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Instructions for Form 5471

Department of the Treasury
Internal Revenue Service

(Rev. January 2023)

(Use with the December 2022 revision of Form 5471 and separate Schedule Q; the
December 2021 revision of separate Schedules E, G-1, H, I-1, and M; the December
2020 revision of separate Schedules J, P, and R; and the December 2012 revision of
separate Schedule O.)

DRAFT AS OF
March 10, 2023

Information Return of U.S. Persons
With Respect to Certain Foreign Corporations
Section references are to the Internal Revenue
Code unless otherwise noted.

Contents
Future Developments . . . . . . . .
What’s New . . . . . . . . . . . . . .
General Instructions . . . . . . . . .
Purpose of Form . . . . . . . . . . .
Who Must File . . . . . . . . . . . .
When and Where To File . . . . .
Categories of Filers . . . . . . . . .
Additional Filing Requirements . .
Penalties . . . . . . . . . . . . . . . .
Other Reporting Requirements . .
Specific Instructions . . . . . . . . .
Schedule B . . . . . . . . . . . . . .
Schedule C . . . . . . . . . . . . . .
Schedule F . . . . . . . . . . . . . .
Schedule G . . . . . . . . . . . . . .
Schedule I . . . . . . . . . . . . . . .
Instructions for Separate
Schedules . . . . . . . . . . . .
Schedule E . . . . . . . . . . . . . .
Schedule E-1 . . . . . . . . . . . . .
Schedule G-1 . . . . . . . . . . . . .
Schedule H . . . . . . . . . . . . . .
Schedule I-1 . . . . . . . . . . . . .
Schedule J . . . . . . . . . . . . . .
Schedule M . . . . . . . . . . . . . .
Schedule O . . . . . . . . . . . . . .
Schedule P . . . . . . . . . . . . . .
Schedule Q . . . . . . . . . . . . . .
Schedule R . . . . . . . . . . . . . .
Principal Business Activity Codes

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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, the wording of Schedule G,
lines 6a through 6d was amended to
reflect the final regulations under section
250 (T.D. 9901, 85 FR 43042, July 15,
2020, as amended by 85 FR 68249, Oct.
28, 2020; T.D. 9956, 86 FR 52971, Sept.
24, 2021).
Mar 9, 2023

Changes to separate Schedule Q. At
the top of page 1 of the schedule, new line
C requests that, if code 901j is entered on
line A, filers are to enter the country code
for the sanctioned country. This new line is
needed because Form 5471 filers are
required to complete a separate
Schedule Q for each sanctioned country,
and this new line identifies the sanctioned
country with respect to which the schedule
is being completed. This new line is
identical to corresponding lines on Form
1118 (and many separate schedules to
Form 1118) as well as many of the
separate schedules to Form 5471. As a
result of this change, former lines C and D
have been re-lettered as new lines D and
E.
At the top of page 1 of the schedule, if
a Schedule Q filer enters code “TOTAL”
on line A, the filer must also check one or
both boxes on line D (former line C) to
indicate whether the total amounts
reported on Schedule Q include only
foreign source income, or both foreign
source income and U.S. source income.
Note that, with respect to line D, a
Schedule Q filer generally checks either
the foreign source income box or the U.S.
source income box. However, a taxpayer
may check both boxes only in cases
where the taxpayer enters code “TOTAL”
on line A and the total reported on
Schedule Q includes both foreign source
income and U.S. source income.
Lines 1f(1) and 1f(2) are added for
reporting of other types of income not
reportable on lines 1a through 1e. These
new lines have been added to reflect
section 954(c)(1) and Regulations section
1.954-1(c)(1)(iii). As a result of these new
lines, previous lines 1f through 1l have
been re-lettered as lines 1g through 1m.
Columns (xv) and (xvi) are added for
reporting of loss allocations. These new
columns have been added to reflect
Regulations section 1.861-20(e).
There is no longer a need to enter a
total on line 5, column (xiii), Average Asset
Value. As a result, this entry space has
been shaded.

Cat. No. 49959G

Changes to these Instructions. These
instructions have been updated for the
aforementioned changes to Form 5471
and separate Schedule Q. In addition, the
following changes have been made.
The “Categories of Filers,” “Exceptions
From Filing,” and “Additional Filing
Requirements” sections have been
revised as follows:
• The “Categories of Filers” section now
includes a comprehensive summary for
each category of filer that details what
type of person each category of filer is;
definitions that apply specifically for
purposes of each category of filer;
additional information for each category of
filer, including information on required
statements and other filings; and what
exceptions apply specifically to each
category of filer. This section also clarifies
exceptions for certain Category 1 and 5
filers announced in Notice 2018-13,
2018-6 I.R.B. 341, and Rev. Proc.
2019-40, 2019-43 IRB 982.
• The “Exceptions From Filing” section
has been renamed “Additional Filing
Exceptions” and now includes only filing
exceptions that apply to all categories of
filers.
• The additional filings required of
Category 3 filers and the instructions
related to foreign sales corporations have
been removed from the “Additional Filing
Requirements” section and are now
included in the instructions for Category 2,
3, 4, and 5 filers, as applicable.
At the very end of the instructions for
Item 1b(2)—Reference ID Number,
additional clarification has been added to
the note pertaining to the correlation
requirement. Specifically, if the correlation
requirement is applicable with respect to a
tax year, it applies only on Form 5471,
page 1, line 1b(2). It does not apply on any
of the separate schedules for Form 5471.
On all separate schedules for Form 5471,
please enter only the current reference ID
number in the applicable entry space.
In the instructions for Schedule G, later,
in the Schedule G, Line 14 table, question
18 has been revised for clarity. In addition,
new question 22 has been added

pertaining to the U.S. person’s pro rata
share of subpart F income or tested items
from a CFC.
In the instructions for Schedule G-1,
later, if the taxpayer made the election
described in Regulations section
1.482-7(d)(3)(iii)(B) or Notice 2005-99, the
taxpayer is required to attach to Form
5471 the statement described in the
instructions for Schedule G-1, questions
6b and 6c.
For tax year 2022, several changes
have been made to the principal business
activities and codes listed at the end of
these instructions. See the revised list
before entering a six-digit code and the
description of the activity on page 1, items
1f and 1g.

exempt organization return) and file both
by the due date (including extensions) for
that return.

Categories of Filers
Category 1 Filers

In general, a Category 1 filer is a person
who was a U.S. shareholder of a foreign
corporation that was a section 965
specified foreign corporation (SFC) at any
time during the foreign corporation’s tax
year ending with or within the U.S.
shareholder’s tax year, and who owned
that stock on the last day in that year in
which the foreign corporation was a
section 965 SFC, taking into account the
regulations under section 965. There are
three different types of Category 1 filers,
each described below: Category 1a filers,
Category 1b filers, and Category 1c filers.

Category 1b Filer
A Category 1b filer is a person who is an
unrelated section 958(a) U.S. shareholder
(defined below) of a foreign-controlled
section 965 SFC. This type of Category 1
filer extends the relief for certain Category
5 filers announced in section 8.02 of Rev.
Proc. 2019-40, 2019-43 IRB 982 to
similarly situated Category 1 filers.

DRAFT AS OF
March 10, 2023

General Instructions
Purpose of Form

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.

