or royalties*
for the use of, or privilege of using, property within the
country under the laws of which the CFC is created or
organized?
*Rents or royalties (other than rents or royalties that
reduce the payor's subpart F income or create or
increase a deficit that may reduce the subpart F income
of the payor or another CFC).
In other words, are any
amounts described in section
954(c)(3)(A)(ii) excluded
from line 1a of Worksheet A?
SCRR
Same country
rents/royalties
Amount excluded
12 During the tax year, did the CFC receive or accrue from
a related CFC dividends, interest (including factoring
income treated as income equivalent to interest for
purposes of section 954(c)(1)(E)), rents, or royalties
attributable or properly allocable to income of the related
person which is neither subpart F income nor income
treated as effectively connected with the conduct of a
trade or business in the United States?
In other words, are any
amounts excluded from
line 1a of Worksheet A by
reason of the look through
rule described in section
954(c)(6)?
LT
Look through
Amount excluded
13 During the tax year, did the CFC derive income (either
directly or through a branch or similar establishment, for
example, disregarded entity) in connection with the
purchase or sale from, to, or on behalf of a related
person, of agricultural commodities not grown in the
United States in commercially marketable quantities?
In other words, are any
amounts excluded from line 3
of Worksheet A by reason of
the special rule in
Regulations section
1.954-3(a)(1)(ii)?
AC
Agricultural
commodities
Amount excluded
14 During the tax year, did the CFC derive income (either
directly or through a branch or similar establishment, for
example, disregarded entity) in connection with the
purchase or sale from, to, or on behalf of a related
person, of personal property manufactured in the same
country under the laws of which the CFC is created or
organized?
In other words, are any
amounts that are derived in
connection with property that
does not satisfy section
954(d)(1)(A) excluded from
line 3 of Worksheet A (that is,
income excluded by reason
of Regulations section
1.954-3(a)(2))?
SCM
Same country
manufacturing
Amount excluded
15 During the tax year, did the CFC derive income (either
directly or through a branch or similar establishment, for
example, disregarded entity) in connection with the
purchase or sale from, to, or on behalf of a related
person, of personal property purchased or sold for use
or consumption in the same country under the laws of
which the CFC is created or organized?
In other words, are any
amounts that are derived in
connection with property that
does not satisfy section
954(d)(1)(B) excluded from
line 3 of Worksheet A (that is,
income excluded by reason
of Regulations section
1.954-3(a)(3))?
SCSU
Same country
sales/use
Amount excluded
16 During the tax year, did the CFC derive income (either
directly or through a branch or similar establishment, for
example, disregarded entity) in connection with the
purchase or sale from, to, or on behalf of a related
person, of personal property manufactured by the CFC
within the meaning of Regulations section 1.954-3(a)(4)
(ii) or (iii)?
In other words, are any
amounts excluded from line 3
of Worksheet A by reason of
Regulations section
1.954-3(a)(4)(ii) or (iii)?
PM
Physical
manufacturing
Amount excluded
-12-
Instructions for Form 5471 (Rev. February 2020)
Form 5471, Schedule G, Line 19, continued
Question
See Worksheet A in
the Schedule I
Instructions
17
During the tax year, did the CFC derive income (either directly or
through a branch or similar establishment, for example, disregarded
entity) in connection with the purchase or sale from, to, or on behalf of
a related person, of personal property manufactured by the CFC
within the meaning of Regulations section 1.954-3(a)(4)(iv)?
In other words, are any
amounts excluded from
line 3 of Worksheet A
by reason of
Regulations section
1.954-3(a)(4)(iv)?
SC
Substantial
contribution
Amount excluded
18
(a) During the tax year, did the CFC derive income in connection with
the purchase from or sale to a related or unrelated person of personal
property manufactured or sold for use outside the country under the
laws of which the CFC is created or organized (for example, property
manufactured or sold by a disregarded entity of the CFC)? (b) During
the tax year, did the CFC derive income (either directly or through a
branch or similar establishment, for example, disregarded entity) in
connection with the purchase or sale from, to, or on behalf of a
related party (for example, purchase or sales commission income)?
In other words, are any
amounts excluded from
line 3 of Worksheet A
by reason of
disregarding a branch
or similar establishment
(including a
disregarded entity) of
the CFC corporation as
separate from the CFC?
BR
Branch
Amount excluded
19
During the tax year, was the CFC an eligible CFC (as defined in
section 954(h)(2)) that derived qualified banking or financing income
(as defined in section 954(h)(3))?
In other words, are any
amounts excluded from
lines 1a–1i of
Worksheet A by reason
of the special rule
described in section
954(h)?
AF
Active
financing
Amount excluded
20
During the tax year, was the CFC a qualifying insurance company (as In other words, are any
defined in section 953(e)(3)) that derived qualified insurance income amounts excluded from
(as defined in section 954(i)(2))?
lines 1a–1i of
Worksheet A by reason
of the special rule
described in section
954(i)?
AI
Active
insurance
Amount excluded
21
During the tax year, did the subpart F income of the CFC exceed the
earnings and profits of such corporation?
EP
Earnings &
profits
limitation
Excess of line 36 over
line 37c
22
Is the U.S. person filing this return relying on any exception(s),
exclusion(s), or other provision(s) not listed above to reduce or
exclude any amounts reported or reportable as subpart F income (of
or with respect to the CFC)?
XX
Other
Amount excluded,
reduction amount, or
other amount not reported
or reportable
Instructions for Form 5471 (Rev. February 2020)
In other words, is
line 36 of Worksheet A
greater than line 37c?
-13-
If “Yes,”
Code
Corresponding Description
Code to enter
on Schedule G,
line 19
If “Yes,” content of
statement to be
attached to Form 5471
Question 20
For the foreign corporation’s annual
accounting period with respect to which
reporting is being made on this Form
5471, if the foreign corporation is required
to file a U.S. income tax return (for
example, Form 1120-F), check the “Yes,”
box if the foreign corporation has interest
expense disallowed under section 163(j).
If “Yes,” enter the amount from the current
year Form 8990, line 31.
Question 21
For the foreign corporation’s annual
accounting period with respect to which
reporting is being made on this Form
5471, if the foreign corporation is required
to file a U.S. income tax return (for
example, Form 1120-F), check the “Yes,”
box if the foreign corporation has
previously disallowed interest expense
under section 163(j) carried forward to the
current tax year. If “Yes,” enter the amount
from the prior year Form 8990, line 31.
Schedule I
Use Schedule I to report in U.S. dollars the
U.S. shareholder's pro rata share of
income from the foreign corporation
reportable under subpart F and other
income realized from a corporate
distribution.
Certain filers may be able to use
alternative information (as defined in
section 3.01 of Rev. Proc. 2019-40) to
determine certain amounts in this
schedule. See Rev. Proc. 2019-40 for
more details.
Note. A separate Schedule I must be
filed by or for each Category 4 or 5 U.S.
shareholder of the foreign corporation with
respect to which reporting is furnished on
this Form 5471. However, Category 5
filers who are related constructive U.S.
shareholders are not required to file
Schedule I for foreign-controlled
corporations. See Certain Category 1 and
Category 5 Filers under Categories of
Filers.
Line 1
Subpart F income. U.S. shareholders of
CFCs with subpart F income must report
that income on their tax returns. For more
information, see sections 245A, 951, 952,
and 964(e).
Line 1a
Enter the foreign-source portion of any
subpart F inclusions attributable to the
sale or exchange by a CFC of stock in
another foreign corporation described in
section 964(e)(4).
Line 1b
Enter the amount of hybrid dividends
received from any other CFC that is
treated as subpart F income under section
245A(e)(2). A hybrid dividend generally is
any dividend from a CFC for which the
CFC received a deduction (or other tax
benefit) for foreign tax purposes.
Lines 1c through 1f
Enter on lines 1c through 1f the amounts
from Worksheet A, lines 63, 65, 67, and
69, respectively.
Use Worksheet A, later, in these
instructions, to compute the U.S.
shareholder's pro rata share of subpart F
income of the CFC, which is reportable on
lines 1c through 1f. Do not include any
income includible on Form 5471,
Schedule I, lines 1a and 1b, or any income
includible under section 951A
(Schedule I-1 is used to provide
information relating to section 951A).
Subpart F income reportable on lines 1c
through 1f includes the following.
• Adjusted net foreign base company
income (lines 1 through 17).
• Adjusted net insurance income
(line 18).
• Adjusted net related person insurance
income (line 19).
• International boycott income (line 20).
• Illegal bribes, kickbacks, and other
payments (line 21).
• Income described in section 952(a)(5)
(line 22).
Important. If the subpart F income of any
CFC for any tax year was reduced
because of the current E&P limitation, any
excess of the E&P of the CFC for any
subsequent tax year over the subpart F
income of the CFC for the tax year must
be recharacterized as subpart F income.
As a result, if the foreign corporation has
E&P for the taxable period covered by this
return that is subject to recapture as a
result of a prior-year E&P limitation, add
such recapture amount to the result from
Worksheet A, Line 69, and include the
combined amount on Line 1f (Other
subpart F income). See the instructions for
Line 37. Current E&P limitation, later, for a
discussion of the current-year E&P
limitation.
Line 2
Report on line 2 earnings invested in U.S.
property (Worksheet B).
Line 3
If the foreign corporation with respect to
which information is being reported on this
Form 5471 is a specified 10%-owned
foreign corporation (as defined in section
245A(b)), for each domestic corporate
shareholder of that specified 10%-owned
foreign corporation, enter on line 3 the
foreign-source portion (as defined in
section 245A(c)) of all dividends paid by
that specified 10%-owned foreign
corporation to the domestic corporate
shareholder. Include gain from the sale of
stock of the foreign corporation that is
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treated as a dividend under sections
1248(a) and (j).
The domestic corporate shareholder
will take this line 3 amount into account
when determining the amount to enter on
Form 1120, Schedule C, line 13, column
(a), or the comparable line of other
corporate income tax returns. In doing so,
the domestic corporate shareholder will
take into account the rules of section
246(c)(5) and other applicable rules (such
as those specified in sections 246(a)(1),
246(c)(1), 1059, and Temporary
Regulations section 1.245A-5T).
If the foreign corporation with respect to
which information is being reported on this
Form 5471 disposed of an asset or assets
in one or more extraordinary dispositions
within the meaning of Temporary
Regulations section 1.245A-5T(c)(3)(ii) in
a prior taxable period of the foreign
corporation, attach a statement to this
Form 5471 describing each such
transaction, including the resulting amount
of extraordinary disposition earnings and
profits within the meaning of Temporary
Regulations section 1.245A-5T(c)(3)(C).
Also include a statement of the balance of
the extraordinary disposition account of
the U.S. shareholder of the foreign
corporation with respect to which
information is being reported on this Form
5471 as of the end of the reporting period.
If the U.S. shareholder of the foreign
corporation with respect to which
information is being reported on this Form
5471 had one or more reductions in
ownership of the foreign corporation that
resulted in one or more extraordinary
reductions within the meaning of
Temporary Regulations section
1.245A-5T(e)(2)(i) in a prior or current tax
period of the foreign corporation, attach a
statement to this Form 5471 providing
each extraordinary reduction amount
within the meaning of Temporary
Regulations section 1.245A-5T(e)(1). If
the U.S. shareholder of the foreign
corporation with respect to which
information is being reported on this Form
5471 intends to elect to close the tax year
of the CFC pursuant to Temporary
Regulations section 1.245A-5T(e)(3)(i)
with respect to one or more extraordinary
reductions, attach a statement to this
Form 5471 following the procedures set
forth in that Regulation.
If the foreign corporation with respect to
which information is being reported on this
Form 5471 distributed one or more
ineligible amounts within the meaning of
Temporary Regulations section
1.245A-5T(b) to the U.S. shareholder of
the foreign corporation for which
information is being reported on this Form
5471 in a prior or current tax period of the
foreign corporation, attach a statement to
this Form 5471 separately providing the
Instructions for Form 5471 (Rev. February 2020)
amount of each ineligible amount
distributed attributable to extraordinary
disposition E&P and each ineligible
amount distributed attributable to
extraordinary reduction E&P within the
meaning of Temporary Regulations
sections 1.245A-5T(c) and (e),
respectively.
If the foreign corporation with respect to
which information is being reported on this
Form 5471 received one or more tiered
extraordinary disposition amounts or
tiered extraordinary reduction amounts
within the meaning of Temporary
Regulations sections 1.245A-5T(d)(2) or
1.245A-5T(f)(2) in a prior or current tax
period of the foreign corporation, attach a
statement to this Form 5471 separately
providing the amount of each tiered
extraordinary disposition amount and
tiered extraordinary reduction amount
received by the foreign corporation, as
well as the name and employer
identification number of the distributor, if
any.
Line 4
Enter the factoring income (as defined in
section 864(d)(1)) if no subpart F income
is reported on line 1a, Worksheet A,
because of the operation of the de minimis
rule (see lines 1a and 10 of Worksheet A
and the related instructions at Line 1a and
Line 10. De minimis rule).
Reporting amounts on lines 1
through 4 on your income tax
return
U.S. shareholders should compute their
pro rata share of the income on Form
5471, Schedule I, lines 1a through 1f, 2,
and 4. For a corporate shareholder, enter
the result on Form 1120, Schedule C,
line 16c, or on the comparable line of other
corporate tax returns. For a noncorporate
U.S. shareholder, enter the result on
Schedule 1 (Form 1040 or 1040-SR),
line 8 (Other income), or on the
comparable line of other noncorporate tax
returns.
Line 5
Enter the dividends you received from the
foreign corporation that were not
previously taxed under subpart F in the
current year or in any prior year.
Instructions for Form 5471 (Rev. February 2020)
-15-
Line 6
If previously taxed E&P (PTEP) described
in section 959(a) or (b) was distributed,
enter the amount of foreign currency gain
or (loss) on the distribution, computed
under section 986(c). See Notice 88-71,
1988-2 C.B. 374, for rules for computing
section 986(c) gain or (loss).
For a corporate U.S. shareholder,
include the gain or (loss) as “Other
income” on Form 1120, line 10, or on the
comparable line of other corporate tax
returns. For a noncorporate U.S.
shareholder, include the result as “Other
income” on Schedule 1 (Form 1040 or
1040-SR), line 8, or on the comparable
line of other noncorporate tax returns.
Certain current year deficits of a
member of the same chain of corporations
may be considered in determining subpart
F income. See section 952(c)(1)(C).
Worksheet A
Summary of U.S. Shareholder’s Pro Rata Share of Subpart F Income of a CFC (See Worksheet A
instructions, later.) Enter the amounts on lines 1a through 62, 64, 66, and 68 in functional currency.
1
Gross foreign personal holding company income:
a Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A)
1a
(excluding amounts described in sections 954(c)(2), (3), and (6))
b Excess of gains over losses from certain property transactions
1b
(section 954(c)(1)(B))
1c
c Excess of gains over losses from commodity transactions (section 954(c)(1)(C))
1d
d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D))
1e
e Income equivalent to interest (section 954(c)(1)(E))
1f
f Net income from a notional principal contract (section 954(c)(1)(F))
1g
g Payments in lieu of dividends (section 954(c)(1)(G))
h Certain amounts received for services under personal service
1h
contracts (see section 954(c)(1)(H))
i Certain amounts from sales of partnership interests to which the
1i
look-through rule of section 954(c)(4) applies
2 Gross foreign personal holding company income. Add lines 1a through 1i
3 Gross foreign base company sales income (see section 954(d))
4 Gross foreign base company services income (see section 954(e))
5 Gross foreign base company income. Add lines 2 through 4
6 Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 18 and
19)
7 Gross foreign base company income and gross insurance income. Add lines 5 and 6
8 Enter 5% of total gross income (as computed for income tax purposes)
9 Enter 70% of total gross income (as computed for income tax purposes)
10 If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 19
11 If line 7 is more than line 9, enter total gross income (as computed for income tax purposes)
12 Total adjusted gross foreign base company income and insurance income (enter the greater of
line 7 or line 11)
13 Adjusted net foreign personal holding company income:
13a
a Enter amount from line 2
13b
b Expenses directly related to amount on line 2
13c
c Subtract line 13b from line 13a
13d
d Related person interest expense (see section 954(b)(5))
e Other expenses allocated and apportioned to the amount on line 2
under section 954(b)(5)
f Net foreign personal holding company income. Subtract the sum of
lines 13d and 13e from line 13c
g Net foreign personal holding company income excluded under
high-tax exception
h Subtract line 13g from line 13f
14 Adjusted net foreign base company sales income:
a Enter amount from line 3
b Expenses allocated and apportioned to the amount on line 3 under
section 954(b)(5)
c Net foreign base company sales income. Subtract line 14b from line 14a
d Net foreign base company sales income excluded under high-tax exception
e Subtract line 14d from line 14c
15 Adjusted net foreign base company services income:
a Enter amount from line 4
b Expenses allocated and apportioned to line 4 under section 954(b)(5)
c Net foreign base company services income. Subtract line 15b from line 15a
d Net foreign base company services income excluded under high-tax exception
e Subtract line 15d from line 15c
16
a
b
c
d
e
Adjusted net full inclusion foreign base company income:
Enter the excess, if any, of line 11 over line 7
Expenses allocated and apportioned under section 954(b)(5)
Net full inclusion foreign base company income. Subtract line 16b from line 16a
Net full inclusion foreign base company income excluded under high-tax exception
Subtract line 16d from line 16c
-16-
2
3
4
5
6
7
8
9
10
11
12
13e
13f
13g
13h
14a
14b
14c
14d
14e
15a
15b
15c
15d
15e
16a
16b
16c
16d
16e
Instructions for Form 5471 (Rev. February 2020)
Worksheet A
Worksheet A (continued) (See instructions.)
