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

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SCHEDULE E
(Form 5471)

DRAFT AS OF
July 2, 2021
DO NOT FILE
Income, War Profits, and Excess Profits Taxes Paid or Accrued

(Rev. December 2021)
Department of the Treasury
Internal Revenue Service
Name of person filing Form 5471
Name of foreign corporation

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Identifying number
Reference ID number (see instructions)

EIN (if any)

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

Part I

OMB No. 1545-0123

▶ Attach to Form 5471.
Go to www.irs.gov/Form5471 for instructions and the latest information.

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Taxes for Which a Foreign Tax Credit Is Allowed

Section 1 — Taxes Paid or Accrued Directly by Foreign Corporation

(b)
EIN or Reference
ID Number
of Payor Entity

(a)
Name of Payor Entity

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

(c)
Unsuspended
Taxes

(e)
Foreign Tax Year of Payor
Entity to Which Tax Relates
(Year/Month/Day)

(f)
U.S. Tax Year of Payor Entity
to Which Tax Relates
(Year/Month/Day)

(l)
In U.S. Dollars
(divide column (j)
by column (k))

(m)
In Functional Currency
of Foreign Corporation

1
2
3
4
(g)
Income Subject to Tax
in the Foreign Jurisdiction
(see instructions)

(h)
If taxes are paid on
U.S. source income,
check box

(i)
Local Currency in
Which Tax Is Payable
(enter code—see instructions)

(j)
Tax Paid or Accrued
(in local currency in which
the tax is payable)

1
2
3
4
5
Total (combine lines 1 through 4 of column (l)). Also report amount on Schedule E-1, line 4 .
6
Total (combine lines 1 through 4 of column (m)) . . . . . . . . . . . . . . .
Section 2 — Taxes Deemed Paid by Foreign Corporation
(a)
Name of Lower-Tier Distributing Foreign Corporation

(b)
EIN or Reference ID
Number of Lower-Tier
Distributing Foreign
Corporation

(k)
Conversion Rate
to U.S. Dollars

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

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(d)
PTEP Group
(enter code)

(e)
Annual PTEP Account
(enter year)

1
2
3
4
(f)
PTEP Distributed
(enter amount in functional currency)

1
2
3
4
5

(g)
Total Amount of PTEP in the PTEP Group
(in functional currency)

Total (combine lines 1 through 4 of column (i)). Also report amount on Schedule E-1, line 6 .

For Paperwork Reduction Act Notice, see instructions.

(i)
Foreign Income Taxes Properly Attributable
to PTEP and not Previously Deemed Paid
((column (f)/column (g)) x column (h)) (USD)

(h)
Total Amount of the PTEP Group Taxes
With Respect to PTEP Group (USD)

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Cat. No. 71397A

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Schedule E (Form 5471) (Rev. 12-2021)

Schedule E (Form 5471) (Rev. 12-2021)
Name of foreign corporation

DRAFT AS OF
July 2, 2021
DO NOT FILE

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

Part II

Election

Page 2
Reference ID number (see instructions)

EIN (if any)

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

Part III

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

1
2
3
4

(b)
EIN or Reference
ID Number
of Payor Entity

(c)
Section 901(j)

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

(e)
Section 901(m)

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

Schedule E-1

9
10
11
12
13
14
15
16

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(h)
Other

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(i)
Total

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

IMPORTANT: Enter amounts in U.S. dollars.
1a
b
c
2
3a
b
4
5
6
7
8

(g)
Suspended
Taxes

(f)
U.S. Taxes

Balance at beginning of year (as reported in prior year Schedule E-1) . . . . . . . .
Beginning balance adjustments (attach statement) . . . . . . . . . . . . . .
Adjusted beginning balance (combine lines 1a and 1b)
. . . . . . . . . . . .
Adjustment for foreign tax redetermination
. . . . . . . . . . . . . . . .
Taxes unsuspended under anti-splitter rules . . . . . . . . . . . . . . . .
Taxes suspended under anti-splitter rules . . . . . . . . . . . . . . . . .
Taxes reported on Schedule E, Part I, Section 1, line 5, column (l) . . . . . . . . .
Taxes carried over in nonrecognition transactions . . . . . . . . . . . . . .
Taxes reported on Schedule E, Part I, Section 2, line 5, column (i) . . . . . . . . .
Other adjustments (attach statement) . . . . . . . . . . . . . . . . . .
Taxes paid or accrued on current income/E&P or accumulated E&P (combine lines 1c
through 7) . . . . . . . . . . . . . . . . . . . . . . . . . . .
Taxes deemed paid with respect to inclusions (see instructions) . . . . . . . . . .
Taxes deemed paid with respect to actual distributions . . . . . . . . . . . .
Taxes on amounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P . . .
Other (attach statement)
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Balance of taxes paid or accrued (combine lines 8 through 12 in columns (a), (b), and (c))
Reserved for future use . . . . . . . . . . . . . . . . . . . . . . .
Reduction for other taxes not deemed paid . . . . . . . . . . . . . . . .
Balance of taxes paid or accrued at the beginning of the next year. Line 16, columns (a), (b),
and (c) must always equal zero. So, if necessary, enter negative amounts on line 15 of
columns (a), (b), and (c) in amounts sufficient to reduce line 13, columns (a), (b), and (c) to
zero. For the remaining columns, combine lines 8 through 12 . . . . . . . . . . .

Taxes related to:
(a)
Subpart F Income

(b)
Tested Income

(c)
Residual Income

-0-

-0-

-0-

-0-

-0-

(d)
Suspended Taxes

-0Schedule E (Form 5471) (Rev. 12-2021)

Schedule E (Form 5471) (Rev. 12-2021)
Name of foreign corporation

DRAFT AS OF
July 2, 2021
DO NOT FILE

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

Schedule E-1

Page 3
Reference ID number (see instructions)

EIN (if any)

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Taxes Paid, Accrued, or Deemed Paid on Accumulated Earnings and Profits (E&P) of Foreign Corporation (continued)
(e) Taxes related to previously taxed E&P (see instructions)

(i)
Reclassified
section 965(a)
PTEP

1a
b
c
2
3a
b
4
5
6
7
8
9
10
11
12
13
14
15
16

(ii)
Reclassified
section 965(b)
PTEP

(iii)
General
section 959(c)(1)
PTEP

(iv)
Reclassified
section 951A
PTEP

(v)
Reclassified
section 245A(d)
PTEP

(vi)
Section 965(a)
PTEP

(vii)
Section 965(b)
PTEP

(viii)
Section 951A
PTEP

(ix)
Section 245A(d)
PTEP

(x)
Section 951(a)(1)(A)
PTEP

Schedule E (Form 5471) (Rev. 12-2021)