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.
Note. When a schedule is required but all
amounts are zero, the schedule should
still be filed with one or more zero
amounts. For schedules that are
completed by category (that is,
Schedule E, I-1, J, P, and Q), inclusion of
a single instance of that schedule for any
separate category will meet the
requirement.
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 (that is, you are described
in Categories 4 and 5a), complete all six
pages of Form 5471 and separate
Schedules E, G-1, H, I-1, J, M, P, Q, and
R.
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

Except as otherwise provided in the
instructions for each type of Category 1
filer below, the following definitions apply
for purposes of Category 1:
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
section 958(a) and (b)) 10% or more of the
total combined voting power or value of
shares of all classes of stock of a section
965 SFC. See section 951(b).
U.S. person. For purposes of Category 1,
a U.S. person is:
1. A citizen or resident of the United
States;
2. A domestic partnership;
3. A domestic corporation; or
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.
Section 965 SFC. For purposes of
Category 1, a section 965 SFC is:
1. A CFC (see Category 5 Filers, later,
for definition); or
2. Any foreign corporation with
respect to which one or more domestic
corporations is a U.S. shareholder.
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 a section 965 SFC.
See section 965 and the regulations
thereunder for exceptions.

Category 1a Filer
A Category 1a filer is a Category 1 filer
that is not a Category 1b or 1c filer.

-2-

Unrelated section 958(a) U.S. shareholder. For purposes of Category 1b, an
unrelated section 958(a) U.S. shareholder
is a U.S. shareholder with respect to a
foreign-controlled section 965 SFC who:
1. Owns, within the meaning of
section 958(a), stock of a
foreign-controlled section 965 SFC; and
2. Is not related (using principles of
section 954(d)(3)) to the foreign-controlled
section 965 SFC.
Foreign-controlled section 965 SFC.
For purposes of Category 1b, a
foreign-controlled section 965 SFC is a
foreign corporation that is a section 965
SFC that would not be a section 965 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 that is owned
by a foreign person.

Category 1c Filer
A Category 1c filer is a person who is a
Related constructive U.S. shareholder. of
a foreign-controlled section 965 SFC. This
type of Category 1 filer extends the relief
for certain Category 5 filers announced in
section 8.03 of Rev. Proc. 2019-40,
2019-43 IRB 982, to similarly situated
Category 1 filers.
Related constructive U.S. shareholder.
For purposes of Category 1c, a related
constructive U.S. shareholder is a U.S.
shareholder with respect to a
foreign-controlled section 965 SFC who:
1. Does not own, within the meaning
of section 958(a), stock of the
foreign-controlled section 965 SFC; and
2. Is related (using principles of
section 954(d)(3)) to the foreign-controlled
section 965 SFC.
Foreign-controlled section 965 SFC.
For purposes of Category 1c, the term
foreign-controlled section 965 SFC has
the same meaning as provided in
Category 1b Filers, above.

Additional Information for
Category 1 Filers
When Category 1 reporting is no longer required. A Category 1 filer must
continue to file all information required as
long as:
Instructions for Form 5471 (Rev. 01-2023)

• The section 965 SFC (or
foreign-controlled section 965 SFC) has
accumulated E&P related to section 965
that is reportable on Schedule J (Form
5471); or
• The Category 1 filer has previously
taxed E&P related to section 965 that is
reportable on Schedule P (Form 5471).

3. The Category 1 filer is not related,
using principles of section 954(d)(3), to
the foreign-controlled section 965 SFC.
This exception implements the relief for
certain Category 5 filers announced in
section 8.04 of Rev. Proc. 2019-40,
2019-43 IRB 982, and extends it to
Category 1 filers.

Category 2 Filers - Exceptions
From Filing

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 information required of the Category
2 filer.

DRAFT AS OF
March 10, 2023

Category 1 Filers - Exceptions
From Filing

Certain constructive owners.
• A Category 1 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The Category 1 filer does not own a
direct interest in the foreign corporation;
2. The Category 1 filer 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
Category 1 filer constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the information
required of the Category 1 filer.

• A Category 1 filer does not have to file

Form 5471 if it:
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.
No statement is required to be attached
to the tax return of a Category 1 filer
claiming either constructive ownership
exception. See Regulations section
1.6038-2(j)(2) and (3) and (l) for additional
information.
No section 958(a) U.S. shareholder. A
Category 1 filer does not have to file Form
5471 if no U.S. shareholder (including the
Category 1 filer) owns, within the meaning
of section 958(a), stock in the section 965
SFC on the last day in the year of the
foreign corporation in which it was a
section 965 SFC and the SFC is a
foreign-controlled section 965 SFC. This
exception extends the relief for Category 5
filers announced in section 5.02 of Notice
2018-13, 2018-6 IRB 341, to similarly
situated Category 1 filers.
Unrelated constructive U.S. shareholder. A Category 1 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The foreign corporation is a
foreign-controlled section 965 SFC;
2. The Category 1 filer is a U.S.
shareholder that does not own stock,
within the meaning of section 958(a), in
the foreign-controlled section 965 SFC;
and
Instructions for Form 5471 (Rev. 01-2023)

Other filing exceptions. Certain other
filing exceptions apply to all categories of
filers. See Additional Filing Exceptions,
later.

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
has acquired (in one or more
transactions):
1. Stock that meets the 10% stock
ownership requirement 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(c) and (f)(1) for more details.

10% stock ownership requirement. For
purposes of Category 2, 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.
See Regulations section 1.6046-1(i) for
additional information.
U.S. person. For purposes of Category 2,
a U.S. person is:
1. A citizen or resident of the United
States;
2. A domestic partnership;
3. A domestic corporation; or
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.

Additional Information for
Category 2 Filers
Foreign sales corporations (FSCs).
Category 2 filers who are shareholders,
officers, and directors of an 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.
-3-

Other filing exceptions. Certain other
filing exceptions apply to all categories of
filers. See Additional Filing Exceptions,
below.

Category 3 Filer

This category includes:
1. A U.S. person 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 with respect to the
foreign corporation;
2. 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;
3. A person who is treated as a U.S.
shareholder under section 953(c) with
respect to the foreign corporation;
4. A person who becomes a U.S.
person while meeting the 10% stock
ownership requirement with respect to the
foreign corporation; or
5. 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.

10% stock ownership requirement. For
purposes of 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.
See Regulations section 1.6046-1(i) for
additional information.

U.S. person. For purposes of Category 3,
a U.S. person is:
1. A citizen or resident of the United
States;
2. A domestic partnership;
3. A domestic corporation; or
4. An estate or trust that is not a
foreign estate or trust as defined in section
7701(a)(31).

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).

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 repeal); and
4. Any deductions that are
apportioned or allocated to the nonexempt
foreign trade income described above.

• Category 4 filers who are shareholders
of an FSC 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.

DRAFT AS OF
March 10, 2023

See Regulations section 1.6046-1(f)(3)
for exceptions.

Additional Information for
Category 3 Filers

Statement required. Category 3 filers
must attach a statement that includes:
1. The amount and type of any
indebtedness the foreign corporation has
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 suscriber to the foreign
corporation's stock.
Foreign sales corporations (FSCs).
Category 3 filers who are shareholders,
officers, and directors of an 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 3 Filers - Exception
From Filing

A Category 3 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The Category 3 filer does not own a
direct interest in the foreign corporation;
2. The Category 3 filer 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
Category 3 filer constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the information
required of the Category 3 filer.
No statement is required to be attached
to tax returns for persons claiming this
constructive ownership exception.
Other filing exceptions. Certain other
filing exceptions apply to all categories of
filers. See Additional Filing Exceptions,
below.

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.