17
18
a
b
c
d
e
19
a
b
c
d
e
20
21
22
23
24
25
26
27
28
29
30
31
32
Adjusted net foreign base company income. Add lines 13h, 14e, 15e, and 16e . . . . .
Adjusted net insurance income (other than related person insurance income):
Enter amount from line 6 (other than related person insurance income)
18a
Expenses allocated and apportioned to the amount on line 18a under
section 953 . . . . . . . . . . . . . . . . . . . . 18b
Net insurance income. Subtract line 18b from line 18a . . . . . . 18c
Net insurance income excluded under high-tax exception . . . . . 18d
Subtract line 18d from line 18c . . . . . . . . . . . . . . . . . . . . . .
Adjusted net related person insurance income:
Enter amount from line 6 that is related person insurance income . . 19a
Expenses allocated and apportioned to the amount on line 19a under
section 953 . . . . . . . . . . . . . . . . . . . . 19b
Net related person insurance income. Subtract line 19b from line 19a . 19c
Net related person insurance income excluded under high-tax exception 19d
Subtract line 19d from line 19c . . . . . . . . . . . . . . . . . . . . . .
International boycott income (section 952(a)(3)) . . . . . . . . . . . . . . . .
lllegal bribes, kickbacks, and other payments (section 952(a)(4)) . . . . . . . . . . .
Income described in section 952(a)(5) (see instructions)
. . . . . . . . . . . . .
Subpart F income before application of sections 952(b) and (c) and section 959(b). Add lines 17,
18e, 19e, and 20 through 22 . . . . . . . . . . . . . . . . . . . . . . .
Enter the portion of line 13h that is U.S. source income effectively
connected with a U.S. trade or business (section 952(b)) . . . . . .
24
Exclusions under section 959(b) that apply to line 13h amount . . . .
25
Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract the sum of
lines 24 and 25 from line 13h . . . . . . . . . . . . . . . . . . . . . .
Enter the portion of line 14e that is U.S. source income effectively
connected with a U.S. trade or business (section 952(b)) . . . . . .
27
Exclusions under section 959(b) that apply to line 14e amount . . . .
28
Section 954(d) subpart F Foreign Base Company Sales Income. Subtract the sum of lines 27
and 28 from line 14e. . . . . . . . . . . . . . . . . . . . . . . . . .
Enter the portion of line 15e that is U.S. source income effectively
30
connected with a U.S. trade or business (section 952(b)) . . . . . .
Exclusions under section 959(b) that apply to line 15e amount . . . .
31
Section 954(e) subpart F Foreign Base Company Services Income. Subtract the sum of lines
30 and 31 from line 15e . . . . . . . . . . . . . . . . . . . . . . . .
.
17
.
18e
.
.
.
.
19e
20
21
22
.
23
.
26
.
29
.
32
.
.
35
36
.
38
33
Enter the sum of the portion of lines 16e, 18e, 19e, 20, 21, and 22 that is
U.S. source income effectively connected with a U.S. trade or business
33
(section 952(b)) . . . . . . . . . . . . . . . . . . .
34
Exclusions under section 959(b) that apply to line 16e, 18e, 19e, 20, 21,
34
and 22 amounts . . . . . . . . . . . . . . . . . . .
35
Other subpart F income. Subtract the sum of lines 33 and 34 from the sum of lines 16e, 18e,
19e, 20, 21, and 22 . . . . . . . . . . . . . . . . . . . . . . . . . .
36
Total subpart F income. Add lines 26, 29, 32, and 35 . . . . . . . . . . . . . .
37
Current E&P limitation computation:
a Current E&P . . . . . . . . . . . . . . . . . . . . 37a
b Tested loss (enter as a positive number – see instructions) . . . . . 37b
c Total of line 37a and line 37b . . . . . . . . . . . . . . 37c
38
Enter the smaller of line 36 or line 37c . . . . . . . . . . . . . . . . . . .
Instructions for Form 5471 (Rev. February 2020)
-17-
Worksheet A
Worksheet A (continued) (See instructions.)
39
If the amount on line 37c is less than the amount on line 36, allocate the subpart F income remaining (after having been limited)
to lines 40, 41, 42, and 43 below in the manner prescribed by Regulations section 1.952-1(e). If the amount on line 37c is
greater than or equal to the amount on line 36, enter the amount from line 26 onto line 40, enter the amount from line 29 onto
line 41, enter the amount from line 32 onto line 42, and enter the amount from line 35 onto line 43.
40
41
42
43
44
45
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal . . . . . . .
Section 954(c) subpart F Foreign Base Company Sales Income subtotal . . . . . . . . .
Section 954(c) subpart F Foreign Base Company Services Income subtotal . . . . . . . .
Other subpart F income subtotal . . . . . . . . . . . . . . . . . . . . . .
Shareholder’s pro rata share of line 40 . . . . . . . . . . .
44
Shareholder’s pro rata share of export trade income that applies to line
44 amount (see section 970(a)) . . . . . . . . . . . . . .
45
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 45
from line 44 . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Shareholder’s pro rata share of line 41. . . . . . . . . . . .
47
Shareholder’s pro rata share of export trade income that applies to line
47 amount (see section 970(a)) . . . . . . . . . . . . . .
48
Section 954(c) subpart F Foreign Base Company Sales Income subtotal. Subtract line 48 from line
47 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Shareholder’s pro rata share of line 42 . . . . . . . . . . .
50
Shareholder’s pro rata share of export trade income that applies to line
50 amount (see section 970(a)) . . . . . . . . . . . . . .
51
Section 954(c) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from
line 50 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Shareholder’s pro rata share of line 43 . . . . . . . . . . .
53
Shareholder’s pro rata share of export trade income that applies to line
54
53 amount (see section 970(a)) . . . . . . . . . . . . . .
Other subpart F income subtotal. Subtract line 54 from line 53 . . . . . . . . . . . .
Add lines 46, 49, 52, and 55 . . . . . . . . . . . . . . . . . . . . . . . .
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
Divide the number of days in the tax year that the corporation was a
CFC by the number of days in the tax year and multiply the result by
line 56 . . . . . . . . . . . . . . . . . . . . . .
57
Dividends paid to any other person with respect to your stock during
the tax year . . . . . . . . . . . . . . . . . . . .
58
Divide the number of days in the tax year you did not own such stock
59
by the number of days in the tax year and multiply the result by line 56 .
Enter the smaller of line 58 or line 59 . . . . . . . . . . . .
60
Shareholder’s pro rata share of subpart F income. Subtract line 60 from line 57 . . . . . .
Amount of line 61 that applies to section 954(c) subpart F Foreign Personal Holding Company
Income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Translate the amount on line 62 from functional currency to U.S. dollars at the average exchange
rate. See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1c . . . . .
Amount of line 61 that applies to section 954(c) subpart F Foreign Base Company Sales Income .
Translate the amount on line 64 from functional currency to U.S. dollars at the average exchange
rate. See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1d . . . . .
Amount of line 61 that applies to section 954(c) subpart F Foreign Base Company Services Income
Translate the amount on line 66 from functional currency to U.S. dollars at the average exchange
rate. See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1e . . . . .
Amount of line 61 that applies to other subpart F income . . . . . . . . . . . . . .
Translate the amount on line 68 from functional currency to U.S. dollars at the average exchange
rate. See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1f. . . . . .
-18-
40
41
42
43
46
49
52
55
56
61
62
63
64
65
66
67
68
69
Instructions for Form 5471 (Rev. February 2020)
Worksheet A Instructions
Foreign base company income.
Foreign base company income generally
does not include the following.
• Foreign base company shipping
income as defined in former section
954(f).
• Foreign personal holding company
income derived in the active conduct of a
banking, finance, or similar business
(section 954(h)).
• Exempt insurance income under
section 953(e) and certain investment
income of a qualifying insurance company
or a qualifying insurance branch (section
953(a)(2) and 954(i)).
• Certain income derived in the ordinary
course of business of a securities dealer
(section 954(c)(2)(C)(i)).
Line 1a. Do not include the following:
• Interest from conducting a banking
business that is “export financing interest”
(section 904(d)(2)(G));
• Rents and royalties from actively
conducting a trade or business received
from a person other than a “related
person” (as defined in section 954(d)(3));
and
• Dividends, interest, rent, or royalty
income from related corporate payors
described in sections 954(c)(3) or (6).
However, see section 964(e) for an
exception to section 954(c)(3) and section
964(e)(4) for an exception to section
954(c)(6).
Interest income includes factoring
income arising when a person acquires a
trade or service receivable (directly or
indirectly) from a related person. The
income is treated as interest on a loan to
the obligor under section 864(d)(1) and
generally is not eligible for the de minimis,
export financing, and related party
exceptions to the inclusion of subpart F
income. Also, a trade or service receivable
acquired or treated as acquired by a CFC
from a related U.S. person is considered
an investment in U.S. property for
purposes of section 956 (Worksheet B) if
the obligor is a U.S. person.
Line 1b. Enter the excess of gains over
losses from the sale or exchange of:
• Property that produces the type of
income reportable on line 1a;
• An interest in a trust, partnership, or
REMIC. However, see the instructions for
Line 1i for an exception that provides for
look-through treatment for certain sales of
partnership interests; or
• Property that does not produce any
income.
Do not include the following.
• Income, gain, deduction, or loss from
any transaction (including a hedging
transaction) and transactions involving
physical settlement of a regular dealer in
property, forward contracts, option
contracts, and similar financial instruments
(section 954(c)(2)(C)).
• Gains and losses from the sale or
exchange of any property that, in the
hands of the CFC, is property described in
section 1221(a)(1).
Line 1c. Enter the excess of gains over
losses from transactions (including
futures, forward, and similar transactions)
in any commodities. See section 954(c)(1)
(C) for exceptions. See section 954(c)(5)
for a definition and special rules relating to
commodity transactions.
Line 1d. Enter the excess of foreign
currency gains over foreign currency
losses from section 988 transactions. An
exception applies to transactions directly
related to the business needs of a CFC.
Line 1e. Enter any income equivalent to
interest, including income from
commitment fees (or similar amounts) for
loans actually made.
Line 1f. Include net income from notional
principal contracts (except a contract
entered into to hedge inventory property).
Line 1g. Include payments in lieu of
dividends that are made as required under
section 1058.
Line 1h. Enter amounts received:
• Under a contract under which the
corporation is to furnish personal services
if (a) some person other than the
corporation has a right to designate (by
name or by description) the individual who
is to perform the services, or (b) the
individual who is to perform the services is
designated (by name or by description) in
the contract; and
• From the sale or other disposition of
such a contract.
Note. The above rules apply with respect
to amounts received for services under a
particular contract only if at some time
during the tax year 25% or more in value
of the outstanding stock of the corporation
is owned, directly or indirectly, by or for
the individual who has performed, is to
perform, or may be designated (by name
or by description) as the one to perform,
such services.
Line 1i. For tax years beginning after
December 31, 2004, in the case of any
sale by a CFC of an interest in a
partnership with respect to which the CFC
is a 25% owner (defined below), such
CFC is treated for purposes of computing
its foreign personal holding company
income as selling the proportionate share
of the assets of the partnership
attributable to such interest. Thus, the sale
of a partnership interest by a CFC that
meets the ownership threshold constitutes
subpart F income only to the extent that a
proportionate sale of the underlying
partnership assets attributable to the
Instructions for Form 5471 (Rev. February 2020)
-19-
partnership interest would constitute
subpart F income. Do not report these
amounts on line 1b. Instead, report them
on line 1i.
25% owner. For purposes of these
rules, a 25% shareholder is a CFC that
owns directly 25% or more of the capital or
profits interest in a partnership. For
purposes of the preceding sentence, if a
CFC is a shareholder or partner of a
corporation or partnership, the CFC is
treated as owning directly its proportionate
share of any such capital or profits interest
held directly or indirectly by such
corporation or partnership. If a CFC is
treated as owning a capital or profits
interest in a partnership under
constructive ownership rules similar to the
rules of section 958(b), the CFC shall be
treated as owning such interest directly or
indirectly for purposes of this definition.
Line 10. De minimis rule. If the sum of
foreign base company income
(determined without regard to section
954(b)(5)) and gross insurance income
(as defined in section 954(b)(3)(C)) for the
tax year is less than the smaller of 5% of
gross income for income tax purposes, or
$1 million, then no portion of the gross
income for the tax year is treated as
foreign base company income or
insurance income. In this case, enter zero
on line 10 and skip lines 11 through 19.
Otherwise, go to line 11.
Line 11. Full inclusion rule. If the sum
of foreign base company income
(determined without regard to section
954(b)(5)) and gross insurance income for
the tax year exceeds 70% of gross income
for income tax purposes, the entire gross
income for the tax year must (subject to
the high tax exception described below,
the section 952(b) exclusion, and the
deductions to be taken into account under
section 954(b)(5)) be treated as foreign
base company income or insurance
income, whichever is appropriate. In this
case, enter total gross income (for income
tax purposes) on line 11. Otherwise, enter
zero.
Lines 13g, 14d, 15d, 16d, 18d, and 19d.
Exception for certain income subject
to high foreign taxes. Foreign base
company income and insurance income
does not include any item of income
received by a CFC if the taxpayer
establishes that such income was subject
to an effective rate of income tax imposed
by a foreign country that is greater than
90% of the maximum rate of tax specified
in section 11. For more information, see
section 954(b)(4) and Regulations section
1.954-1(d)(1).
Line 18. Adjusted net insurance income. In determining a shareholder's pro
rata share of the subpart F income of a
CFC, insurance income is any income:
• That is attributable to the issuing (or
reinsuring) of any insurance or annuity
contract:
1. For property in, liability from an
activity in, or for the lives or health of
residents of a country other than the
country under the laws of which the CFC
is created or organized; or
2. For risks not described in 1 above,
resulting from any arrangement in which
another corporation receives a
substantially equal amount of premiums or
other consideration for issuing (or
reinsuring) a contract described in 1
above.
• That would, subject to the modifications
provided in sections 953(b)(1) and 953(b)
(2), be taxed under subchapter L
(insurance company tax) if such income
were income of a domestic insurance
company.
Line 19. Adjusted net related person
insurance income. In determining a
shareholder's pro rata share of the subpart
F income of a CFC, related person
insurance income is any insurance income
(within the meaning of section 953(a))
attributable to a policy of insurance or
reinsurance for which the person insured
(directly or indirectly) is a U.S. shareholder
(as defined in section 953(c)(1)(A)) in a
CFC, or a related person (as defined in
section 953(c)(6)) to such a shareholder.
In such case, the pro rata share referred to
above is to be determined under the rules
of section 953(c)(5).