See Regulations section 1.6038-2(d)
for exceptions.
Control. For purposes of Category 4, 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.
For purposes of Category 4, 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” for
purposes of Category 4, see section
6038(e)(2) and Regulations sections
1.6038-2(b) and (c).

Additional Information for
Category 4 Filers

Category 4 Filers - Exceptions
From Filing
Certain constructive owners.
• A Category 4 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The Category 4 filer does not own a
direct interest in the foreign corporation;
2. The Category 4 filer 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
Category 4 filer constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the information
required of the Category 4 filer.

• A Category 4 filer does not have to file
Form 5471 if it:
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.
No statement is required to be attached
to the tax return of a Category 4 filer
claiming either constructive ownership
exception. See Regulations section
1.6038-2(j)(2) and (3) and (l) for additional
information.

Foreign sales corporations (FSCs).
• Category 4 filers who are shareholders
of an FSC are not subject to the subpart F
rules with respect to the FSC for:
1. Exempt foreign trade income;
2. Deductions that are apportioned or
allocated to exempt foreign trade income;

FSCs. Category 4 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 are
required to file Form 5471 for an FSC,
regardless of whether it has filed Form
1120-FSC, if the filer has inclusions with

-4-

Instructions for Form 5471 (Rev. 01-2023)

respect to the FSC under section 951(a)
(as described above).
Other filing exceptions. Certain other
filing exceptions apply to all categories of
filers. See Additional Filing Exceptions,
below.

Category 5 Filers

CFC also includes a foreign corporation
that is described in section 957(b); and for
purposes only of taking into account
related person insurance income, a CFC
includes a foreign corporation described in
section 953(c)(1)(B).

Category 5a Filer

CFC has the same meaning as defined in
Category 5b filers, above.

Additional Information for
Category 5 Filers
Foreign sales corporations (FSCs)
• Category 5 filers who are shareholders
of an FSC are not subject to the subpart F
rules with respect to the FSC for:
1. Exempt foreign trade income;
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 repeal); and
4. Any deductions that are
apportioned or allocated to the nonexempt
foreign trade income described above.

DRAFT AS OF
March 10, 2023

In general, a Category 5 filer is a person
who was a U.S. shareholder that owned
stock in a foreign corporation that was a
CFC at any time during the foreign
corporation’s tax year ending with or within
the U.S. shareholder’s tax year, and who
owned that stock on the last day in that
year in which the foreign corporation was
a CFC. There are three different types of
Category 5 filers, each described below:
Category 5a filers, Category 5b filers, and
Category 5c filers.
Except as otherwise provided in the
instructions for each type of Category 5
filer below, the following definitions apply
for purposes of Category 5:

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 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)), unless the
foreign corporation has an effective
section 953(c)(3)(C) election in place for
the tax year.
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; or
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.
In general, a CFC is a foreign
corporation that has U.S. shareholders
that own (directly, indirectly, or
constructively, within the meaning of
section 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.
For purposes only of taking into
account income described in section
953(a) (relating to insurance income), a
Instructions for Form 5471 (Rev. 01-2023)

A Category 5a filer is a Category 5 filer
that is not a Category 5b or 5c filer.

Category 5b Filer

A person is a Category 5b filer if they are
an unrelated section 958(a) U.S.
shareholder of a foreign-controlled CFC.
This type of Category 5 filer implements
the relief for certain Category 5 filers
announced in section 8.02 of Rev. Proc.
2019-40, 2019-43 IRB 982.

Unrelated section 958(a) U.S. shareholder. For purposes of Category 5b, an
unrelated section 958(a) U.S. shareholder
is a U.S. shareholder with respect to a
foreign-controlled CFC who:
1. Owns, within the meaning of
section 958(a), stock of a
foreign-controlled CFC; and
2. Is not related (using principles of
section 954(d)(3)) to the foreign-controlled
CFC.
Foreign-controlled CFC. For purposes
of Category 5b, a foreign-controlled CFC
is a foreign corporation that is a CFC that
would not be a CFC 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 that is owned by a foreign
person.

Category 5c Filer
A person is a Category 5c filer if they are a
related constructive U.S. shareholder of a
foreign-controlled CFC. This type of
Category 5 filer implements the relief for
certain Category 5 filers announced in
section 8.03 of Rev. Proc. 2019-40,
2019-43 IRB 982.
Related constructive U.S. shareholder.
For purposes of Category 5c, a related
constructive U.S. shareholder is a U.S.
shareholder with respect to a
foreign-controlled CFC who:
1. Does not own, within the meaning
of section 958(a), stock of the
foreign-controlled CFC; and
2. Is related (using principles of
section 954(d)(3)) to the foreign-controlled
CFC.
Foreign-controlled CFC. For purposes
of Category 5c, the term foreign-controlled
-5-

• Category 5 filers who are shareholders
of an FSC 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 5 Filers - Exceptions
From Filing
Certain constructive owners
• A Category 5 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The Category 5 filer does not own a
direct interest in the foreign corporation;
2. The Category 5 filer 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
Category 5 filer constructively owns an
interest in the foreign corporation files
Form 5471 to report all of the information
required of the Category 5 filer.

• A Category 5 filer does not have to file
Form 5471 if it:
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.
No statement is required to be attached
to the tax return of a Category 5 filer
claiming either constructive ownership

exception. See Regulations section
1.6038-2(j)(2) and (3) and (l) for additional
information.
No section 958(a) U.S. shareholder. A
Category 5 filer does not have to file Form
5471 if no U.S. shareholder (including the
Category 5 filer) owns, within the meaning
of section 958(a), stock in the CFC on the
last day in the year of the foreign
corporation in which it was a CFC and the
CFC is a foreign-controlled CFC. See
section 5.02 of Notice 2018-13, 2018-6
IRB 341 for additional information.

Category 5b filer (but not a Category 5c
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 H. All
persons identified in Item H must attach a
statement to their income tax return that
includes the information described in the
instructions for Item H. See Regulations
section 1.6038-2(j)(1) and (3) for
additional information.

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).

DRAFT AS OF
March 10, 2023

Unrelated constructive U.S. shareholder. A Category 5 filer does not have to file
Form 5471 if all of the following conditions
are met:
1. The foreign corporation is a
foreign-controlled CFC;
2. The filer is a U.S. shareholder that
does not own stock, within the meaning of
section 958(a), in the foreign-controlled
CFC; and
3. The filer is not related, using
principles of section 954(d)(3), to the
foreign-controlled CFC.
See section 8.04 of Rev. Proc.
2019-40, 2019-43 IRB 982 for additional
information.
FSCs. Category 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 are
required to file Form 5471 for an FSC,
regardless of whether it has filed Form
1120-FSC, if the filer has inclusions with
respect to the FSC under section 951(a)
(as described above).
Other filing exceptions. Certain other
filing exceptions apply to all categories of
filers. See Additional Filing Exceptions,
below.

Additional Filing
Exceptions
Multiple filers of same information.
With respect to any category of filer, 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 filer or another Category 5
filer; similarly, a U.S. person described in
Category 5b may file a joint Form 5471
with a Category 4 or 5a filer or another

Additional Filing
Requirements

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:

Domestic corporations. Shareholders
are not required to file Form 5471 for a

Filing Requirements for Categories of Filers
Table of Required Information
Required Information*

Category of Filer
1a

1b

1c

2

3

4

5a

5b

5c

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

1

Schedule E-1 (included with separate
Schedule E)

1

2

1

2

1

Schedule G
Separate Schedule G-1
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
Separate Schedule Q
Separate Schedule R
*See also Additional Filing Requirements.
1. 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 section 965 SFC or foreign-controlled CFC under section 960 for the
filer’s tax year. See Rev. Proc. 2019-40 for more details.
2. 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.

-6-

Instructions for Form 5471 (Rev. 01-2023)

• 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;
• A U.S. shareholder that files a section
338 election on behalf of a foreign
purchasing corporation that is a controlled
foreign corporation pursuant to
Regulations section 1.338-2(e)(3) must
attach a copy of Form 8023, Elections
Under Section 338 for Corporations
Making Qualified Stock Purchases, to the
Form 5471 filed with respect to the
purchasing corporation for the taxable
year that includes the acquisition date
(see the Instructions for Form 8023 for
details).

disclose a reportable transaction under
section 6011 and fails to properly
complete and file Form 8886. Penalties
may also 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, may also apply. See the
Instructions for Form 8886 for details on
these and other penalties.

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. See section 6679.

DRAFT AS OF
March 10, 2023

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
Instructions for Form 5471 (Rev. 01-2023)

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)
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 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.
See Regulations sections 1.6038-1(j) and
1.6038-2(k)(3) for alleviation of this
penalty in certain cases.
-7-

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 them 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 must generally 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.

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/Pub. 1167.

Dormant Foreign Corporations

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.

DRAFT AS OF
March 10, 2023

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
108.8593 Japanese Yen to one U.S. dollar
or (0.009184) U.S. dollar to one Japanese
Yen. The foreign corporation divides
30,255,400 Yen by 108.8593 to determine
the U.S. dollar amount to enter in column
(l) of Schedule E, Part I, Section 1, line 1.
Line 1 of Schedule E, Part I, Section 1, is
completed in relevant part as follows.
• Enter the name of the payor entity in
column (a).
• Enter the payor entity’s EIN or
reference ID number in column (b).
• Enter "JA" in column (d).
• Enter “JPY” in column (i).
• Enter "30,255,400 Yen" in column (j).
• Enter "108.8593" in column (k).
• Enter "277,931" in column (l).

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

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 are generally 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
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 Regulations
section 1.362-4(d)(3).

!

Do not attach the statement
described above to Form 5471.

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) is generally 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. 2006-45, 2006-45 I.R.B.
851, available at IRS.gov/irb/
2006-45_IRB#2006-45, as modified by
Rev. Proc. 2007-64, 2007-42 I.R.B. 818,
available at IRS.gov/irb/
2007-42_IRB#RP-2007-64.

CAUTION

-8-

Instructions for Form 5471 (Rev. 01-2023)

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.

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 17. For more information, see
the Instructions for Form 8938, generally,
and in particular, Duplicative Reporting
and the specific instructions for Part IV,
Excepted Specified Foreign Financial
Assets.

5471 may be determined by the unrelated
section 958(a) U.S. shareholder or the
unrelated constructive U.S. shareholder,
as applicable, on the basis of alternative
information (without adjustments other
than those described in sections 3.01(b)
and 3.10 of the revenue procedure) with
respect to the SFC. See section 3 of Rev.
Proc. 2019-40 for definitions of terms.

DRAFT AS OF
March 10, 2023

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

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.

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. See
Categories of Filers, earlier.
Note. If you satisfy the requirements of
both Category 4 and Category 5a filers,
only check the box for Category 4 and
leave the box for Category 5a blank.

Item C—Percentage of Voting
Stock Owned

Enter the total percentage of the foreign
corporation's voting power 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 example, if a reorganization
has occurred, a complete liquidation has

Instructions for Form 5471 (Rev. 01-2023)

Item F—Alternative Information
Under Rev. Proc. 2019-40

Check the box on line F if Form 5471 has
been completed using alternative
information (as defined in section 3.01 of
Rev. Proc. 2019-40).

Section 5 of Rev. Proc. 2019-40
provides a safe harbor for determining
certain items, including taxable income
and E&P, of certain CFCs based on
alternative information. Specifically, in the
case of a foreign-controlled CFC with
respect to which there is no related
section 958(a) U.S. shareholder, if
information satisfying the requirements of
Regulations section 1.952-2(a), (b), and
(c)(2) and section 964 and the regulations
thereunder is not readily available to an
unrelated section 958(a) U.S. shareholder
or an unrelated constructive U.S.
shareholder with respect to the
foreign-controlled CFC, an amount
reported on a Form 5471 may be
determined by the unrelated section
958(a) U.S. shareholder or the unrelated
constructive U.S. shareholder, as
applicable, on the basis of alternative
information (without adjustments other
than those described in section 3.01(b)
and 3.10 of the revenue procedure) with
respect to the foreign-controlled CFC. See
section 3 of Rev. Proc. 2019-40 for
definitions of terms.
Section 6 of Rev. Proc. 2019-40
provides a safe harbor for determining
certain items of certain SFCs based on
alternative information. Specifically, in the
case of an SFC, other than either a
foreign-controlled CFC with respect to
which there is no related section 958(a)
U.S. shareholder or a U.S. controlled
CFC, if information satisfying the
requirements of section 964 and the
regulations thereunder is not readily
available to an unrelated section 958(a)
U.S. shareholder or an unrelated
constructive U.S. shareholder with respect
to the SFC, an amount reported on a Form
-9-

Item G—Alternative Information
Code

If the box on line F is checked, enter the
applicable code from the list provided
below.

Audited separate-entity financial statements of
the foreign corporation that are prepared in
01
accordance with U.S. generally accepted
accounting principles (U.S. GAAP).
02

Audited separate-entity financial statements of
the foreign corporation that are prepared on
the basis of international financial reporting
standards (IFRS).

Audited separate-entity financial statements of
the foreign corporation that are prepared on
the basis of the generally accepted accounting
03
principles of the jurisdiction in which the foreign
corporation is organized (“local-country
GAAP”).
Unaudited separate-entity financial statements
04 of the foreign corporation that are prepared in
accordance with U.S. GAAP.
Unaudited separate-entity financial statements
05 of the foreign corporation that are prepared on
the basis of IFRS.
Unaudited separate-entity financial statements
06 of the foreign corporation that are prepared on
the basis of local-country GAAP.
07

Separate-entity records used by the foreign
corporation for tax reporting.

Separate-entity records used by the foreign
08 corporation for internal management controls
or regulatory or other similar purposes.

Information described in a code listed
above qualifies as alternative information
only if information described in any
preceding code is not “readily available”
(as defined in section 3.04 of Rev. Proc.
2019-40). For example, information
described in code “03” above qualifies as
alternative information only if information
described in code “01” and “02” is not
readily available.
For more information, see Rev. Proc.
2019-40.

Item H—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, earlier. This includes completing
Item H on page 1 of the form. When
completing Item H with respect to
members of a consolidated group, identify
only the direct owners in Item H
(constructive owners are not required to
be listed).

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.

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.

DRAFT AS OF
March 10, 2023

A separate Schedule I must be filed for
each person described in Category 4, 5a,
or 5b. For each Category 4, 5a, or 5b 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 H. Except for members of
the filer's consolidated return group, all
persons identified in Item H 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 H 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 H
must complete a separate
CAUTION Schedule P (Form 5471) if the
person is a U.S. shareholder described in
Category 1a, 1b, 4, 5a, or 5b. 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

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 should
also 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. Also, if a U.S.
shareholder is required to file Schedule A
(Form 8992) or Schedule B (Form 8992)
with respect to the CFC, the reference ID
number on Form 5471 and the reference
ID number used on Schedule A (Form
8992) or Schedule B (Form 8992) for that
CFC must be the same.