Exceptions. The above definition does
not apply to any foreign corporation if:
• At all times during the foreign
corporation's tax year, less than 20% of
the total combined voting power of all
classes of stock of the corporation entitled
to vote, and less than 20% of the total
value of the corporation, is owned (directly
or indirectly under the principles of section
883(c)(4)) by persons who are (directly or
indirectly) insured under any policy of
insurance or reinsurance issued by the
corporation or who are related persons to
any such person;
• The related person insurance income
(determined on a gross basis) of the
corporation for the tax year is less than
20% of its insurance income for the tax
year determined without regard to the
provisions of section 953(a)(1) that limit
insurance income to income from
countries other than the country in which
the corporation was created or organized;
or
• The corporation:
1. Elects to treat its related person
insurance income for the tax year as
income effectively connected with the
conduct of a trade or business in the
United States;
2. Elects to waive all treaty benefits
(other than from section 884) for related
person insurance income; and
3. Meets any requirement the IRS
may prescribe to ensure that any tax on
such income is paid.
This election will not be effective if the
corporation was a disqualified corporation
(as defined in section 953(c)(3)(E)) for the
tax year for which the election was made
or for any prior tax year beginning after
1986. See section 953(c)(3)(D) for special
rules for this election.
Mutual life insurance companies. The
related person insurance income rules
also apply to mutual life insurance
companies under regulations prescribed
by the Secretary. For these purposes,
policyholders must be treated as
shareholders.
Line 20. International boycott income.
If a CFC or a member of a controlled
group (within the meaning of section
993(a)(3)) that includes the CFC has
operations in, or related to, a country (or
with the government, a company, or a
national of a country) that requires
participation in or cooperation with an
international boycott as a condition of
doing business within such country or with
the government, company, or national of
that country, a portion of the CFC's
income is included in subpart F income.
The amount included is determined by
multiplying the CFC's income (other than
income included under section 951 and
U.S. source effectively connected
business income described in section
952(b)) by the international boycott factor.
This factor is a fraction determined on
Schedule A (Form 5713).
Special rule. If the shareholder of a CFC
can clearly demonstrate that the income
earned for the tax year is from specific
operations, then, instead of applying the
international boycott factor, the addition to
subpart F income is the amount
specifically from the operations in which
there was participation in or cooperation
with an international boycott. See
Schedule B (Form 5713).
Line 21. Illegal bribes, kickbacks, and
other payments. Enter the total of any
illegal bribes, kickbacks, or other
payments (within the meaning of section
162(c)) paid by or on behalf of the
corporation, directly or indirectly, to an
official, employee, or agent of a
government.
-20-
Line 22. Income described in section
952(a)(5). The income of a CFC derived
from any foreign country during any period
during which section 901(j) applies to such
foreign country will be deemed to be
income to the U.S. shareholders of such
CFC. As of the date these instructions
were revised, section 901(j) applied to:
Iran, North Korea, Sudan, and Syria.
Note. Prior to December 22, 2015,
section 901(j) applied to Cuba. Revenue
Ruling 2016-8 provides that as of
December 22, 2015, section 901(j) no
longer applies to Cuba.
Lines 24, 27, 30, and 33. Exclusion of
U.S. income. Subpart F income does not
include any U.S. source income (which,
for these purposes, includes all carrying
charges and all interest, dividends,
royalties, and other investment income
received or accrued by a FSC) that is
effectively connected with a CFC's
conduct of a trade or business in the
United States unless that item is exempt
from taxation (or is subject to a reduced
rate of tax) pursuant to a treaty obligation
of the United States or the Code.
Line 37. Current E&P limitation. A
CFC's subpart F income is limited to the
sum of the following.
• Its current year E&P, computed under
the special rule of section 952(c)(1). Enter
this amount on line 37a.
• Any tested loss under section 951A(c)
(2)(B)(ii). If the total of all lines 6 of all
separate Schedules I-1 (Form 5471) for
the CFC is a negative number, enter the
amount as a positive number on line 37b.
If the total of all lines 6 is a positive
number or zero, enter -0- on line 37b.
The amount included in the gross
income of a U.S. shareholder of a CFC
under section 951(a)(1)(A)(i) for any tax
year and attributable to a qualified activity
must be reduced by the shareholder's pro
rata share of any qualified deficit (see
section 952(c)(1)(B)).
Lines 39 through 43. If Worksheet A,
line 37c is less than the amount on
Worksheet A, line 36, allocate the subpart
F income remaining (after having been
limited) (that is, the line 38 amount) to the
four categories of subpart F income listed
on Worksheet A, lines 40 through 43 using
the rules of Regulations section
1.952-1(e).
Instructions for Form 5471 (Rev. February 2020)
Worksheet B
U.S. Shareholder’s Pro Rata Share of Earnings of a CFC Invested in U.S. Property
Enter the amounts on lines 1 through 16 in functional currency.
1
a
b
c
d
2
3
4
5
6
7
a
b
8
9
10
11
12
13
14
15
16
17
Amount of U.S. property (as defined in sections 956(c) and (d)) held (directly or indirectly) by
the CFC as of the close of:
1a
The first quarter of the tax year
1b
The second quarter of the tax year
1c
The third quarter of the tax year
1d
The fourth quarter of the tax year
Number of quarter-ends the foreign corporation was a CFC during the tax year
Average amount of U.S. property held (directly or indirectly) by the CFC as of the close of each
quarter of the tax year. (Add lines 1a through 1d. Divide this amount by the number on line 2.)
U.S. shareholder’s pro rata share of the amount on line 3
Earnings and profits described in section 959(c)(1)(A) with respect to the U.S. shareholder after
reductions (if any) for current year distributions that affect the U.S. shareholder’s section 959(c)(1)
E&P account
Section 956(a)(1) amount. Subtract line 5 from line 4
Applicable earnings:
7a
Current year earnings and profits
7b
Line 7a plus accumulated earnings and profits
Enter the greater of line 7a or line 7b
Distributions made by the CFC during the tax year
Subtract line 9 from line 8
Earnings and profits described in section 959(c)(1)
Applicable earnings. Subtract line 11 from line 10
Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12
Section 956(a) amount. Enter the smaller of line 6 or line 13.
Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder
Section 956 Inclusion. Subtract line 15 from line 14
Translate the amount on line 16 from functional currency to U.S. dollars at the year-end spot
rate (as provided in section 989(b)). Enter the result here and on line 2 of Schedule I
Worksheet B Instructions
Use Worksheet B to determine a U.S.
shareholder's pro rata share of earnings of
a CFC invested in U.S. property that is
subject to tax. Only earnings of a CFC not
distributed or otherwise previously taxed
are subject to these rules. Thus, the
amount of previously untaxed earnings
limits the section 956 inclusion. A CFC's
investment in U.S. property in excess of
this limit will not be included in the taxable
income of the CFC's U.S. shareholders.
The balances in the previously taxed
accounts of prior section 956 inclusions
(see section 959(c)(1)(A)) and current or
prior subpart F inclusions (see section
959(c)(2)) reduce what would otherwise
be the current section 956 inclusion.
Note. The previously taxed accounts
should be adjusted to reflect any
reclassification of subpart F inclusions that
reduced prior section 956 or 956A
inclusions (see section 959(a)(2) and
Schedule J).
Distributions also are taken into
account before the section 956 inclusion is
determined. Distributions generally are
treated as coming first from (and thus
reducing the balances of) the previously
taxed accounts. Thus, the U.S.
shareholders must:
1. Compute the current subpart F
inclusion (potentially increasing that
previously taxed account),
2. Take into account current
distributions (potentially reducing the
previously taxed and untaxed accounts),
and
3. Compute the current section 956
inclusion (potentially increasing or
reclassifying the previously taxed
accounts).
U.S. property is measured on a
quarterly average basis. For purposes of
Worksheet B, the amount taken into
account with respect to U.S. property
generally is its adjusted basis for E&P
purposes, reduced by any liability to which
the property is subject. See sections
956(c) and (d) and the regulations under
section 956 to determine whether the CFC
is treated as holding U.S. property. The
amount of U.S. property held (directly or
indirectly) by the CFC does not include
any item that was acquired by the foreign
corporation before it became a CFC,
except for the property acquired before
the foreign corporation became a CFC
that exceeds the applicable earnings (as
Instructions for Form 5471 (Rev. February 2020)
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2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
defined in section 956(b)) accumulated
during periods before it became a CFC.
If the foreign corporation ceases to be
a CFC during the tax year:
• The determination of the U.S.
shareholder's pro rata share will be made
based upon the stock owned (within the
meaning of section 958(a)) by the U.S.
shareholder on the last day during the tax
year in which the foreign corporation was
a CFC;
• The CFC's U.S. property for the tax
year will be determined only by taking into
account quarters ending on or before such
last day (and investments in U.S. property
as of the close of subsequent quarters
should be recorded as zero on line 1); and
• In determining applicable earnings,
current E&P will include only E&P that are
allocable (on a pro rata basis) to the part
of the year during which the foreign
corporation was a CFC.
Instructions for Separate
Schedules
Schedule E
Use Schedule E to report taxes paid or
accrued by a foreign corporation for which
a foreign tax credit is allowed and taxes for
which a credit may not be taken.
Several of the foreign tax credit
provisions of the Act are applicable in tax
years of foreign corporations beginning
after December 31, 2017, and to tax years
of U.S. shareholders in which or with
which such tax years of the foreign
corporations end (“post-2017 foreign
corporate tax year”). As such, if the foreign
corporation's year begins before 2018
(“pre-2018 foreign corporate tax year”),
some pre-enactment rules continue to
apply in the domestic corporation's tax
year beginning in 2019 if such domestic
corporation owns the foreign corporation
through certain pass-through entities. For
example, if a domestic corporation with a
tax year ending September 30, 2020 owns
a domestic partnership with a tax year
ending October 31, 2019 and the
domestic partnership owns a foreign
corporation with a U.S. tax year beginning
on December 1, 2017, and ending on
November 30, 2018, for its 2019 tax year
such domestic corporation is subject to
certain pre-enactment provisions with
respect to such foreign corporation.
However, if such domestic corporation
also owns a foreign corporation with a
U.S. tax year beginning on January 1,
2019, and ending on December 31, 2019,
for its 2019 tax year such domestic
corporation is subject to certain
post-enactment provisions with respect to
such foreign corporation. Therefore, the
Form 5471 continues to require reporting
under pre-enactment provisions, as well
as requiring new reporting for
post-enactment provisions.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471.”
Reference ID number. If applicable, use
the reference ID number shown on Form
5471, page 1, Item 1b(2).
Lines a and b. Complete a separate
Schedule E for each applicable separate
category of income. Enter the appropriate
code on line a (above Part I). To
determine the appropriate code, see
Categories of Income in the Instructions
for Form 1118, Foreign Tax
Credit—Corporations. A foreign
corporation may need to report taxes with
respect to all categories of income listed in
the Instructions for Form 1118, with the
exception of foreign branch category
income. A foreign corporation may accrue
or pay taxes properly attributable to an
income group within the general category,
passive category, or section 901(j)
category. See Regulations section
1.960-1(d)(2)(ii). A foreign corporation
may accrue or pay taxes properly
attributable to a PTEP group within any of
the separate categories of income, with
the exception of foreign branch category
income. See Regulations section
1.960-3(c)(1).
If code 901j is entered on line a, enter
on line b the country code for the
sanctioned country using the two-letter
codes (from the list at IRS.gov/
countrycodes).
Part I—Taxes for Which a
Foreign Tax Credit Is Allowed
List income, war profits, and excess profits
taxes (income taxes) paid or accrued to
each foreign country or U.S. possession
for the foreign corporation’s foreign tax
year(s) that end with or within its U.S. tax
year. With respect to dividends paid in tax
years of foreign corporations beginning
before January 1, 2018, the taxes reported
on this schedule include taxes deemed
paid with respect to a dividend from a
lower-tier foreign corporation. See section
902 before its repeal by the Act.
Amounts not reported in Part I. Do not
report taxes that are not creditable,
including taxes for which a credit is
disallowed under section 901(j), (k), (l), or
(m). Such taxes are reported in Part III.
Also, do not report taxes suspended and
unsuspended under the anti-splitter rules
and taxes associated with hovering
deficits on Schedule E. Such taxes are
reported on Schedule E-1 (Form 5471).
Adjustments to foreign income taxes.
Adjustments to foreign income taxes paid
or accrued in a prior year should not be
reflected on Schedule E in the year of
adjustment. Instead, they should be
reported in the year to which such taxes
relate. This may require an amended
return. See section 905(c), as amended
by the Act. Adjustments include additional
payments, refunds, and downward
adjustments for accrued foreign taxes that
are not paid within 2 years after the close
of the tax year to which such taxes relate.
Comparison to income tax expense reported on Schedule C (Form 5471).
The foreign income taxes reported on
Schedule E may differ from the amount
reported as income tax expense on
line 21a of Schedule C. This is due in part
to differences in the accounting for foreign
tax redeterminations, disallowed taxes,
and foreign income taxes reported in
Other Comprehensive Income for U.S.
GAAP purposes.
Comparison to income tax expense reported on Schedule H (Form 5471).
The foreign income taxes reported on
Schedule E may differ from the taxes
deducted on line 2g of Schedule H. For
-22-
example, disallowed taxes reported in Part
III of Schedule E are taken into account in
E&P but are not creditable foreign income
taxes.
Column (a)
Amounts reported on Schedule E may
include taxes paid or accrued by the
foreign corporation or a pass-through
entity (for example, partnership or
disregarded entity) owned by the foreign
corporation. If the tax is paid or accrued by
the pass-through entity, enter the name of
such entity instead of the name of the
foreign corporation. If the tax paid or
accrued by the foreign corporation is
attributable to a branch or qualified
business unit (QBU) of the foreign
corporation, enter the name of the branch
or QBU.
With respect to deemed paid taxes
related to dividends received from
lower-tier foreign corporations in tax years
of foreign corporations beginning before
January 1, 2018, column (a) should
include the name of the lower-tier foreign
corporation that paid the dividend instead
of the recipient foreign corporation.
With respect to deemed paid taxes
related to PTEP distributions received
from lower-tier foreign corporations in tax
years of foreign corporations beginning
before January 1, 2018, column (a) should
include the name of the lower-tier foreign
corporation that made the PTEP
distribution instead of the recipient foreign
corporation.
Column (b)
Enter the employer identification number
(EIN) or reference ID number of the payor
entity listed in column (a). A reference ID
number is required only in cases in which
no EIN was entered for the foreign
corporation or pass-through entity owned
by the foreign corporation. Filers are
permitted to enter both an EIN and a
reference ID number.
Column (c)
Enter the two-letter codes (from the list at
IRS.gov/countrycodes) of all foreign
countries and U.S. possessions to which
taxes were paid or accrued. If taxes were
paid or accrued to more than one country
with respect to the same income, include
each tax paid or accrued to a different
country on separate lines.
Column (d)
The foreign tax year under foreign tax law
may not be the same tax year as the U.S.
tax year of the foreign corporation. If the
tax is attributable to a pass-through entity
owned by a foreign corporation, the
foreign tax year of the foreign corporation
within which such pass-through entity’s
year ends should be reported on this line.
Instructions for Form 5471 (Rev. February 2020)
Column (f)
Enter the income reported to the foreign
tax authority under foreign tax law. This
should be the foreign taxable income base
for determining the tax reported in column
(g).
Column (g)
Enter the tax paid or accrued in the local
currency in which tax is payable and not
the functional currency of the payor or
foreign corporation. See sections 986(a)
and 905(c).
Columns (h) and (i)
Enter the exchange rate in column (h) and
the translated dollar amount in column (i).
Translate the taxes entered in column
(g) into dollars at the average exchange
rate for the tax year to which the tax
relates unless one of the exceptions below
applies. See section 986(a).
Exceptions. If one of the following
exceptions applies, use the exchange rate
in effect on the date the foreign
corporation paid the tax.
1. The tax is paid before the
beginning of the year to which the tax
relates.
2. Accrued taxes are not paid before
the date two years after the close of the
tax year to which such taxes relate.
3. There is an election in effect under
section 986(a)(1)(D) to translate foreign
taxes using the exchange rate in effect on
the date of payment.
4. The foreign corporation reports on
the cash basis. See section 986(a).
5. The foreign tax is denominated in
an inflationary currency. See section
986(a)(1)(C).