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.
Taxpayers no longer have the option of
entering “FOREIGNUS” or “APPLIED
FOR” in a column that requests an EIN or
reference ID number with respect to a
foreign entity. Instead, if the foreign entity
does not have an EIN, the taxpayer must
enter a reference ID number that uniquely
identifies the foreign entity.
There are some situations that warrant
correlation of a new reference ID number
-10-

Note. This correlation requirement
applies only to the first year the new
reference ID number is used and it applies
only on Form 5471, page 1, line 1b(2). On
all separate schedules for Form 5471,
please enter only the current reference ID
number in the applicable entry space.

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.
For tax year 2022, several
changes have been made to the
CAUTION principal business activities and
codes listed at the end of these
instructions. See the revised list before
entering a six-digit code and the
description of the activity on page 1, items
1f and 1g.

!

Item 1h—Functional Currency

The foreign corporation's functional
currency is determined under section 985.
Enter the applicable three-character
alphabet code for the foreign corporation's
functional currency using the ISO 4217
standard. These codes are available at
www.six-group.com/en/products-services/
Instructions for Form 5471 (Rev. 01-2023)

financial-information/datastandards.html#scrollTo=currency-codes.
Click on List One (XLS).
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.

Category 4 filers should list all direct
owners of the CFC. Category 1a, 3, and
5a filers should list all direct owners of the
SFC or CFC through which such filer
indirectly owns the SFC or CFC as
described in section 958(a)(2). Category
1c and 5c filers should list all direct
owners of the SFC or CFC from which
such filer is attributed ownership in the
SFC or CFC as described in section
958(b). If the filer is a direct owner, include
the filer's direct ownership.

and deferred income tax expense (benefit)
on line 21b.

Schedule C

Lines 23 and 24. Enter amounts defined
in ASC 220 (Income Statement Reporting Comprehensive Income).

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.

DRAFT AS OF
March 10, 2023

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.

Schedule B

Note. If any person (including the filer) is
both a U.S. shareholder and a direct
shareholder of the foreign corporation,
that person’s information should be
provided in both Schedule B, Part I and
Part II.

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 of
the total combined voting power of all
classes of stock entitled to vote of the
foreign corporation, or 10% or more of the
total value of shares of all classes of stock
of the foreign corporation.
A person that is both a category 3 and
category 5 filer because it is treated as a
U.S. shareholder under section 953(c)(1)
(A) with respect to the foreign corporation
must complete Schedule B, Part 1 for U.S.
persons that owned (on the last day of the
foreign corporation’s taxable year),
directly or indirectly through foreign
entities, any 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 1a, 1c, 3, 4, 5a, and 5c filers
must complete Part II.
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. If
there is more than one regarded entity
owner, use separate lines for each, listing
each regarded entity owner in column (a)
and reporting the information requested in
columns (b), (c), and (d) for each such
regarded entity owner.
Instructions for Form 5471 (Rev. 01-2023)

Report all information in the foreign
corporation's functional currency in
accordance with U.S. GAAP and translate
using U.S. GAAP translation principles.

If the foreign corporation uses the
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
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 220
(Income Statement), Subtopic 220-20
(Unusual or Infrequently Occurring 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
may also 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
-11-

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 U.S. dollars.
Generally, the foreign corporation's
balance sheet is prepared in functional
currency and translated to U.S. dollars
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 1b and 5b filers are not
required to file Schedule G for
foreign-controlled section 965 SFCs and
foreign-controlled CFCs, respectively.

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.

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)).

Question 3

If the foreign corporation paid or accrued
any interest or royalty (including in the
case of a foreign corporation that is a
partner in a partnership, the foreign
corporation’s allocable share of interest or
royalty paid by the partnership) for which a
deduction is disallowed under section
267A, check “Yes” for question 5a and
enter the total amount for which a
deduction is not allowed on line 5b. The
amount reported on line 5b should not
include disallowed deductions attributable
to interest or royalty paid or accrued by a
U.S. taxable branch of the foreign
corporation; such amounts are reported
on Form 1120-F.

The term “base erosion tax benefit”
generally means any U.S. deduction that
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.

instructions for information on the section
250 deduction. If no deduction is being
claimed, check the “No” box on line 6a
and go to line 7.

Question 9a

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 9b.

DRAFT AS OF
March 10, 2023

Check the “Yes” box if the foreign
corporation is the tax owner of an FDE or
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, 5a, or 5c 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 1b, 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 or
FB, country under whose laws the FDE or
FB was organized, and EIN (if any) of the
FDE or FB.

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

Questions 5a and 5b

Interest or royalty paid or accrued by a
foreign corporation (including through a
partnership) is subject to section 267A,
provided in general that the foreign
corporation is a CFC (and there are one or
more U.S. tax residents that own directly
or indirectly at least 10% of the stock of
the CFC). Section 267A disallows a
deduction for certain interest or royalty
paid or accrued pursuant to a hybrid
arrangement, to the extent that, under the
foreign tax law, there is not a
corresponding income inclusion (including
long-term deferral). For more detailed
instructions, see the instructions for Form
1120, Schedule K, Question 21.

Question 6

Check the “Yes” box on line 6a if the filer 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

-12-

Question 9b

Enter in functional currency 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 should also
be entered on Schedule H, Current
Earnings and Profits, as a net subtraction
on line 2i.

Question 10

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 10
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 14

Check the "Yes" box on line 14 if you
answer “Yes” to any of the 22 questions in
the Schedule G, line 14 table below. If
"Yes," enter the Corresponding Code(s)
from the table in the entry space provided
on line 14 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. 01-2023)

Form 5471
Schedule G, Line 14
Question

See Worksheet A in the If “Yes,”
Code
Schedule I instructions Corresponding Description
Code to enter
on
Schedule G,
line 14

If “Yes,” content of
statement to be
attached to Form 5471

DRAFT AS OF
March 10, 2023

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 $1 million?

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. 01-2023)

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

-13-

ARR

Business needs Amount excluded

Amount excluded

Form 5471, Schedule G, Line 14, continued
Question

See Worksheet A in the If “Yes,”
Code
Schedule I instructions Corresponding Description
Code to enter
on
Schedule G,
line 14

If “Yes,” content of
statement to be
attached to Form
5471

DRAFT AS OF
March 10, 2023

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 are
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 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, a 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, a 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

-14-

Instructions for Form 5471 (Rev. 01-2023)

Form 5471, Schedule G, Line 14, continued
Question

See Worksheet A in the If “Yes,”
Code
Schedule I instructions Corresponding Description
Code to enter
on
Schedule G,
line 14

If “Yes,” content of
statement to be
attached to Form
5471

DRAFT AS OF
March 10, 2023

17

During the tax year, did the CFC derive income (either directly or
through a branch or similar establishment, for example, a
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

During the tax year, did the CFC derive income through the conduct
of any manufacturing or sales activities (including mere passage of
title) through a branch or similar establishment (such as a
disregarded entity of the CFC) that would have been foreign base
company sales income described in section 954(d) except that either
(1) the branch or other similar establishment was not treated as a
wholly owned subsidiary separate from the CFC under section 954(d)
(2) and the regulations or (2) the income is not foreign base company
sales income after the application of Regulations section 1.954-3(b)
(2)(ii)(e)?

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 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?

In other words, is line 36
of Worksheet A greater
than line 37c?

EP

Earnings &
profits limitation

Excess of line 36 over
line 37c

22

In determining the pro rata share of subpart F income or tested items In other words, is line 58
of the U.S. person filing this return, was the amount of distributions
of Worksheet A greater
by the CFC during the tax year and described in section 951(a)(2)(B) than zero?
greater than zero?

XX

Other

The amounts from
lines 58 and 59 of
Worksheet A.

23

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

Question 15

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 16

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
Instructions for Form 5471 (Rev. 01-2023)

current tax year. If “Yes,” enter the amount
from the prior year Form 8990, line 31.

Question 17a

Check the “Yes” box on line 17a if there
was an extraordinary reduction with
respect to any controlling section 245A
shareholder of the foreign corporation, as
defined in Regulations section 1.245A-5(i)
(2), during the tax year of the foreign
corporation. See Regulations section
1.245A-5(e)(2)(i) for the definition of
extraordinary reduction.

Question 17b

If the answer to the question on line 17a
was “Yes,” complete the question on
line 17b. Check the “Yes” box on line 17b
if any controlling section 245A shareholder
(as defined in Regulations section
1.245A-5(i)(2)) made an election to close
the tax year of the foreign corporation
such that no amount is treated as an
-15-

extraordinary reduction amount or tiered
extraordinary reduction amount as to any
U.S. shareholder of the foreign
corporation. See Regulations section
1.245A-5(e)(3)(i) for further guidance
regarding the election to close the tax
year. If the “Yes” box on line 17b has been
checked and the U.S. shareholder filing
the Form 5471 is a controlling section
245A shareholder of the foreign
corporation, the U.S. shareholder filing
this Form 5471 must attach an Elective
Section 245A Year-Closing Statement
pursuant to Regulations section
1.245A-5(e)(3)(i)(C) containing the
information required under Regulations
section 1.245A-5(e)(3)(i)(D).

Question 18

Check the “Yes” box if during the tax year
the reporting corporation had any loans to
or from the related party to which the safe
haven rate rules of Regulations section

1.482-2(a)(2)(iii)(B) are applicable, and for
which the reporting corporation used a
rate of interest within the safe-haven range
of Regulations section 1.482-2(a)(2)(iii)(B)
(1) (100% to 130% of the AFR for the
relevant term).

Question 19a

Note. Complete lines 19a and 19b only if
the filer is a domestic corporation. In
completing these lines, do not account for
debt instruments that were issued, or
distributions or acquisitions that occurred,
before April 5, 2016. See Regulations
section 1.385-3(g)(3) and 1.385-3(b)(3)
(viii).
Check “Yes” if, during the tax year, the
filer engaged in at least one of the
transactions described in Regulations
section 1.385-3(b)(2). Also check “Yes” if,
taking into account issuances,
distributions, and acquisitions during the
tax year and previous tax years, the filer
had issued a debt instrument to the
foreign corporation during a period
described in Regulations section
1.385-3(b)(3)(iii), which addresses certain
issuances of debt instruments to related
parties within 36 months before or after
certain distributions or acquisitions by the
issuer. Otherwise, check “No.” Apply
Regulations section 1.385-3(b)(3)(iii)(E) to
determine when a debt instrument is
treated as issued for purposes of
Regulations section 1.385-3(b)(3)(iii).
Debt that the filer treats as stock
pursuant to Regulations section 1.385-3
still should be included when completing
line 19a.

Line 1c

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.

Enter the subpart F income inclusion
attributable to tiered extraordinary
disposition amounts resulting from
distributions from an extraordinary
disposition account of the shareholder
filing this Form 5471 and received by the
foreign corporation. See Regulations
section 1.245A-5(d) for further guidance
on tiered extraordinary disposition
amounts.

DRAFT AS OF
March 10, 2023

Question 19b

Provide the total amount of the
transactions described in Regulations
section 1.385-3(b)(2) (as measured by the
fair market value of the distribution or, as
the case may be, the property exchanged
for the debt instrument), and of the
distributions and/or acquisitions described
in Regulations section 1.385-3(b)(3)(i) (as
measured by the fair market value of the
property distributed and/or acquired).
Provide the total amount (as measured
by issue price in the case of an instrument
treated as stock upon issuance, or
adjusted issue price in the case of an
instrument deemed exchanged for stock)
of the debt instrument issuances
addressed by line 19a. See Regulations
section 1.385-1(d)(1) and 1.385-3(d). The
adjusted issue price of a debt instrument
is the issue price increased by the amount
of original issue discount previously
includible in gross income of any holder
and decreased by payments other than
payments of stated interest. See section
1272(a)(4) and Regulations section
1.1275-1(b)(1).

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 the specific instructions for
Item F—Alternative Information Under
Rev. Proc. 2019-40, earlier, for more
details.

Note. A separate Schedule I must be
filed by or for each Category 4, 5a, or 5b
U.S. shareholder of the foreign
corporation with respect to which reporting
is furnished on this Form 5471.

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).
Note. 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).

Line 1a

Corporate U.S. shareholders should enter
the foreign-source portion of any subpart F
income inclusions attributable to the sale
or exchange by a CFC of stock of another
foreign corporation that is eligible for the
section 245A dividends received
deduction pursuant to section 964(e)(4).
Include the amount, if any, that is not
eligible for the section 245A dividends
received deduction pursuant to section
964(e)(4) on line 1e. Noncorporate U.S.
shareholders should leave line 1a blank.

Line 1b

Enter the amount of the U.S. shareholder’s
subpart F income inclusion attributable to
tiered hybrid dividends received by the
CFC. In general, a dividend received by a
CFC from another CFC is a tiered hybrid
dividend to the extent of the sum of the
receiving CFC's hybrid deduction
accounts with respect to shares of stock of
the CFC that pays the dividend. As to a
domestic corporation that is a U.S.
shareholder with respect to both CFCs,
the tiered hybrid dividend is treated as
subpart F income of the receiving CFC,
and the U.S. shareholder must include in
its gross income its pro rata share of the
tiered hybrid dividend. See section
245A(e)(2) and Regulations section
1.245A(e)-1(c) for additional information
about tiered hybrid dividends.
-16-

Line 1d

Enter the subpart F income inclusion
attributable to tiered extraordinary
reduction amounts resulting from
extraordinary reductions. See Regulations
section 1.245A-5(f) for further guidance on
tiered extraordinary reduction amounts.

Lines 1e Through 1h

Enter on lines 1e through 1h the amounts
from Worksheet A, lines 63, 65, 67, and
69, respectively. However, corporate U.S.
shareholders should report on line 1e the
amount from Worksheet A, line 63, less
the amount, if any, reported on line 1a.
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 1e through 1h. Do not include any
income includible on Form 5471,
Schedule I, lines 1a through 1d, 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 1e
through 1h 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 tax 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 1h (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.
Instructions for Form 5471 (Rev. 01-2023)

Line 2

Report on line 2 earnings invested in U.S.
property (Worksheet B).

Line 3

Reserved for future use.

Line 4

Note. The corporate U.S. shareholder
should include the line 5b amount on Form
1120, Schedule C, line 14, column (a), or
the comparable line of other corporate
income tax returns.

Line 5c

Enter the amount of the dividends
received by the shareholder from the
foreign corporation that is an extraordinary
reduction amount. See Regulations
section 1.245A-5(e) for rules for
calculating an extraordinary reduction
amount.

group. See Regulations section
1.986(c)-1(c).
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),
line 8z (other income), or on the
comparable line of other noncorporate tax
returns.