Report the exchange rate using the
“divide-by convention” specified under
Reporting exchange rates on Form 5471,
earlier.
Column (j)
Enter the tax in functional currency. E&P
takes into account foreign income taxes
paid or accrued by the foreign corporation.
The foreign corporation's E&P is
determined in the foreign corporation's
functional currency. See section 986(b).
Line 8
Report the total of the amounts listed in
column (i) on this line 8. This total also
should be reported on Schedule E-1,
line 4.
Line 9
Report the total of the amounts listed in
column (j) on this line 9. This total and the
amount reported on line 3 of Schedule E,
Part III, are the appropriate reduction to
current year E&P. See Schedule H,
line 2g.
Example. CFC1, a foreign
corporation, with reference ID number
1000123, pays or accrues tax of 10u =
$10 to Country X on 50u of Country X
taxable income with respect to CFC1’s
foreign tax year ending December 31,
2019. CFC1 has a December 31 tax year
end for both foreign and U.S. tax
purposes. Also, CFC1 receives in the tax
year ending December 31, 2019, a refund
of 3u from Country X on 15u of income
with respect to CFC1’s tax year ending
December 31, 2016, translated to equal
$5, and on which the original liability was
$7. Therefore, the revised tax liability is
$2. All taxes relate to general category
income. Also assume for both years that
the local currency in which the tax was
paid was the same as the foreign
corporation’s functional currency. The
country code for Country X is XX.
The following entries should be made
on the 2019 Form 5471, Schedule E, Part
I, for CFC1.
• Line 1, column (a): CFC1
• Line 1, column (b): 1000123
• Line 1, column (c): XX
• Line 1, column (d): 2019/12/31
• Line 1, column (e): 2019/12/31
• Line 1, column (f): 50u
• Line 1, column (g): 10u
• Line 1, column (h): 1.0000
• Line 1, column (i): $10
• Line 1, column (j): 10u
An amended 2016 tax return should be
filed by or for the U.S. person(s) with
respect to which Form 5471 was required
and that return should include an
amended Form 5471. The amended Form
5471 should include an attachment with a
schedule that looks like the current version
of Schedule E, Part I, with the following
entries.
• Line 1, column (a): CFC1
• Line 1, column (b): 1000123
• Line 1, column (c): XX
• Line 1, column (d): 2016/12/31
• Line 1, column (e): 2016/12/31
• Line 1, column (f): 15u
• Line 1, column (g): 1.20u
• Line 1, column (h): 1.6667
• Line 1, column (i): $2
• Line 1, column (j): 1.20u
Part III—Taxes for Which
Foreign Tax Credit Is
Disallowed
Use Part III to report taxes for which
foreign tax credits are not allowed. While
not allowed as a credit, such taxes are
taken into account in determining the
foreign corporation’s E&P.
Do not enter taxes that do not meet the
criteria under Regulations section 1.901-2.
Do not enter foreign income taxes that
have been suspended under the
anti-splitter rules under section 909 or the
Instructions for Form 5471 (Rev. February 2020)
-23-
hovering deficit rules under Regulations
section 1.367(b)-7. Such taxes are
reported on Schedule E-1.
Columns (a) and (b)
See Part I Taxes for Which a Foreign Tax
Credit Is Allowed for instructions regarding
these columns.
Column (c)
Enter foreign income taxes that are
disallowed under section 901(j), generally
foreign income taxes paid or accrued to
certain sanctioned countries.
Column (d)
Enter foreign income taxes that are
disallowed under section 901(k), which
generally applies to certain taxes paid on
dividends if the minimum holding period is
not met with respect to the underlying
stock, or if the corporation is obligated to
make related payments with respect to
positions in similar or related property.
Also enter foreign income taxes
disallowed under section 901(l), which
generally applies to certain taxes paid on
gain and income other than dividends if
the minimum holding period is not met
with respect to the underlying property, or
if the corporation is obligated to make
related payments with respect to positions
in similar or related property.
Column (e)
In the case of a covered asset acquisition
(as defined in section 901(m)(2)), enter
the disqualified portion of any tax
determined with respect to the income or
gain attributable to the relevant foreign
assets (section 901(m)).
Note. This rule generally applies to
covered asset acquisitions after
December 31, 2010. See Temporary and
Proposed Regulations sections 1.901(m)1 through 1.901(m)-8 for additional
information. Note that the rules contained
in these regulations have later effective
dates.
Column (f)
Enter the amount of taxes paid or accrued
by the foreign corporation to the United
States. No credit is allowed for these taxes
because only foreign income taxes paid or
accrued to a foreign country or possession
of the United States are allowed as a
credit. See section 901(b).
Column (g)
Enter taxes for which a foreign tax credit is
disallowed other than those detailed in
columns (c) through (f). Such taxes may
include, but are not limited to, certain
taxes on the purchase or sale of oil and
gas (section 901(f)), certain taxes used to
provide subsidies (section 901(i)), and
taxes for which no credit is allowed
because of the boycott provisions of
section 908. Taxes reported in column (g)
also include any taxes related to the
residual income group. See Regulations
section 1.960-1(d)(2)(ii)(D).
Example. CFC1, a foreign
corporation, wholly owns the only class of
stock of CFC2, a foreign corporation.
CFC2 does not have PTEP. CFC2
distributes section 959(c)(3) E&P to CFC1
which is treated as a dividend for U.S. tax
purposes. For foreign tax purposes, the
distribution is also characterized as a
dividend. As CFC1 and CFC2 are located
in different countries, a withholding tax is
levied by CFC2’s country of residence on
the distribution. Under the principles of
Regulations section 1.904-6, the
distribution is assigned to the statutory or
residual grouping to which the
corresponding U.S. item is assigned. In
this case the corresponding U.S. item is
section 959(c)(3) E&P, which is in the
residual income group. See Regulations
section 1.960- 1(d)(2)(ii)(D). Therefore,
the withholding taxes are properly
attributable to the residual income group.
Under Regulations section 1.960-1(e),
such taxes are not deemed paid for any
taxable year and therefore are reported in
column (g).
Column (h)
For each line in this column, enter the total
amount for each payor in columns (c)
through (g).
Line 3
Total each amount in column (h) and enter
on line 3. All amounts should be in
functional currency.
Line 4
Translate the line 3 amount from functional
currency to U.S. dollars using, in general,
the average exchange rate as defined by
section 989(b)(3).
Schedule E-1
Use Schedule E-1 to report the cumulative
balance of foreign income taxes paid or
accrued by a CFC by separate category of
income. Also use this schedule to report
the foreign income taxes paid or accrued
by specified foreign corporations that are
only treated as CFCs for limited purposes
under section 965(e)(2).
Enter amounts in U.S. dollars unless
otherwise noted.
Columns (a), (b), and (c)
Report the opening balance, current year
additions and subtractions, and the
closing balance of the foreign
corporation's foreign income taxes paid or
accrued with respect to E&P described in
section 959(c)(3). In general, this is E&P
of the foreign corporation that has not
been included in gross income of a U.S.
person under sections 951(a)(1) and
951A.
In column (a), report foreign income
taxes paid or accrued with respect to
current E&P and earned after the repeal of
section 902, that is, post-2017 E&P not
previously taxed (post-2017 section
959(c)(3) balance). Only include
information with respect to the current tax
year of the foreign corporation. Do not
include foreign income taxes paid or
accrued by the foreign corporation in its
other tax years beginning after December
31, 2017 or that do not relate to the current
tax year. Therefore, in column (a), no
amount should be reported on lines 1a
through 1c, line 2, and line 14. The repeal
of section 902 is effective for tax years of
foreign corporations beginning after
December 31, 2017, and to tax years of
U.S. shareholders in which or with which
such tax years of foreign corporations end
(post-2017 foreign corporate tax years).
In column (b), report post-1986 foreign
income taxes, as defined in section 902(c)
(2), and as in effect prior to the repeal of
section 902.
In column (c), report the aggregate
amount of the foreign corporation's foreign
income taxes paid or accrued with respect
to pre-1987 section 964(a) E&P
accumulated since 1962 and not
previously distributed or deemed
distributed.
Column (d)
Use column (d) to report taxes related to
hovering deficits and taxes suspended
under section 909.
Columns (e)(i) through (e)(xvi)
Report foreign income taxes paid or
accrued with respect to E&P described in
sections 959(c)(1) and (c)(2) (previously
taxed E&P).
Specific Instructions Related to
Lines 1 through 12
Line 1a. This amount should equal the
amount that was reported as the balance
at the beginning of the next year on line 14
of the prior year Schedule E-1. No amount
should be reported in column (a).
Line 1b. If the balance on line 14 of the
prior year Schedule E-1 was adjusted after
the filing of the original prior year Form
5471, such adjustments should be
reflected on line 1b. For example, if there
were errors in the original computation of
foreign income taxes, an adjustment
would be included in this line. See
Corrections to Form 5471, earlier. Do not
include any adjustments required to be
reported on line 6 or 12. No amount
should be reported in column (a).
-24-
Line 2. Use line 2 to reflect adjustments
to a U.S. person’s foreign tax credit as a
result of redetermined foreign income
taxes. If a U.S. person has appropriately
amended the immediately prior year
return, including its Schedule E-1, to
redetermine its U.S. tax liability, no
adjustment should be included on this line.
This line is only applicable if a U.S. person
appropriately amended a prior year return
and there were intervening years between
the amended year return and the current
year return for which an amended return
was not filed. If so, an adjustment for the
prior year amended return (and its impact
on intervening years) should be reflected
on line 2. No amount should be reported in
column (a).
Line 3a. Include in column (a), (b), (c), or
(e) foreign income taxes paid or accrued
by the corporation during prior tax years
that were suspended due to the
application of the rules of section 909 and
that are unsuspended in the current year
because related income is taken into
account by the foreign corporation, certain
U.S. corporate owners of the foreign
corporation, or a member of such U.S.
corporate owner’s consolidated group.
This amount is reported as a positive
amount on line 3a, column (a), (b), (c), or
(e), and as a negative amount in column
(d). See Regulations section 1.909-1(d)
with respect to the application of section
909 to pre-1987 E&P not previously taxed
and income taxes.
Line 3b. Include as a positive amount in
column (d) foreign income taxes related to
the current tax year that have been
suspended due to the rules of section 909.
Line 4. The total reported on Schedule E,
column (i), line 8, should be separated into
columns (a) through (e) according to the
type of E&P to which such taxes relate.
Example 1. Domestic Corporation, a
U.S. shareholder, wholly owns the only
class of stock of CFC1, a foreign
corporation. CFC1, in turn, wholly owns
the only class of stock of CFC2, a foreign
corporation. CFC2, in turn, wholly owns
the only class of stock of CFC3, a foreign
corporation. The functional currency of
Domestic Corporation, CFC1, CFC2, and
CFC3 is the U.S. dollar. During Year 1,
Domestic Corporation reports an inclusion
under section 951(a)(1) of $100 as a result
of subpart F income of CFC3. During Year
2, CFC3 distributes $40 to CFC2. CFC2
pays withholding tax of $4 on the
distribution from CFC3. Such tax is a tax
related to previously taxed subpart F
income and is reported on line 4, column
(e)(xvi), of Schedule E-1 of CFC2’s Form
5471.
Example 2. The facts are the same as
in Example 1, except that, in addition,
CFC2 distributes $36 to CFC1 in Year 3.
Instructions for Form 5471 (Rev. February 2020)
CFC1 is deemed to pay the $4 of
withholding tax paid by CFC2 in Year 2.
See section 960(b). Such tax is related to
previously taxed subpart F income and is
reported on line 4, column (e)(xvi), of
Schedule E-1 of CFC1’s Form 5471. Such
tax is also reported as a negative number
on line 10, column (e)(xvi), of Schedule E1 of CFC2’s Form 5471.
Line 5a. Report taxes carried over to a
foreign surviving corporation after an
acquisition by a foreign corporation of the
assets of another foreign corporation in a
transaction described in section 381. See
Regulations section 1.367(b)-7(b)(1) and
(d)(1). See Regulations section
1.367(b)-7(e)(1) with respect to foreign
income taxes related to pre-1987 E&P not
previously taxed.
Line 5b. Post-1986 foreign income taxes
that are related to a hovering deficit in a
separate category of post-1986
undistributed earnings should only be
added to the foreign surviving
corporation’s post-1986 foreign income
taxes in that separate category on a pro
rata basis as the hovering deficit is
absorbed. See Regulations section
1.367(b)-7(d)(2)(iii). An amount equal to
the taxes related to a hovering deficit that
are reported in column [(a)], (b), or (c) of
line 5a is included as a negative amount
on line 5b of column [(a)], (b), or (c),
respectively. An amount equal to the total
taxes related to hovering deficits reported
on line 5b of columns [(a)], (b), and (c) is
included as a positive number in column
(d) of line 5b.
Line 6. Attach a statement with a
description and the amount of any
adjustments required before taking into
account taxes deemed paid by the foreign
corporation. Do not include any
adjustments required to be reported on
line 1b or 12. An example of an
adjustment entered on line 6 is the foreign
taxes imposed on receipt of a distribution
of PTEP from a lower-tier foreign
corporation.
Line 7, column (b). Report post-1986
foreign income taxes used for purposes of
determining the taxes deemed paid on
dividends from a foreign corporation in
such corporation’s tax years beginning
before January 1, 2018 (pre-2018 foreign
corporate tax years). See section 902(c)
(2).
Line 8. A domestic corporation is
deemed to pay foreign income taxes
attributable to inclusions under section
951(a)(1). See section 960(a)(1) (for
pre-2018 foreign corporate tax years) and
section 960(a) (for post-2017 foreign
corporate tax years). If a domestic
corporation computes deemed paid taxes
under both sections 902 and 960 in the
same tax year, section 960 is applied first.
See section 960(a)(2) and Regulations
section 1.960-1(i)(2) (for pre-2018 foreign
corporate tax years). Amounts reported on
line 8 should be negative numbers.
Line 9. If a domestic corporation includes
an amount in income under section 951A,
such domestic corporation is deemed to
pay foreign income taxes equal to 80% of
the product of:(a) such domestic
corporation’s inclusion percentage,
multiplied by (b) the aggregate tested
foreign income taxes paid or accrued by
the CFC. For the computation of such
amount, see Form 1118, Schedule D.
Amounts reported on line 9 should be
negative numbers.
Line 10. A domestic corporation is
deemed to pay foreign income taxes with
respect to distributions of post-1986
undistributed earnings from certain foreign
corporations in pre-2018 foreign corporate
tax years. Include on line 10 all taxes
attributable to distributions of E&P
regardless of whether the shareholder
receiving the distribution is eligible for a
deemed paid credit or whether the
shareholder is required to file Form 5471.
In addition, a domestic corporation is
deemed to pay foreign income taxes with
respect to distributions of previously taxed
E&P. See section 960(a)(3) for pre-2018
foreign corporate tax years and section
960(b) for post-2017 foreign corporate tax
years. Amounts reported on line 10 should
be negative numbers.
Example 3. The facts are the same as
in Example 2, except that during Year 4,
CFC1 distributes $36 to Domestic
Corporation. Domestic Corporation is
deemed to pay the $4 of withholding taxes
deemed paid by CFC1 in Year 3 and paid
by CFC2 in Year 2. A negative $4 will be
recorded on line 10, column (e)(xvi).
Line 11. Foreign income taxes
reclassified from section 959(c)(2)
previously taxed E&P to section 959(c)(1)
previously taxed E&P should be reported
as negative numbers in columns (e)(x)
through (e)(xvi) and as positive numbers
in columns (e)(i) through (e)(viii).
Example 4. The facts are the same as
in Example 1, except that during Year 2
CFC2 invests $40 in U.S. property. At the
time of investment in such property, CFC2
continues to maintain a $36 balance in its
section 959(c)(2) previously taxed E&P
account. CFC2 reclassifies such amount
as section 959(c)(1) previously taxed E&P
on Schedule J. Accordingly, $4 of foreign
income taxes related to section 959(c)(2)
previously taxed E&P is reclassified to
section 959(c)(1) previously taxed E&P on
line 11, column (e)(iii). A negative $4 will
be recorded on line 11, column (e)(xvi),
and a positive $4 will be recorded on
line 11, column (e)(iii).