DRAFT AS OF
March 10, 2023

Enter the factoring income (as defined in
section 864(d)(1)) if no subpart F income
is reported on line 1a of Worksheet A,
because of the operation of the de minimis
rule (see lines 1a and 10 of Worksheet A
and the related instructions under Line 1a
and Line 10, De minimis rule), later.

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 1h, 2,
and 4. For a corporate shareholder, enter
the result from line 1a on Form 1120,
Schedule C, line 16a; enter the result from
line 1b on Form 1120, Schedule C,
line 16b; and enter the remaining lines 1c
through 1h, 2, and 4 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), line 8n (other income section 951(a) inclusion), or on the
comparable line of other noncorporate tax
returns.

Line 5a

Enter the amount of dividends received by
the shareholder from the foreign
corporation that is eligible for a deduction
under section 245A. This amount does not
include the amount of dividends that are
not eligible for a deduction under section
245A and are instead entered on lines 5b,
5c, and 5d. See section 245A for guidance
on computing the amount of a dividend
eligible for a deduction.
Note. The corporate U.S. shareholder
should include the line 5a amount on Form
1120, Schedule C, line 13, column (a), or
the comparable line of other corporate
income tax returns. In doing so, the
corporate U. S. shareholder must
determine whether it meets the statutory
and regulatory requirements for section
245A DRD.

Line 5b

Enter the amount of the dividends
received by the shareholder from the
foreign corporation that is an extraordinary
disposition amount. See Regulations
section 1.245A-5(c) for rules for
calculating an extraordinary disposition
amount.

Instructions for Form 5471 (Rev. 01-2023)

Note. The corporate U.S. shareholder
should include the line 5c amount on Form
1120, Schedule C, line 14, column (a), or
the comparable line of other corporate
income tax returns.

Line 5d

Enter the amount of hybrid dividends
received by the U.S. shareholder from the
foreign corporation. In general, in the case
of a domestic corporation that is a U.S.
shareholder with respect to a CFC, a
dividend received by the domestic
corporation from the CFC is a hybrid
dividend to the extent of the sum of the
U.S. shareholder’s hybrid deduction
accounts with respect to shares of stock of
the CFC. See section 245A(e) and
Regulations section 1.245A(e)-1(b) for
additional information about hybrid
dividends.
Note. The corporate U.S. shareholder
should include the line 5d amount on Form
1120, Schedule C, line 14, column (a), or
the comparable line of other corporate
income tax returns.

Line 5e

Enter on line 5e dividends not reported on
line 5a, 5b, 5c, or 5d.

Note. The corporate U.S. shareholder
should include the line 5e amount on Form
1120, Schedule C, line 14, column (a), or
the comparable line of other corporate
income tax returns.

Line 6

If previously taxed E&P (PTEP) were
distributed, enter the amount of foreign
currency gain or (loss) recognized 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) and Regulations section
1.986(c)-1(a) and (b) for rules for
computing section 986(c) gain or (loss)
recognized with respect to distributions of
PTEP within the reclassified section
965(a) PTEP group and the section 965(a)
PTEP group. Do not include any foreign
currency gain or loss with respect to PTEP
within the reclassified section 965(b)
PTEP group or the section 965(b) PTEP
-17-

Line 8a

Check the “Yes” box on line 8a if the U.S.
shareholder completing this form had an
extraordinary disposition account with
respect to the foreign corporation having a
balance greater than zero at any time
during the tax year of the foreign
corporation. See Regulations section
1.245A-5(c) for rules regarding an
extraordinary disposition account.

Line 8b

If “Yes” is checked on line 8a, enter on
line 8b the U.S. shareholder’s
extraordinary disposition account balance
at the beginning and end of the foreign
corporation’s tax year. Attach a statement
detailing any differences between the
starting and ending balance of the
extraordinary disposition account reported
on line 8b.

Line 8c

Enter on line 8c the CFC’s total
extraordinary disposition account balance
with respect to all U.S shareholders of the
CFC at the beginning of the CFC year and
at the end of the CFC tax year. Attach a
statement detailing any differences
between the starting and ending balance
reported on line 8c.

Line 9

If the foreign corporation is a CFC and the
filer is a domestic corporation, enter on
line 9 the sum of the hybrid deduction
accounts with respect to each share of
stock of the CFC that the domestic
corporation owns directly or indirectly
(within the meaning of section 958(a)(2),
and determined by treating a domestic
partnership as foreign). The reported
amount should reflect the balance of the
hybrid deduction accounts as of the close
of the tax year of the CFC, and after all
adjustments to the hybrid deduction
accounts for the tax year (for example, to
reflect hybrid deductions of the CFC, or
hybrid dividends paid by the CFC). For
example, if the CFC is an upper-tier CFC
all the stock of which is owned by the filer,
then line 9 must reflect the sum of the
filer’s hybrid deduction accounts with
respect to shares of stock of the upper-tier
CFC; if instead the CFC is a lower-tier
CFC all the stock of which is owned by the
filer through an upper-tier CFC, then line 9

must reflect the sum of the upper-tier
CFC’s hybrid deduction accounts with
respect to shares of stock of the lower-tier
CFC.
A hybrid deduction account with
respect to a share of stock of a CFC
reflects the amount of hybrid deductions of
the CFC that has been allocated to the
share. In general, a hybrid deduction is a
deduction or other tax benefit allowed to
the CFC (or a related person) under a
foreign tax law for an amount paid,

accrued, or distributed with respect to an
instrument of the CFC that is stock for
U.S. tax purposes. A hybrid deduction
includes a deduction allowed to the CFC
under a foreign tax law with respect to
equity (such as a notional interest
deduction). See Regulations section
1.245A(e)-1(d) for additional information
about hybrid deduction accounts.

respect to each share of stock of the CFC
that the domestic corporation owns
directly or indirectly through a partnership,
trust, or estate. In addition, certain
upper-tier CFCs must maintain a hybrid
deduction account with respect to each
share of the stock of a lower-tier CFC that
the upper-tier CFC owns directly or
indirectly through a partnership, trust, or
estate. See Regulations section
1.245A(e)-1(d) for more on maintenance
of hybrid deduction accounts.

DRAFT AS OF
March 10, 2023
A domestic corporation that is a U.S.
shareholder with respect to a CFC must
maintain a hybrid deduction account with

-18-

Instructions for Form 5471 (Rev. 01-2023)

Worksheet A

Summary of U.S. Shareholder’s Pro Rata Share of Subpart F Income of a CFC (See the Worksheet A
instructions, later.) Enter the amounts on lines 1a through 62, 64, 66, and 68 in functional currency.
1

DRAFT AS OF
March 10, 2023

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

Instructions for Form 5471

-19-

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

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

DRAFT AS OF
March 10, 2023
.

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 . . . . . . . . . . . . . . . . . . .

-20-

Instructions for Form 5471 (Rev. 01-2023)

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(d) subpart F Foreign Base Company Sales Income subtotal . . . . . . . . .
Section 954(e) 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(d) 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(e) 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

DRAFT AS OF
March 10, 2023

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 1e . . . . .
Amount of line 61 that applies to section 954(d) 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 1f . . . . .
Amount of line 61 that applies to section 954(e) 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 1g . . . . .
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 1h. . . . . .

Instructions for Form 5471 (Rev. 01-2023)

-21-

40
41
42
43

46

49

52

55
56

61
62
63
64
65
66
67
68
69

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 (sections
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)).

• 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 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
partnership interest would constitute
subpart F income. Do not report these
amounts on line 1b. Instead, report them
on line 1i.