Instructions for Form 5471 (Rev. February 2020)
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Line 12. Attach a statement with a
description and the amount of any
required adjustments to taxes of the
foreign corporation not already taken into
account on this schedule.
Schedule H
Use Schedule H to report the foreign
corporation's current E&P for U.S. tax
purposes. Enter the amounts on lines 1
through 5c in the CFC's functional
currency.
Certain filers may be able to use
alternative information (as defined in
section 3.01 of Rev. Proc. 2019-40) to
determine certain amounts in this
schedule. See Rev .Proc. 2019-40 for
more details
Note. Category 5 filers who are unrelated
section 958(a) U.S. shareholders are not
required to file Schedule H for
foreign-controlled corporations. Category
5 filers who are related constructive U.S.
shareholders are not required to file
Schedule H for foreign-controlled
corporations. See Certain Category 1 and
Category 5 Filers under Categories of
Filers.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471.”
Lines a and b. Complete a separate
Schedule H for each applicable separate
category of income. Schedule H may
include E&P with respect to the general
category, passive category, or section
901(j) category. See Regulations section
1.960-1(d)(2)(ii). The code for general
category income is GEN, the code for
passive category income is PAS, and the
code for the section 901(j) category is
901j.
If code 901j is entered on line a, enter
on line b the country code for the
sanctioned country using the two-letter
codes (from the list at IRS.gov/
countrycodes).
Note. For purposes of this Schedule H,
include in each separate category of
income foreign and U.S. income.
Reference ID number. If applicable, use
the reference ID number shown on Form
5471, page 1, Item 1b(2).
Special rules for DASTM. If the foreign
corporation uses DASTM, enter on line 1
the dollar GAAP income or (loss) from
line 22 of Schedule C. Enter on lines 2a
through 4 the adjustments made in
figuring current E&P for U.S. tax purposes.
Report these amounts in U.S. dollars.
Enter on line 5b the DASTM gain or loss
figured under Regulations section
1.985-3(d).
Lines 2a through 2i. Certain
adjustments (required by Regulations
sections 1.964-1(b) and (c)) must be
made to the foreign corporation's line 1 net
book income or (loss) to determine its
current E&P. These adjustments may
include both positive and negative
adjustments to conform the foreign book
income to U.S. GAAP and to U.S. tax
accounting principles. If the foreign
corporation's books are maintained in
functional currency in accordance with
U.S. GAAP, enter on line 1 the functional
currency GAAP income or (loss) from
line 21 of Schedule C, rather than starting
with foreign book income, and show
GAAP-to-tax adjustments on lines 2a
through 2i.
Lines 2b and 2c. Generally,
depreciation, depletion, and amortization
allowances must be based on the
historical cost of the underlying asset, and
depreciation must be figured according to
section 167. However, if 20% or more of
the foreign corporation's gross income is
from U.S. sources, depreciation must be
figured on a straight line basis according
to Regulations section 1.312-15.
Line 2f. Inventories must be taken into
account according to the rules of
sections 471 (incorporating the provisions
of section 263A) and 472 and the related
regulations.
Line 2g. See the instructions for
Schedule C, Line 20, earlier. Reflect
differences between the income tax
expense (benefit) reported for book
purposes and the income taxes deducted
or added to E&P. Such differences
include, for example, deferred income tax
expenses, uncertain tax positions,
intraperiod allocations, adjustments made
after closing the financial statements
(post-closing adjustments) and not
reflected in income tax expense (benefit),
and the adjustment for a foreign tax
redetermination that required a
redetermination of the U.S. tax liability.
Line 2h. Enter the adjustment to foreign
gains or losses. Attach a statement with a
description of the gain or losses.
In the case of section 988 losses,
determine whether Form 8886 needs to be
completed as described in Additional
Filing Requirements, earlier.
Line 2i. Enter the net amount of any
additional adjustments not included on
lines 2a through 2h. List these additional
adjustments on a separate statement.
Attach this statement to Form 5471.
Line 5b. DASTM gain or (loss), reflecting
unrealized exchange gain or loss, should
be entered on line 5b only for foreign
corporations that use DASTM.
Line 5d. Enter the line 5c functional
currency amount translated into U.S.
dollars at the average exchange rate for
the foreign corporation's tax year. See
section 989(b). Report the exchange rate
using the “divide-by convention” specified
under Reporting Exchange Rates on Form
5471, earlier. If the foreign corporation
uses DASTM, enter on line 5d the same
amount entered on line 5c.
Blocked income. The E&P of the foreign
corporation, as reflected on Schedule H,
must not be reduced by all or any part of
such E&P that could not have been
distributed by the foreign corporation due
to currency or other restrictions or
limitations imposed under the laws of any
foreign country.
Schedule I-1
This schedule is used to report information
determined at the CFC level with respect
to amounts used in the determination of
income inclusions by U.S. shareholders
under section 951A. The information in
this schedule will be used by the U.S.
shareholder(s) of the CFC to file Form
8992, U.S. Shareholder Calculation of
Global Intangible Low-Taxed Income
(GILTI), and may assist in the completion
of Form 1118, Foreign Tax
Credits—Corporations, or Form 1116,
Foreign Tax Credit (Individual, Estate, or
Trust), if applicable.
Enter the amounts on lines 1 through
10c in the CFC's functional currency. The
functional currency amounts entered on
lines 6 through 10c must be converted to
U.S. dollars.
Certain filers may be able to use
alternative information (as defined in
section 3.01 of Rev. Proc. 2019-40) to
determine certain amounts in this
schedule. See Rev. Proc. 2019-40 for
more details.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471.”
Separate category. Schedule I-1 is now
completed once. (It is no longer
completed separately for each applicable
category of income.) Therefore,
Schedule I-1 is completed once (for
general category income, passive
category income, or both). A Schedule I-1
that includes passive category income
must include the code for passive
category income (PAS) in the entry space
for separate category (at the top of
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Schedule I-1). A taxpayer with only
general category income (and no passive
category income), should enter the code
“GEN” in the entry space for separate
category.
Note. The other reporting requirements of
a taxpayer that includes passive category
income with general category income in a
Schedule I-1 do not change because the
taxpayer includes passive category
income with general category income in a
Schedule I-1. For example, the taxpayer
may still be required to complete a Form
1116 or a Form 1118, and/or a Form 5471
(including Schedule J and Schedule P),
and separately report passive category
income and section 951A category
income.
Line 1. Enter the CFC’s gross income.
Line 2a. Enter the amount of the CFC’s
income described in section 952(b), which
generally is income from sources within
the United States that is effectively
connected to the conduct of a trade or
business by the CFC in the United States
and not reduced or exempt from tax
pursuant to an income tax treaty with the
United States.
Line 2b. Enter the amount, if any, of the
CFC’s gross income taken into account in
determining the CFC’s subpart F income
(as defined in section 952). Note that an
amount determined under section 956(a)
is not considered subpart F income. The
amount to be entered is computed after
application of the high-tax exception in
section 954(b)(4), but before application of
the E&P limitation in section 952(c)(1)(A).
Line 2c. Enter the amount, if any, of the
CFC’s gross income excluded from
foreign base company income (as defined
in section 954) and insurance income (as
defined in section 953) by reason of
section 954(b)(4), the high-tax exception.
Line 2d. Enter the amount of any
dividend income received by the CFC
from a related person as defined in section
954(d)(3). Do not include the amounts of
any dividend income received from a
related person that are already included in
the amounts entered on line 2b or line 2c.
Line 2e. Enter the amount of the CFC’s
taxable income from sources outside the
United States and its possessions from
the following.
• The extraction (by the corporation or
any other person) of minerals from oil or
gas wells located outside the United
States and its possessions.
• The sale or exchange of assets used
(by the corporation) in the trade or
business of extracting minerals from oil or
gas wells located outside the United
States and its possessions.
Instructions for Form 5471 (Rev. February 2020)
Line 3. Enter the sum of lines 2a through
2e.
Line 4. Subtract line 3 from line 1 and
enter the result on line 4.
Line 5. Enter the deductions (including
taxes) properly allocable to the amount on
line 4 (or to which such deductions would
be allocable if there were such gross
income).
Line 6. Subtract line 5 from line 4 and
enter the result on line 6. This amount
must be converted from functional
currency to U.S. dollars using the average
exchange rate for the year of the CFC.
See Regulations section 1.951A-1(d)(1).
Report the exchange rate using the
“divide-by convention” specified under
Reporting exchange rates on Form 5471,
earlier.
Line 7. If the CFC has a tested loss on
line 6, enter zero. If the CFC has tested
income on line 6, enter only those foreign
income taxes that are properly attributable
to the CFC’s tested income. This amount
must be converted from functional
currency to U.S. dollars using the average
exchange rate for the year of the CFC.
See section 986. The U.S. shareholder(s)
will compute their pro rata share of the
tested foreign taxes and enter that amount
on Form 1118, Schedule D, Part I, column
5, if applicable.
Line 8. If the CFC has a tested loss on
line 6, enter zero. If the CFC has tested
income on line 6, enter the Qualified
Business Asset Investment (QBAI)
(defined below). This amount must be
converted from functional currency to U.S.
dollars using the average exchange rate
for the year of the CFC. See Regulations
section 1.951A-1(d)(1).
Qualified business asset
investment (QBAI). QBAI is the average
of the CFC's aggregate adjusted bases,
as of the close of each quarter of its
taxable year, in specified tangible property
used in its trade or business in the
production of tested income, and for which
a deduction is allowable under section
167. Adjusted basis in any property must
be determined by using the alternative
depreciation system under section 168(g)
and allocating depreciation deductions
with respect to such property ratably to
each day during the period in the taxable
year to which such depreciation relates.
Specified tangible property and
dual–use property. Specified tangible
property means any tangible property
used in the production of tested income. If
such property was used in the production
of tested income and income that is not
tested income (that is, dual-use property),
the property is treated as specified
tangible property in the same proportion
that the amount of tested income
determined before allocable deductions
(that is, line 4) produced with respect to
the property bears to the total amount of
gross income produced with respect to the
property.
Partnership property. A CFC with
tested income that is a partner of a
partnership that has depreciable tangible
property determines its share of the
partnership’s average adjusted basis in
the depreciable tangible property of the
partnership based on the amount of the
distributive share of the gross income
produced by the property that is included
in the CFC’s gross tested income (defined
below) relative to the total amount of gross
income produced by the property. The
partnership’s average adjusted basis in
the depreciable tangible property of the
partnership generally is determined based
on the average of the adjusted basis in the
property as of the close of each quarter of
the partnership’s taxable year that ends
with or within the CFC’s taxable year. See
Regulations section 1.951A-3(g).
Gross tested income. For these
purposes, a CFC’s gross tested income is
its gross income less total exclusions
(Schedule I-1, line 4).
Lines 9a through 9d. In general, see
Regulations section 1.951A-4(b)(1) to
determine how to compute the CFC’s
tested interest expense.
Schedule J
Use Schedule J to report a CFC’s
accumulated E&P in its functional
currency, computed under sections 964(a)
and 986(b). Also use this schedule to
report the E&P of specified foreign
corporations that are only treated as CFCs
for limited purposes under section 965(e)
(2).
Note. Category 1 and 5 filers who are
unrelated section 958(a) U.S.
shareholders are not required to file
Schedule J for foreign-controlled
corporations. Category 1 and 5 filers who
are related constructive U.S. shareholders
are not required to file Schedule J for
foreign-controlled corporations. See
Certain Category 1 and Category 5 Filers
under Categories of Filers.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471.”
Reference ID number. If applicable, use
the reference ID number shown on Form
5471, page 1, Item 1b(2).
Line 10a. Enter the amount of interest
income included on line 4. See the
instructions for Line 6 for foreign currency
translation.
Lines a and b. Complete a separate
Schedule J for each applicable separate
category of income. Enter the appropriate
code on line a (at the top of page 1 of
Schedule J). To determine the appropriate
code, see Categories of Income in the
Instructions for Form 1118. A foreign
corporation may need to report E&P with
respect to all categories of income listed in
the Instructions for Form 1118, with the
exception of foreign branch category
income. A foreign corporation may have
E&P in an income group within the general
category, passive category, or section
901(j) category. See Regulations section
1.960-1(d)(2)(ii). A foreign corporation
may have PTEP in a PTEP group within
any of the separate categories of income,
with the exception of foreign branch
category income. See Regulations section
1.960-3(c)(1).
If code 901j is entered on line a, enter
on line b the country code for the
sanctioned country using the two-letter
codes (from the list at IRS.gov/
countrycodes).
Line 10b. Enter the CFC’s qualified
interest income as defined in Regulations
section 1.951A-4(b)(2)(iii).
Note. For purposes of this Schedule J,
include in each separate category of
income foreign and U.S. income.
Line 9a. Enter the amount of interest
expense included on line 5. See the
instructions for Line 6 for foreign currency
translation.
Line 9b. Enter the CFC’s qualified
interest expense as defined in Regulations
section 1.951A-4(b)(1)(iii).
Line 9c. Enter the CFC’s tested loss
QBAI amount as defined in Regulations
section 1.951A-4(b)(1)(iv).
Line 9d. Subtract the sum of line 9b
and line 9c from line 9a and enter the
result on line 9d.
Lines 10a through 10c. In general, see
Regulations section 1.951A-4(b)(2) to
determine how to compute the CFC’s
tested interest income.
Line 10c. Subtract line 10b from
line 10a and enter the result on line 10c.
Instructions for Form 5471 (Rev. February 2020)
Part I—Accumulated E&P of
Controlled Foreign Corporation
Check the box at the top of Part I if the
person filing Form 5471 does not have all
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U.S. shareholders’ information necessary
to complete any one of the previously
taxed E&P amounts required to be
included in column (e). If the person filing
Form 5471 is unable to determine whether
amounts should be reported as previously
taxed E&P, those amounts should be
included in column (a), Post-2017 E&P
Not Previously Taxed, section 959(c)(3)
balance. For example, one U.S.
shareholder might not know the other U.S.
shareholder’s section 951A inclusion with
respect to a CFC because the first U.S.
shareholder does not have information
with respect to the second U.S.
shareholder’s tested loss for the CFC or
QBAI. See the instructions for Schedule P
for an example.
Enter the amounts in this schedule in
the functional currency of the foreign
corporation as reported on Form 5471,
page 1, item 1h. If the foreign corporation
is the owner of a qualified business unit(s)
(QBU) with a different functional currency,
translate the E&P of the QBU(s) to the
foreign corporation’s functional currency.
Columns (a), (b), and (c)
Report the opening balance, current year
additions and subtractions, and the
closing balance in the foreign
corporation's E&P described in section
959(c)(3). In general, this is E&P of the
foreign corporation that has not been
included in gross income of a U.S. person
under section 951(a)(1) and section 951A.
In column (a), report E&P described in
section 959(c)(3) and earned after the
repeal of section 902, that is, post-2017
E&P not previously taxed (post-2017
section 959(c)(3) balance). The repeal of
section 902 is effective for tax years of
foreign corporations beginning after
December 31, 2017, and to tax years of
U.S. shareholders in which or with which
such tax years of foreign corporations
end.
In column (b), report post-1986
undistributed earnings, as defined under
section 902(c)(1), and as in effect prior to
the repeal of section 902.
Use column (c) to report the aggregate
amount of the foreign corporation's
pre-1987 section 964(a) E&P accumulated
since 1962 and not previously distributed
or deemed distributed. These amounts are
figured in U.S. dollars using the rules of
Regulations sections 1.964-1(a) through
(e), translated into the foreign
corporation's functional currency
according to Notice 88-70, 1988-2 C.B.
369.
Column (d)
Use column (d) to report hovering deficits
(see section 381(c)(2)(B) and Regulations
section 1.367(b)-7) and suspended taxes
(see section 909). See Specific
instructions related to lines 1 through 14,
below, for additional information pertaining
to reporting amounts in column (d).
Column (e)
Use column (e) to report the running
balance of the foreign corporation's PTEP,
section 964(a) E&P accumulated since
1962 that have resulted in deemed
inclusions under subpart F, or amounts
treated as PTEP under section 965(b)(4)
(A). Pre-1987 U.S. dollar PTEP should be
translated into the foreign corporation's
functional currency using the rules of
Notice 88-70 and added to post-1986
amounts in the appropriate PTEP
category.
• Columns (e)(i) and (e)(ii) are PTEP
originally attributable to inclusions under
section 965(a) and section 965(b)(4)(A),
respectively, and reclassified as
investments in U.S. property (section
959(c)(1)(A) amounts).
• Column (e)(iii) is PTEP attributable to,
or reclassified as, investments in U.S.
property (section 959(c)(1)(A) amounts).
• Column (e)(iv) is PTEP originally
attributable to inclusions under section
951A and reclassified as investments in
U.S. property (section 959(c)(1)(A)
amounts).
• Column (e)(v) is PTEP attributable to
hybrid dividends under section 245A(e)(2)
and reclassified as investments in U.S.
property.
• Column (e)(vi) is PTEP attributable to
section 1248 amounts under section
959(e) and reclassified as investments in
U.S. property.
• Column (e)(vii) is PTEP attributable to
section 1248 amounts from the gain on
the sale of a CFC by a CFC and
reclassified as investments in U.S.
property.
• Column (e)(viii) is PTEP attributable to
subpart F income inclusions (not already
described) and reclassified as
investments in U.S. property.
• Column (e)(ix) is PTEP attributable to
inclusions under previous section 951(a)
(1)(C) and reclassified as investments in
U.S. property.
• Column (e)(x) is PTEP attributable to
section 965(a) inclusions (section 959(c)
(2) amounts). Do not include E&P reported
in column (e)(xi).
• Column (e)(xi) is E&P treated as PTEP
under section 965(b)(4)(A) (section 959(c)
(2) amounts).
• Column (e)(xii) is PTEP attributable to
section 951A inclusions (section 959(c)(2)
amounts).
• Column (e)(xiii) is PTEP attributable to
hybrid dividends under section 245A(e)
(2).
• Column (e)(xiv) is PTEP attributable to
section 1248 amounts under section
959(e).
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• Column (e)(xv) is PTEP attributable to
section 1248 amounts from the gain on
the sale of a CFC by a CFC.
• Column (xvi) is PTEP attributable to
section 951(a)(1)(A) inclusions (section
959(c)(2) amounts).
Column (f)
Use column (f) to report the opening and
closing balance of the foreign
corporation's accumulated E&P. This
amount is the sum of post-2017 E&P not
previously taxed, post-1986 undistributed
earnings, pre-1987 E&P not previously
taxed, and PTEP. Do not include column
(d) amounts in the total reported in column
(f).
Specific Instructions Related to
Lines 1 Through 13
Line 1a. Enter the balances for each
column at the beginning of the tax year.
These balances should equal the amounts
reported as the ending balances in the
prior year Schedule J.
Line 1b. If there is a difference between
last year’s ending balance on Schedule J
and the amount that should be last year’s
ending balance, taking into account
modifications in Schedule J, include the
difference on line 1b and attach an
explanation for the difference. If there are
multiple differences, include the
explanation and amount of each such
difference on the attachment. Do not
include adjustments required to be
reported on line 6 or 12.
Lines 1a through 1c. These lines of
column (d) account for the balance of prior
year hovering deficits and suspended
taxes that have not yet been deducted in
prior years. Such amounts are reported as
negative numbers.
Line 2a. This line of column (d) is the
unsuspended taxes under section 909 as
a result of related income taken into
account by the foreign corporation, certain
U.S. corporate owners of the foreign
corporation, or a member of such U.S.
corporate owner’s consolidated group.
Report the unsuspended taxes on line 2a
of column (d) as a positive number. Report
the unsuspended taxes as negative
numbers on line 2a of column (a), (b), (c),
or (e), as applicable.
Line 2b. This line of column (d) accounts
for foreign income taxes that are
suspended in the current tax year. Report
such amounts as negative numbers.
Line 4. Report as a positive number E&P
attributable to PTEP distributions from
lower-tier foreign corporations. Generally,
the E&P of a CFC attributable to amounts
that are, or have been, included in the
gross income of a U.S. shareholder under
section 951(a), are not, when distributed
through a chain of ownership described in
Instructions for Form 5471 (Rev. February 2020)
section 958(a), also included in the gross
income of another CFC in such chain for
purposes of the application of section
951(a) to such other CFC with respect to
such U.S. shareholder. See section
959(b).
Line 5a. Enter earnings carried over to a
foreign surviving corporation after an
acquisition by a foreign corporation of the
assets of another foreign corporation in a
transaction described in section 381. See
Regulations section 1.367(b)-7. The
amounts entered on line 5a may be
negative or positive.
Line 5b. If the foreign surviving
corporation had a deficit in E&P prior to a
transaction described in section 381, such
deficit is recharacterized as a hovering
deficit after such nonrecognition
transaction. See section 381(c)(2)(B) and
Regulations sections 1.367(b)-7(d)(2)(i)
(post-1986 undistributed earnings) and
1.367(b)-7(e)(1) (pre-1987 E&P not
previously taxed). An amount equal to the
deficit reported in column (a), (b), or (c) of
line 5a is included as a positive amount on
line 5b of column (a), (b), or (c),
respectively. An amount equal to the total
hovering deficits reported on line 5b of
columns (a), (b), and (c) is included as a
negative number in column (d) of line 5b.
Line 6. Attach a statement detailing the
nature and amount of any adjustments not
accounted for in the E&P determined
before reduction for distributions and
inclusions (that is, adjustments other than
those listed on lines 2a through 5b). Do
not include amounts reported on line 1b.
An example of an adjustment entered on
Line 6 is the foreign taxes imposed on
receipt of a distribution of PTEP from a
lower-tier foreign corporation.
Example. Domestic Corporation, a
U.S. shareholder, wholly owns the only
class of stock of CFC1, a foreign
corporation. CFC1, in turn, wholly owns
the only class of stock of CFC2, a foreign
corporation. CFC2, in turn, wholly owns
the only class of stock of CFC3, a foreign
corporation. The functional currency of
Domestic Corporation, CFC1, CFC2, and
CFC3 is the U.S. dollar. During Year 1,
Domestic Corporation reports an inclusion
under section 951(a)(1) of $100 as a result
of subpart F income of CFC3. During Year
2, CFC3 distributes $40 to CFC2. CFC2
pays withholding tax of $4 on the
distribution from CFC3. Such tax is related
to previously taxed subpart F income.
Domestic Corporation reports on CFC2’s
Form 5471, Schedule J, line 3, column (e)
(xvi), as a positive number, the $40 PTEP
distribution. Domestic Corporation reports
on line 6, column (e)(xvi), as a negative
number, the $4 of tax on the PTEP
distribution.
Line 7. Enter on line 7, E&P as of the
close of the tax year before actual
distributions or inclusions under section
951(a)(1) or section 951A during the year.
For dividends paid by certain foreign
corporations in U.S. tax years beginning
before January 1, 2018, this number in
column (b) generally is the denominator of
the deemed paid credit fraction under
section 902(c)(1) used for foreign tax
credit purposes.
Line 8. Enter amounts included in gross
income of the U.S. shareholder(s) under
section 951(a)(1)(A) or section 951A with
respect to the CFC. Report the inclusion
as a negative amount in columns (a)
through (c), as applicable. Report the
inclusion as a positive amount in column
(e)(x) through (e)(xvi), as applicable.
Amounts reported as positive numbers on
line 8 of column (e)(x) or (e)(xi) should
only be reported with respect to negative
amounts on line 8 of column (b). Amounts
reported as positive numbers on line 8 of
column (e)(xii) should only be reported
with respect to negative amounts on line 8
of column (a). The negative amounts
could be reported on a different schedule
J than the positive amounts if such
amounts are reclassified from one
separate category to another separate
category.
Note. Section 951(a)(1)(A) inclusions are
taken into account for the tax year before
actual distributions and section 951(a)(1)
(B) inclusions. See section 959(a).
Note. The amount included in gross
income of U.S. shareholders of the CFC
under section 951A might not be known if
there is more than one U.S. shareholder.
See the example in the instructions for
Schedule P for reporting information.
Example. Domestic Corporation
wholly owns the stock of CFC1 and CFC2,
each a foreign corporation. Thus,
Domestic Corporation is a U.S.
shareholder of CFC1 and CFC2. The
functional currency of Domestic
Corporation, CFC1, and CFC2 is the U.S.
dollar. During Year 1, CFC1 has tested
income of $100, which is equal to CFC1’s
current year E&P in Year 1, and CFC2 has
a tested loss of $40, which is equal to
CFC2’s current year E&P deficit in Year 1.
Domestic Corporation’s year 1 income
inclusion under section 951A is $60
($100 - $40). Neither CFC1 nor CFC2
have accumulated E&P at the beginning of
year 1.
Domestic Corporation reports on
CFC1’s Schedule J (Form 5471) with
respect to the general category, column
(a), as follows:
Instructions for Form 5471 (Rev. February 2020)
Line
Amount
3
$100
7
$100
8
($60)
14
$40
Domestic Corporation reports on
CFC1’s Schedule J (Form 5471) with
respect to the general category, column
(e)(xii) as follows:
Line
Amount
8
$60
12
($60)
Domestic Corporation completes a
second Schedule J (Form 5471) for CFC1,
but with respect to the section 951A
category, column (e)(xii) as follows:
Line
Amount
12
$60
14
$60
Domestic Corporation reports on
CFC2’s Schedule J (Form 5471), with
respect to the general category, column
(a), as follows:
Line
Amount
3
($40)
7
($40)
14
($40)
Line 9. Report actual distributions as
negative numbers.
Note. Actual distributions are taken into
account for the tax year before section
951(a)(1)(B) inclusions. See section 959(f)
(2). An actual distribution is first out of
PTEP, if any, and then out of the section
959(c)(3) balance. See section 959(c).
Line 10. Use line 10 to report
reclassifications of section 959(c)(2) PTEP
in columns (e)(x) through (xvi) to section
959(c)(1) PTEP in columns (e)(i) through
(viii). A potential section 951(a)(1)(B)
inclusion results in a reclassification of
section 959(c)(2) PTEP, if any, to section
959(c)(1) PTEP before reclassification out
of the section 959(c)(3) E&P balance. See
section 959(a)(2) and (f)(1). The amounts
reclassified are reported as negative
numbers in columns (e)(x) through (xvi)
and positive numbers in columns (e)(i)
through (viii), as applicable.
Line 11. Use this line to report E&P not
previously taxed, which is treated as
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earnings invested in U.S. property and,
therefore, reclassified to section 959(c)(1)
PTEP (column (e)(iii)). The amounts
reclassified are reported as negative
numbers in columns (a) through (c) and
positive numbers in column (e)(iii), as
applicable.
Line 12. Attach a statement detailing the
nature and amount of any adjustments in
E&P not accounted for on lines 8 through
11. Do not include adjustments required to
be reported on line 1b or line 6.
Line 13. The hovering deficit offset
included in column (d) is reported as a
positive number. The same amount
entered in column (d) is reported as a
negative number on line 13 of column (a)
or (b), as appropriate. See section 381(c)
(2)(B) and Regulations section
1.367(b)-7(d)(2)(ii).
Schedule M
Every U.S. person described in Category
4 must file Schedule M to report the
transactions that occurred during the
foreign corporation's annual accounting
period ending with or within the U.S.
person's tax year.
If a U.S. corporation that owns stock in
a foreign corporation is a member of a
consolidated group, list the common
parent as the U.S. person filing
Schedule M.
Important. In translating the amounts
from functional currency to U.S. dollars,
use the average exchange rate for the
foreign corporation's tax year. See section
989(b). Report the exchange rate in the
entry space provided at the top of
Schedule M using the “divide-by
convention” specified under Reporting
exchange rates on Form 5471, earlier.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471. ”
Reference ID number. Use the
reference ID number shown on Form
5471, line 1b(2).
Lines 4 and 17. Report on these lines
platform contribution transaction
payments received and paid by the foreign
corporation (without giving effect to any
netting of payments due and owed). See
Regulations section 1.482-7(b)(1)(ii). The
corporation is required to complete both
lines only if the corporation provides a
platform contribution to other controlled
participants and is required to make
platform contribution transaction
payments to other controlled participants
that provide a platform contribution to
other controlled cost sharing arrangement
participants.
Lines 5 and 18. Report on these lines
cost sharing transaction payments
received and paid by the foreign
corporation (without giving effect to any
netting of payments due and owed). See
Regulations section 1.482-7(1)(i). The
corporation is required to complete line 5
only if the corporation itself incurred
intangible development costs. If the
corporation does not itself incur intangible
development costs, then it should only
report cost sharing transaction payments
made on line 18.
Lines 9 and 22. Report on line 9 hybrid
dividends received by the foreign
corporation to which section 245A(e)(2)
applies, and report on line 22 hybrid
dividends paid by the foreign corporation
to which section 245A(e)(1) or (2) applies.
A hybrid dividend generally is any
dividend from a controlled foreign
corporation for which the CFC received a
deduction (or other tax benefit) under a
foreign tax law.
Lines 10 and 23. Report on these lines
dividends received and paid by the foreign
corporation not previously taxed under
subpart F in the current year or in any prior
year.
Lines 27 and 29. Report on these lines
the largest aggregate outstanding
accounts receivable and payable
balances during the year with the related
parties described in columns (b) through
(f). Report only accounts receivables or
payables arising in connection with the
provision of services or the sale or
processing of property. Only net accounts
receivables and payables to the extent
that the CFC’s books net the accounts
payable against the receivables as
payment of the accounts receivable.
Lines 28 and 30. Report on these lines
the largest outstanding balances during
the year of gross amounts borrowed from,
and gross amounts loaned to, the related
parties described in columns (b) through
(f). Do not enter aggregate cash flows,
year-end loan balances, average
balances, or net balances. Do not include
an account receivable or payable balance
arising in connection with the provision of
services or the sale or processing of
property if the amount of such balance
does not, at any time during the tax year,
exceed what is ordinary and necessary to
carry on the trade or business. Any
outstanding balance from these
transactions should be reported on the
Balance Sheet (Form 5471, Schedule F,
page 4) and possibly also on Schedule M,
lines 27 and 29.
Accrued payments and receipts. A
corporation that uses an accrual method
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of accounting must use accrued payments
and accrued receipts for purposes of
computing the total amount to enter on
each line of Schedule M.
Schedule O
Schedule O is used to report the
organization or reorganization of a foreign
corporation and the acquisition or
disposition of its stock.
Every U.S. citizen or resident described
in Category 2 must complete Part I. Every
U.S. person described in Category 3 must
complete Part II.
See Regulations section 1.6046-1(i) for
rules on determining when U.S. persons
constructively own stock of a foreign
corporation and therefore are subject to
the section 6046 filing requirements.
Name of person filing Form 5471. The
name of the person filing Form 5471 is
generally the name of the U.S. person
described in the applicable category or
categories of filers (see Categories of
Filers, earlier). However, in the case of a
consolidated return, enter the name of the
U.S. parent in the field for “Name of
person filing Form 5471.”
Reference ID number. Use the
reference ID number shown on Form
5471, line 1b(2).
Part I
Column (d). Enter the date the
shareholder first acquired 10% or more (in
value or voting power) of the outstanding
stock of the foreign corporation.
Column (e). Enter the date the
shareholder acquired (whether in one or
more transactions) an additional 10% or
more (in value or voting power) of the
outstanding stock of the foreign
corporation.
Part II
Section A—General Shareholder
Information
If the shareholder's latest tax return was
filed electronically, enter “e-filed” in
column (b)(3) instead of a service center.
Section C—Acquisition of Stock
Section C is completed by shareholders
who are completing Schedule O because
they have acquired sufficient stock in a
foreign corporation. If the shareholder
acquired the stock in more than one
transaction, use a separate line to report
each transaction.
Column (d). Enter the method of
acquisition (for example, purchase, gift,
bequest, trade).
Column (e)(2). Enter the number of
shares acquired indirectly (within the
Instructions for Form 5471 (Rev. February 2020)
meaning of section 958(a)(2)) by the
shareholder listed in column (a).
Column (e)(3). Enter the number of
shares constructively owned (within the
meaning of section 958(b)) by the
shareholder listed in column (a).
Section D—Disposition of Stock
Section D must be completed by
shareholders who dispose of their interest
(in whole or in part) in a foreign
corporation.
Column (d). Enter the method of
disposition (for example, sale, bequest,
gift, trade).
Example. In 1999, Mr. Jackson, a
U.S. citizen, purchased 10,000 shares of
common stock of foreign corporation X.
The purchase represented 10%
ownership of the foreign corporation.
On July 1, 2019, Mr. Jackson made a
gift of 5,000 shares of foreign corporation
X to his son, John. Because Mr. Jackson
has reduced his holding in the foreign
corporation, he is required to complete
Form 5471 and Schedule O. To show the
required information about the disposition,
Mr. Jackson completes Section D as
follows:
• Enters his name in column (a).
• Enters “common” in column (b).
• Enters “July 1, 2019” in column (c).
• Enters “gift” in column (d).
• Enters “5,000” in column (e)(1).
• Enters “-0-” in column (f) because the
disposition was by gift.
• Enters the name and address of his
son, John, in column (g).
Section F—Additional Information
Item (b). List the date of any
reorganization of the foreign corporation
that occurred during the last 4 years while
any U.S. person held 10% or more in
value or vote (directly or indirectly) of the
corporation's stock. If there is more than
one such date, use the most recent date.
However, do not enter a date for which
information was reported on Schedule E.
Instead, enter the date (if any) of any
reorganization prior to that date (if it is
within the last 4 years).
Example for Item (c). Mr. Lyons, a
U.S. person, acquires a 10% ownership in
foreign corporation F. F is the 100% owner
of two foreign corporations, FI and FJ. F is
also a 50% owner of foreign corporation
FK. In addition, F is 90% owned by foreign
corporation W. Mr. Lyons does not own
any of the stock of corporation W.
Mr. Lyons completes and files Form
5471 and Schedule O for the corporations
in which he is a 10% or more shareholder.
Mr. Lyons also is required to submit a
chart if the foreign corporation is a
member of a chain of corporations, and to
indicate if he is a 10% or more
shareholder in any of those corporations.
Mr. Lyons would prepare a list showing
the corporations as follows.
• Corporation W.
• Corporation F.
• Corporation FI.
• Corporation FJ.
• Corporation FK.
Then Mr. Lyons is required to indicate
that he is a 10% or more shareholder in
corporations F, FI, and FJ.
Schedule P
Use Schedule P to report the PTEP of the
U.S. shareholder of a CFC in the CFC’s
functional currency (Part I) and in U.S.
dollars (Part II). Also use this schedule to
report the PTEP of the U.S. shareholder of
an SFC that is only treated as a CFC for
limited purposes under section 965(e)(2).
Note. A separate Schedule P must be
completed by each Category 1, 4, or 5
U.S. shareholder of the foreign
corporation with respect to which reporting
is furnished on this Form 5471. However,
Category 1 and 5 filers who are related
constructive U.S. shareholders are not
required to file Schedule P for
foreign-controlled corporations. See
Certain Category 1 and Category 5 Filers
under Categories of Filers.
If a U.S. shareholder wholly owns the
CFC, Schedule P should include the same
information reported on Schedule J, Part I,
column (e). If there is more than one U.S.
shareholder, the amounts reported on
Schedule P with respect to each U.S.
shareholder might be different from the
amounts reported on Schedule J.
Example. Corporation A, a domestic
corporation, owns 50% of the only class of
stock of CFC1 and Corporation B, a
domestic corporation, owns the remaining
50% of the stock of CFC1. Corporation A
wholly owns the only class of stock of
CFC2. The functional currency of all
corporations is the U.S. dollar. CFC1 has
tested income of $100x and CFC2 has
tested loss of $30x. See section 951A(c)
(2). Neither Corporation A nor Corporation
B has any net deemed tangible income
return that would reduce the tested
income taken into account by Corporation
A or B with respect to CFC1. Corporation
A has a section 951A inclusion of $20
because its pro rata share of CFC1’s
tested income ($50x) is offset by its pro
rata share of CFC2’s tested loss ($30x).
Corporation B has a section 951A
inclusion of $50x. On Schedule P of the
Form 5471 with respect to CFC1 filed by
Corporation B, Corporation B will report on
line 7, column (i), $50x of PTEP as a result
of its section 951A inclusion with respect
to CFC1. Corporation A will report $20x of
Instructions for Form 5471 (Rev. February 2020)
-31-
PTEP as a result of its section 951A
inclusion on its Form 5471, Schedule P,
line 7, column (i), with respect to CFC1.
The Form 5471, Schedule J, for CFC1
should include PTEP of $70x with respect
to the aggregate section 951A inclusions
of Corporation A and Corporation B.
However, if Corporation A does not know
Corporation B’s section 951A inclusion at
the time Corporation A files its Form 5471,
Corporation A will only be able to
complete Schedule J, Part I, with respect
to its PTEP of $20x on line 8, column (e)
(xvi). Similarly, Corporation B will only be
able to complete Schedule J, Part I, with
respect to its PTEP of $50x on line 8,
column (e)(xvi). In the following year,
Corporation A and Corporation B should
each report the other corporation’s PTEP
on Schedule J, Part I, line 1b, column (e)
(xvi).
Name of person filing Form 5471. For
the December 2019 revision of
Schedule P (Form 5471), there should be
entry spaces for the name and identifying
number of the person filing Form 5471.
Please include this information in the
top margin of page 1 of the schedule.
Please note that the name of the person
filing Form 5471 is generally the name of
the U.S. person described in the
applicable category or categories of filers
(see Categories of Filers, earlier).
However, in the case of a consolidated
return, enter the name of the U.S. parent
in the field for “Name of person filing Form
5471.”
Reference ID number. If applicable, use
the reference ID number shown on Form
5471, page 1, Item 1b(2).
Lines a and b. Complete a separate
Schedule P for each applicable separate
category of income. Enter the appropriate
code on line a (at the top of page 1 of
Schedule P). To determine the
appropriate code, see Categories of
Income in the Instructions for Form 1118.
A foreign corporation may have PTEP in a
PTEP group within any of the separate
categories of income, with the exception
of foreign branch category income. See
Regulations section 1.960-3(c)(1).
If code 901(j) is entered on line a, enter
on line b the country code for the
sanctioned country using the two-letter
codes (from the list at IRS.gov/
countrycodes).
Note. For purposes of this Schedule P,
include in each separate category of
income foreign and U.S. income.
Columns (a) through (q). Enter
amounts on this schedule in the functional
currency of the foreign corporation as
reported on Form 5471, page 1, Item 1h.
Use columns (a) through (q) to report
the opening balance, current year
additions and subtractions, and the
closing balance in the foreign
corporation's PTEP; section 964(a) E&P
accumulated since 1962 that have
resulted in inclusions under subpart F; and
amounts treated as PTEP under section
965(b)(4)(A). Pre-1987 U.S. dollar PTEP
should be translated into the foreign
corporation's functional currency using the
rules of Notice 88-70 and added to
post-1986 amounts in the appropriate
PTEP category.
Columns (a) through (p) of Schedule P
correspond to Schedule J, columns (e)(i)
through (e)(xvi). See the instructions for
Schedule J for specific line instructions.
Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the United
States. You are required to give us the information. We need it to ensure that you are complying with these laws and to allow us to
figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the form
displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their contents
may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential,
as required by section 6103.
The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden for
individual and business taxpayers filing this form is approved under OMB control number 1545-0074 and 1545-0123 and is included in
the estimates shown in the instructions for their individual and business income tax return.
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Instructions for Form 5471 (Rev. February 2020)
Form 5471
Codes for Principal Business Activity
This list of principal business activities and their
associated codes is designed to classify an enterprise
by the type of activity in which it is engaged to facilitate
the administration of the Internal Revenue Code. These
Agriculture, Forestry, Fishing
and Hunting
Crop Production
111100 Oilseed & Grain Farming
111210 Vegetable & Melon Farming
(including potatoes & yams)
111300 Fruit & Tree Nut Farming
111400 Greenhouse, Nursery, &
Floriculture Production
111900 Other Crop Farming (including
tobacco, cotton, sugarcane, hay,
peanut, sugar beet & all other
crop farming)
Animal Production
112111 Beef Cattle Ranching & Farming
112112 Cattle Feedlots
112120 Dairy Cattle & Milk Production
112210 Hog & Pig Farming
112300 Poultry & Egg Production
112400 Sheep & Goat Farming
112510 Aquaculture (including shellfish &
finfish farms & hatcheries)
112900 Other Animal Production
Forestry and Logging
113110 Timber Tract Operations
113210 Forest Nurseries & Gathering of
Forest Products
113310 Logging
Fishing, Hunting and Trapping
114110 Fishing
114210 Hunting & Trapping
Support Activities for Agriculture and
Forestry
115110 Support Activities for Crop
Production (including cotton
ginning, soil preparation,
planting, & cultivating)
115210 Support Activities for Animal
Production
115310 Support Activities For Forestry
Mining
211120
211130
212110
212200
212310
212320
212390
213110
Crude Petroleum Extraction
Natural Gas Extraction
Coal Mining
Metal Ore Mining
Stone Mining & Quarrying
Sand, Gravel, Clay, & Ceramic &
Refractory Minerals Mining &
Quarrying
Other Nonmetallic Mineral
Mining & Quarrying
Support Activities for Mining
Utilities
221100
221210
221300
221500
Electric Power Generation,
Transmission & Distribution
Natural Gas Distribution
Water, Sewage & Other Systems
Combination Gas & Electric
Construction
Construction of Buildings
236110 Residential Building Construction
236200 Nonresidential Building
Construction
Heavy and Civil Engineering
Construction
237100 Utility System Construction
237210 Land Subdivision
237310 Highway, Street, & Bridge
Construction
237990 Other Heavy & Civil Engineering
Construction
Specialty Trade Contractors
238100 Foundation, Structure, & Building
Exterior Contractors (including
framing carpentry, masonry,
glass, roofing, & siding)
238210 Electrical Contractors
238220 Plumbing, Heating, &
Air-Conditioning Contractors
238290 Other Building Equipment
Contractors
238300 Building Finishing Contractors
(including drywall, insulation,
238900
principal business activity codes are based on the North
American Industry Classification System.
Using the list of activities and codes below,
determine from which activity the company derives the
largest percentage of its “total receipts.” If the company
purchases raw materials and supplies them to a
subcontractor to produce the finished product, but
painting, wallcovering, flooring,
tile, & finish carpentry)
Other Specialty Trade
Contractors (including site
preparation)
Manufacturing
Food Manufacturing
311110 Animal Food Mfg
311200 Grain & Oilseed Milling
311300 Sugar & Confectionery Product
Mfg
311400 Fruit & Vegetable Preserving &
Specialty Food Mfg
311500 Dairy Product Mfg
311610 Animal Slaughtering and
Processing
311710 Seafood Product Preparation &
Packaging
311800 Bakeries, Tortilla & Dry Pasta
Mfg
311900 Other Food Mfg (including
coffee, tea, flavorings &
seasonings)
Beverage and Tobacco Product
Manufacturing
312110 Soft Drink & Ice Mfg
312120 Breweries
312130 Wineries
312140 Distilleries
312200 Tobacco Manufacturing
Textile Mills and Textile Product Mills
313000 Textile Mills
314000 Textile Product Mills
Apparel Manufacturing
315100 Apparel Knitting Mills
315210 Cut & Sew Apparel Contractors
315220 Men's & Boys' Cut & Sew
Apparel Mfg
315240 Women's, Girls' & Infants' Cut &
Sew Apparel Mfg
315280 Other Cut & Sew Apparel Mfg
315990 Apparel Accessories & Other
Apparel Mfg
Leather and Allied Product
Manufacturing
316110 Leather & Hide Tanning &
Finishing
316210 Footwear Mfg (including rubber
& plastics)
316990 Other Leather & Allied Product
Mfg
Wood Product Manufacturing
321110 Sawmills & Wood Preservation
321210 Veneer, Plywood, & Engineered
Wood Product Mfg
321900 Other Wood Product Mfg
Paper Manufacturing
322100 Pulp, Paper, & Paperboard Mills
322200 Converted Paper Product Mfg
Printing and Related Support Activities
323100 Printing & Related Support
Activities
Petroleum and Coal Products
Manufacturing
324110 Petroleum Refineries (including
integrated)
324120 Asphalt Paving, Roofing, &
Saturated Materials Mfg
324190 Other Petroleum & Coal
Products Mfg
Chemical Manufacturing
325100 Basic Chemical Mfg
325200 Resin, Synthetic Rubber, &
Artificial & Synthetic Fibers &
Filaments Mfg
325300 Pesticide, Fertilizer, & Other
Agricultural Chemical Mfg
325410 Pharmaceutical & Medicine Mfg
325500 Paint, Coating, & Adhesive Mfg
325600 Soap, Cleaning Compound, &
Toilet Preparation Mfg
325900 Other Chemical Product &
Preparation Mfg
Plastics and Rubber Products
Manufacturing
326100 Plastics Product Mfg
retains title to the product, the company is considered a
manufacturer and must use one of the manufacturing
codes (311110-339900).
Enter on page 1, Item 1f, the six-digit code selected
from the list below. In item 1g, enter a brief description
of the company's business activity.
326200 Rubber Product Mfg
Nonmetallic Mineral Product
Manufacturing
327100 Clay Product & Refractory Mfg
327210 Glass & Glass Product Mfg
327300 Cement & Concrete Product Mfg
327400 Lime & Gypsum Product Mfg
327900 Other Nonmetallic Mineral
Product Mfg
Primary Metal Manufacturing
331110 Iron & Steel Mills & Ferroalloy
Mfg
331200 Steel Product Mfg from
Purchased Steel
331310 Alumina & Aluminum Production
& Processing
331400 Nonferrous Metal (except
Aluminum) Production &
Processing
331500 Foundries
Fabricated Metal Product
Manufacturing
332110 Forging & Stamping
332210 Cutlery & Handtool Mfg
332300 Architectural & Structural Metals
Mfg
332400 Boiler, Tank, & Shipping
Container Mfg
332510 Hardware Mfg
332610 Spring & Wire Product Mfg
332700 Machine Shops; Turned Product;
& Screw, Nut, & Bolt Mfg
332810 Coating, Engraving, Heat
Treating, & Allied Activities
332900 Other Fabricated Metal Product
Mfg
Machinery Manufacturing
333100 Agriculture, Construction, &
Mining Machinery Mfg
333200 Industrial Machinery Mfg
333310 Commercial & Service Industry
Machinery Mfg
333410 Ventilation, Heating,
Air-Conditioning, & Commercial
Refrigeration Equipment Mfg
333510 Metalworking Machinery Mfg
333610 Engine, Turbine & Power
Transmission Equipment Mfg
333900 Other General Purpose
Machinery Mfg
Computer and Electronic Product
Manufacturing
334110 Computer & Peripheral
Equipment Mfg
334200 Communications Equipment Mfg
334310 Audio & Video Equipment Mfg
334410 Semiconductor & Other
Electronic Component Mfg
334500 Navigational, Measuring,
Electromedical, & Control
Instruments Mfg
334610 Manufacturing & Reproducing
Magnetic & Optical Media
Electrical Equipment, Appliance, and
Component Manufacturing
335100 Electric Lighting Equipment Mfg
335200 Major Household Appliance Mfg
335310 Electrical Equipment Mfg
335900 Other Electrical Equipment &
Component Mfg
Transportation Equipment
Manufacturing
336100 Motor Vehicle Mfg
336210 Motor Vehicle Body & Trailer Mfg
336300 Motor Vehicle Parts Mfg
336410 Aerospace Product & Parts Mfg
336510 Railroad Rolling Stock Mfg
336610 Ship & Boat Building
336990 Other Transportation Equipment
Mfg
Furniture and Related Product
Manufacturing
337000 Furniture & Related Product
Manufacturing
Miscellaneous Manufacturing
339110 Medical Equipment & Supplies
Mfg
-33-
339900
Other Miscellaneous
Manufacturing
Wholesale Trade
Merchant Wholesalers, Durable Goods
423100 Motor Vehicle & Motor Vehicle
Parts & Supplies
423200 Furniture & Home Furnishings
423300 Lumber & Other Construction
Materials
423400 Professional & Commercial
Equipment & Supplies
423500 Metal & Mineral (except
Petroleum)
423600 Household Appliances &
Electrical & Electronic Goods
423700 Hardware & Plumbing & Heating
Equipment & Supplies
423800 Machinery, Equipment, &
Supplies
423910 Sporting & Recreational Goods &
Supplies
423920 Toy & Hobby Goods & Supplies
423930 Recyclable Materials
423940 Jewelry, Watch, Precious Stone,
& Precious Metals
423990 Other Miscellaneous Durable
Goods
Merchant Wholesalers, Nondurable
Goods
424100 Paper & Paper Products
424210 Drugs & Druggists' Sundries
424300 Apparel, Piece Goods, & Notions
424400 Grocery & Related Products
424500 Farm Product Raw Materials
424600 Chemical & Allied Products
424700 Petroleum & Petroleum Products
424800 Beer, Wine, & Distilled Alcoholic
Beverages
424910 Farm Supplies
424920 Book, Periodical, & Newspapers
424930 Flower, Nursery Stock, & Florists'
Supplies
424940 Tobacco & Tobacco Products
424950 Paint, Varnish, & Supplies
424990 Other Miscellaneous Nondurable
Goods
Wholesale Electronic Markets and
Agents and Brokers
425110 Business to Business Electronic
Markets
425120 Wholesale Trade Agents &
Brokers
Retail Trade
Motor Vehicle and Parts Dealers
441110 New Car Dealers
441120 Used Car Dealers
441210 Recreational Vehicle Dealers
441222 Boat Dealers
441228 Motorcycle, ATV, & All other
Motor Vehicle Dealers
441300 Automotive Parts, Accessories,
& Tire Stores
Furniture and Home Furnishings Stores
442110 Furniture Stores
442210 Floor Covering Stores
442291 Window Treatment Stores
442299 All Other Home Furnishings
Stores
Electronics and Appliance Stores
443141 Household Appliance Stores
443142 Electronic Stores (including
Audio, Video, Computer, &
Camera Stores)
Building Material and Garden
Equipment and Supplies Dealers
444110 Home Centers
444120 Paint & Wallpaper Stores
444130 Hardware Stores
444190 Other Building Material Dealers
444200 Lawn & Garden Equipment &
Supplies Stores
Form 5471 (Continued)
Food and Beverage Stores
445110 Supermarkets and Other
Grocery (except Convenience)
Stores
445120 Convenience Stores
445210 Meat Markets
445220 Fish & Seafood Markets
445230 Fruit & Vegetable Markets
445291 Baked Goods Stores
445292 Confectionery & Nut Stores
445299 All Other Specialty Food Stores
445310 Beer, Wine, & Liquor Stores
Health and Personal Care Stores
446110 Pharmacies & Drug Stores
446120 Cosmetics, Beauty Supplies, &
Perfume Stores
446130 Optical Goods Stores
446190 Other Health & Personal Care
Stores
Gasoline Stations
447100 Gasoline Stations (including
convenience stores with gas)
Clothing and Clothing Accessories
Stores
448110 Men's Clothing Stores
448120 Women's Clothing Stores
448130 Children's & Infants' Clothing
Stores
448140 Family Clothing Stores
448150 Clothing Accessories Stores
448190 Other Clothing Stores
448210 Shoe Stores
448310 Jewelry Stores
448320 Luggage & Leather Goods
Stores
Sporting Goods, Hobby, Book, and
Music Stores
451110 Sporting Goods Stores
451120 Hobby, Toy, & Game Stores
451130 Sewing, Needlework, & Piece
Goods Stores
451140 Musical Instrument & Supplies
Stores
451211 Book Stores
451212 News Dealers & Newsstands
General Merchandise Stores
452200 Department Stores
452300 General Merchandise Stores,
incl. Warehouse Clubs and
Supercenters
Miscellaneous Store Retailers
453110 Florists
453210 Office Supplies & Stationery
Stores
453220 Gift, Novelty, & Souvenir Stores
453310 Used Merchandise Stores
453910 Pet & Pet Supplies Stores
453920 Art Dealers
453930 Manufactured (Mobile) Home
Dealers
453990 All Other Miscellaneous Store
Retailers (including tobacco,
candle, & trophy shops)
Nonstore Retailers
454110 Electronic Shopping &
Mail-Order Houses
454210 Vending Machine Operators
454310 Fuel Dealers (including Heating
Oil and Liquefied Petroleum)
454390 Other Direct Selling
Establishments (including
door-to-door retailing, frozen
food plan providers, party plan
merchandisers, & coffee-break
service providers)
Transportation and
Warehousing
Air, Rail, and Water Transportation
481000 Air Transportation
482110 Rail Transportation
483000 Water Transportation
Truck Transportation
484110 General Freight Trucking, Local
484120 General Freight Trucking,
Long-distance
484200 Specialized Freight Trucking
Transit and Ground Passenger
Transportation
485110 Urban Transit Systems
485210 Interurban & Rural Bus
Transportation
485310 Taxi Service
485320
485410
Limousine Service
School & Employee Bus
Transportation
485510 Charter Bus Industry
485990 Other Transit & Ground
Passenger Transportation
Pipeline Transportation
486000 Pipeline Transportation
Scenic & Sightseeing Transportation
487000 Scenic & Sightseeing
Transportation
Support Activities for Transportation
488100 Support Activities for Air
Transportation
488210 Support Activities for Rail
Transportation
488300 Support Activities for Water
Transportation
488410 Motor Vehicle Towing
488490 Other Support Activities for Road
Transportation
488510 Freight Transportation
Arrangement
488990 Other Support Activities for
Transportation
Couriers and Messengers
492110 Couriers
492210 Local Messengers & Local
Delivery
Warehousing and Storage
493100 Warehousing & Storage (except
lessors of mini-warehouses &
self-storage units)
Information
Publishing Industries (except Internet)
511110 Newspaper Publishers
511120 Periodical Publishers
511130 Book Publishers
511140 Directory & Mailing List
Publishers
511190 Other Publishers
511210 Software Publishers
Motion Picture and Sound Recording
Industries
512100 Motion Picture & Video Industries
(except video rental)
512200 Sound Recording Industries
Broadcasting (except Internet)
515100 Radio & Television Broadcasting
515210 Cable & Other Subscription
Programming
Telecommunications
517000 Telecommunications (including
paging, cellular, satellite, cable &
other program distribution,
resellers, & other
telecommunications, and Internet
service providers)
Data Processing Services
518210 Data Processing, Hosting, &
Related Services
Other Information Services
519100 Other Information Services
(including news syndicates &
libraries, Internet publishing &
broadcasting)
Finance and Insurance
Depository Credit Intermediation
522110 Commercial Banking
522120 Savings Institutions
522130 Credit Unions
522190 Other Depository Credit
Intermediation
Nondepository Credit Intermediation
522210 Credit Card Issuing
522220 Sales Financing
522291 Consumer Lending
522292 Real Estate Credit (including
mortgage bankers & originators)
522293 International Trade Financing
522294 Secondary Market Financing
522298 All Other Nondepository Credit
Intermediation
Activities Related to Credit
Intermediation
522300 Activities Related to Credit
Intermediation (including loan
brokers, check clearing, &
money transmitting)
Securities, Commodity Contracts, and
Other Financial Investments and
Related Activities
523110 Investment Banking & Securities
Dealing
523120 Securities Brokerage
523130 Commodity Contracts Dealing
523140 Commodity Contracts Brokerage
523210 Securities & Commodity
Exchanges
523900 Other Financial Investment
Activities (including portfolio
management & investment
advice)
Insurance Carriers and Related
Activities
524140 Direct Life, Health, & Medical
Insurance & Reinsurance
Carriers
524150 Direct Insurance & Reinsurance
(except Life, Health & Medical)
Carriers
524210 Insurance Agencies &
Brokerages
524290 Other Insurance Related
Activities (including third-party
administration of insurance and
pension funds)
Funds, Trusts, and Other Financial
Vehicles
525100 Insurance & Employee Benefit
Funds
525910 Open-End Investment Funds
(Form 1120-RIC, U.S. Income
Tax Return for Regulated
Investment Companies)
525920 Trusts, Estates, & Agency
Accounts
525990 Other Financial Vehicles
(including mortgage REITs and
closed-end investment funds)
“Offices of Bank Holding
Companies” and “Offices of
Other Holding Companies” are
located under Management of
Companies (Holding
Companies) below.
Real Estate and Rental and
Leasing
Real Estate
531110 Lessors of Residential Buildings
& Dwellings (including equity
REITs)
531120 Lessors of Nonresidential
Buildings (except
Mini-warehouses) (including
equity REITs)
531130 Lessors of Mini-warehouses &
Self-Storage Units (including
equity REITs)
531190 Lessors of Other Real Estate
Property (including equity REITs)
531210 Offices of Real Estate Agents &
Brokers
531310 Real Estate Property Managers
531320 Offices of Real Estate Appraisers
531390 Other Activities Related to Real
Estate
Rental and Leasing Services
532100 Automotive Equipment Rental &
Leasing
532210 Consumer Electronics &
Appliances Rental
532281 Formal Wear & Costume Rental
532282 Video Tape & Disc Rental
532283 Home Health Equipment Rental
532284 Recreational Goods Rental
532289 All Other Consumer Goods
Rental
532310 General Rental Centers
532400 Commercial & Industrial
Machinery & Equipment Rental &
Leasing
Lessors of Nonfinancial Intangible
Assets (except copyrighted works)
533110 Lessors of Nonfinancial
Intangible Assets (except
copyrighted works)
Professional, Scientific, and
Technical Services
Legal Services
541110 Offices of Lawyers
541190 Other Legal Services
Accounting, Tax Preparation,
Bookkeeping, and Payroll Services
541211 Offices of Certified Public
Accountants
-34-
541213 Tax Preparation Services
541214 Payroll Services
541219 Other Accounting Services
Architectural, Engineering, and Related
Services
541310 Architectural Services
541320 Landscape Architecture Services
541330 Engineering Services
541340 Drafting Services
541350 Building Inspection Services
541360 Geophysical Surveying &
Mapping Services
541370 Surveying & Mapping (except
Geophysical) Services
541380 Testing Laboratories
Specialized Design Services
541400 Specialized Design Services
(including interior, industrial,
graphic, & fashion design)
Computer Systems Design and Related
Services
541511 Custom Computer Programming
Services
541512 Computer Systems Design
Services
541513 Computer Facilities Management
Services
541519 Other Computer Related
Services
Other Professional, Scientific, and
Technical Services
541600 Management, Scientific, &
Technical Consulting Services
541700 Scientific Research &
Development Services
541800 Advertising & Related Services
541910 Marketing Research & Public
Opinion Polling
541920 Photographic Services
541930 Translation & Interpretation
Services
541940 Veterinary Services
541990 All Other Professional, Scientific,
& Technical Services
Management of Companies
(Holding Companies)
551111
551112
Offices of Bank Holding
Companies
Offices of Other Holding
Companies
Administrative and Support and
Waste Management and
Remediation Services
Administrative and Support Services
561110 Office Administrative Services
561210 Facilities Support Services
561300 Employment Services
561410 Document Preparation Services
561420 Telephone Call Centers
561430 Business Service Centers
(including private mail centers &
copy shops)
561440 Collection Agencies
561450 Credit Bureaus
561490 Other Business Support Services
(including repossession services,
court reporting, & stenotype
services)
561500 Travel Arrangement &
Reservation Services
561600 Investigation & Security Services
561710 Exterminating & Pest Control
Services
561720 Janitorial Services
561730 Landscaping Services
561740 Carpet & Upholstery Cleaning
Services
561790 Other Services to Buildings &
Dwellings
561900 Other Support Services
(including packaging & labeling
services, & convention & trade
show organizers)
Waste Management and Remediation
Services
562000 Waste Management &
Remediation Services
Educational Services
611000
Educational Services (including
schools, colleges, & universities)
Form 5471 (Continued)
Health Care and Social
Assistance
Offices of Physicians and Dentists
621111 Offices of Physicians (except
mental health specialists)
621112 Offices of Physicians, Mental
Health Specialists
621210 Offices of Dentists
Offices of Other Health Practitioners
621310 Offices of Chiropractors
621320 Offices of Optometrists
621330 Offices of Mental Health
Practitioners (except Physicians)
621340 Offices of Physical, Occupational
& Speech Therapists, &
Audiologists
621391 Offices of Podiatrists
621399 Offices of All Other
Miscellaneous Health
Practitioners
Outpatient Care Centers
621410 Family Planning Centers
621420 Outpatient Mental Health &
Substance Abuse Centers
621491 HMO Medical Centers
621492 Kidney Dialysis Centers
621493 Freestanding Ambulatory
Surgical & Emergency Centers
621498 All Other Outpatient Care
Centers
Medical and Diagnostic Laboratories
621510 Medical & Diagnostic
Laboratories
Home Health Care Services
621610 Home Health Care Services
Other Ambulatory Health Care Services
621900 Other Ambulatory Health Care
Services (including ambulance
services & blood & organ banks)
Hospitals
622000 Hospitals
Nursing and Residential Care Facilities
623000 Nursing & Residential Care
Facilities
Social Assistance
624100 Individual & Family Services
624200 Community Food & Housing, &
Emergency & Other Relief
Services
624310 Vocational Rehabilitation
Services
624410 Child Day Care Services
Arts, Entertainment, and
Recreation
Performing Arts, Spectator Sports, and
Related Industries
711100 Performing Arts Companies
711210 Spectator Sports (including
sports clubs & racetracks)
711300 Promoters of Performing Arts,
Sports, & Similar Events
711410 Agents & Managers for Artists,
Athletes, Entertainers, & Other
Public Figures
711510 Independent Artists, Writers, &
Performers
Museums, Historical Sites, and Similar
Institutions
712100 Museums, Historical Sites, &
Similar Institutions
Amusement, Gambling, and Recreation
Industries
713100 Amusement Parks & Arcades
713200 Gambling Industries
713900 Other Amusement & Recreation
Industries (including golf
courses, skiing facilities,
marinas, fitness centers, &
bowling centers)
Accommodation and Food
Services
Accommodation
721110 Hotels (except Casino Hotels) &
Motels
721120 Casino Hotels
721191 Bed & Breakfast Inns
721199 All Other Traveler
Accommodation
721210 RV (Recreational Vehicle) Parks
& Recreational Camps
721310 Rooming & Boarding Houses,
Dormitories & Workers’ Camps
Food Services and Drinking Places
722300 Special Food Services (including
food service contractors &
caterers)
722410 Drinking Places (Alcoholic
Beverages)
722511 Full Service Restaurants
722513 Limited Service Restaurants
722514 Cafeterias & Buffets
722515 Snack & Nonalcoholic Beverage
Bars
Other Services
Repair and Maintenance
811110 Automotive Mechanical &
Electrical Repair & Maintenance
811120 Automotive Body, Paint, Interior,
& Glass Repair
811190 Other Automotive Repair &
Maintenance (including oil
change & lubrication shops & car
washes)
811210 Electronic & Precision
Equipment Repair &
Maintenance
811310 Commercial & Industrial
Machinery & Equipment (except
-35-
Automotive & Electronic) Repair
& Maintenance
811410 Home & Garden Equipment &
Appliance Repair & Maintenance
811420 Reupholstery & Furniture Repair
811430 Footwear & Leather Goods
Repair
811490 Other Personal & Household
Goods Repair & Maintenance
Personal and Laundry Services
812111 Barber Shops
812112 Beauty Salons
812113 Nail Salons
812190 Other Personal Care Services
(including diet & weight reducing
centers)
812210 Funeral Homes & Funeral
Services
812220 Cemeteries & Crematories
812310 Coin-Operated Laundries &
Drycleaners
812320 Drycleaning & Laundry Services
(except Coin-Operated)
812330 Linen & Uniform Supply
812910 Pet Care (except Veterinary)
Services
812920 Photofinishing
812930 Parking Lots & Garages
812990 All Other Personal Services
Religious, Grantmaking, Civic,
Professional, and Similar Organizations
813000 Religious, Grantmaking, Civic,
Professional, & Similar
Organizations (including
condominium and homeowners
associations)
| File Type | application/pdf |
| File Title | Instructions for Form 5471 (Rev. February 2020) |
| Subject | Instructions for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations |
| Author | W:CAR:MP:FP |
| File Modified | 2020-02-20 |
| File Created | 2020-02-19 |