DRAFT AS OF
March 10, 2023

Line 1a. Do not include:
• 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 section 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 is
generally 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.
Note. Section 111 of the Taxpayer
Certainty and Disaster Tax Relief Act of
2020 extended the look-through rule of
section 954(c)(6). The rule now applies to
tax years of foreign corporations
beginning after December 31, 2005, and
before January 1, 2026, and to tax years
of U.S. shareholders with or within which
such tax years of the foreign corporations
end. Continue to exclude the applicable
types of income specified in section
954(c)(6) from Worksheet A, line 1a, for
the period specified in the previous
sentence.
Line 1b. Enter the excess of gains over
losses from the sale or exchange of:

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.
-22-

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
Instructions for Form 5471 (Rev. 01-2023)

to high foreign taxes. Foreign base
company income and insurance income
do 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).

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.

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.
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.

DRAFT AS OF
March 10, 2023

Line 18. Adjusted net insurance income. Insurance income is any income
attributable to the issuing (or reinsuring) of
any insurance or annuity contract that
would (subject to the modifications
provided in section 953(b)) be taxed under
subchapter L (insurance company tax) if
such income were income of a domestic
insurance company. However, insurance
income does not include exempt
insurance income (as defined in section
953(e)).
Line 19. Adjusted net related person
insurance income. 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 (as defined in section 953(c)(1)(B)),
or a related person (as defined in section
953(c)(6)) to such a shareholder. If a CFC
has related person insurance income, the
U.S. shareholder’s pro rata share 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, or
• The corporation:

Instructions for Form 5471 (Rev. 01-2023)

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

-23-

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) 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).

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 18 in functional currency.
1

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:
a The first quarter of the tax year . . . . . . . . . . . . . . . .
1a
b The second quarter of the tax year . . . . . . . . . . . . . .
1b
c The third quarter of the tax year . . . . . . . . . . . . . . .
1c
d The fourth quarter of the tax year . . . . . . . . . . . . . . .
1d
2
Number of quarter-ends the foreign corporation was a CFC during the tax year . . . . . . . .
3
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.) . . .
4
U.S. shareholder’s pro rata share of the amount on line 3 . . . . . . . . . . . . . . .
5
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
Section 956(a)(1) amount. Subtract line 5 from line 4 . . . . . . . . . . . . . . . .
7
Applicable earnings:
7a
a Current year earnings and profits . . . . . . . . . . . . . . .
b Line 7a plus accumulated earnings and profits
. . . . . . . . . .
7b
8
Enter the greater of line 7a or line 7b . . . . . . . . . . . . . . . . . . . . . .
9
Distributions made by the CFC during the tax year . . . . . . . . . . . . . . . . .
10
Subtract line 9 from line 8 . . . . . . . . . . . . . . . . . . . . . . . . .
11
Earnings and profits described in section 959(c)(1) . . . . . . . . . . . . . . . . .
12
Applicable earnings. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . .
13
Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12 . . . . .
14
Section 956(a) amount. Enter the smaller of line 6 or line 13 . . . . . . . . . . . . . .
15
Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder . . . . . . .
16
Tentative section 956 amount. Subtract line 15 from line 14 . . . . . . . . . . . . . .
17
Amount of deduction under section 245A, if any, that the shareholder would be allowed if the
shareholder received a hypothetical distribution within the meaning of Regulations section 1.956-1(a)(2).
If the shareholder is not a U.S. corporation, this amount is zero . . . . . . . . . . . . .
18
Section 956 amount. Subtract line 17 from line 16 . . . . . . . . . . . . . . . . .
19
Translate the amount on line 18 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 . . . . . . . . .

DRAFT AS OF
March 10, 2023

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 are also taken into
account before the section 956 inclusion is
determined. Distributions are generally
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
income 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 is
generally 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
-24-

2
3
4

5
6

8
9
10
11
12
13
14
15
16

17
18
19

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 Form 5471 (Rev. 01-2023)

Instructions for Separate
Schedules
Schedule E

Use Schedule E, Part I, to report taxes
paid, accrued, or deemed paid under
section 960(b)(2), by a foreign corporation
for which a foreign tax credit is allowed
and use Schedule E, Part III, to report
taxes for which a credit may not be taken.

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).
If one of the RBT codes is entered on
line a, enter on line c the country code for
the treaty country using the two-letter
codes (from the list at IRS.gov/
CountryCodes).

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 Tax Cuts and Jobs Act, PL 115-97,
December 22, 2017, 131 Stat 2054.
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.

DRAFT AS OF
March 10, 2023

Note. Schedule E must be completed
even for noncorporate U.S. shareholders.
Certain noncorporate U.S. shareholders
may elect under section 962 to be taxed at
corporate rates on section 951(a) amounts
and the GILTI inclusion for the tax year, so
as to be able to claim a credit for certain
foreign taxes paid or accrued by the CFC.
The information reported on Schedule E is
relevant for U.S. shareholders making this
election. Also, timely information reporting
is important to the extent the U.S.
shareholder chooses to amend its return
in a later year to make the election under
section 962. Schedules E and E-1 are also
relevant for noncorporate U.S.
shareholders who do not make a section
962 election. Taxes paid or accrued with
respect to distributions of PTEP by the
U.S. shareholder, while not reported on
the Form 5471, are subject to different
rules regarding creditability and foreign
currency gain or loss. See, for example,
sections 965(g) and 986(c). Therefore, it is
important that the U.S. shareholder track
the PTEP groups to follow the different
rules for each group.
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 of foreign corporation. If applicable, use the reference ID
number shown on Form 5471, page 1,
Item 1b(2).
Lines a, b, and c. 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,

Instructions for Form 5471 (Rev. 01-2023)

Note. Do not complete a separate
Schedule E for taxes assigned to the
section 951A category. Taxes paid,
accrued, or deemed paid with respect to
section 951A PTEP that is in the section
951A category are reported on the
Schedule E completed for the general
category.

Important. In addition to the separate
category codes referred to above, if you
have more than one of the categories of
income referred to above, you must
complete and file a separate Schedule E
(including Schedule E-1) using code
"TOTAL" that aggregates all amounts
listed for each line and column of all other
Schedules E and E-1.

Part I—Taxes for Which a
Foreign Tax Credit Is Allowed

In Part I, Section 1, 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.
In Part I, Section 2, report taxes
deemed paid under section 960(b)(2) with
respect to distributions of PTEP from a
lower-tier foreign corporation to the foreign
corporation with respect to which this
Schedule E (Form 5471) is being
completed.

Amounts not reported in Part I. Do not
report taxes that are not creditable,
including taxes for which a credit is
disallowed under section 245A(d), section
901(j), (k), (l), or (m) or suspended under
section 909. Such taxes are reported in
Part III. A credit is never allowed for taxes
paid or accrued to the United States. Do
not report such taxes in Part I, but in Part
III.
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
-25-

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 taxes added or deducted on line 2g of
Schedule H include both foreign income
taxes reported in Part I of Schedule E as
well as the taxes reported in Part III of
Schedule E that are not creditable foreign
income taxes.

Section 1—Taxes Paid or
Accrued Directly by Foreign
Corporation
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.

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. See Item 1(b)
(2)—Reference ID number for more
information about reference ID numbers.

Column (c)

Columns (k) and (l)

Check the box if the foreign income taxes
reported in column (j) were paid or
accrued by the corporation during prior tax
years and 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.

Enter the exchange rate in column (k) and
the translated dollar amount in column (l).
Translate the taxes entered in column
(j) 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).

15u of foreign source income with respect
to CFC1’s tax year ending December 31,
2017, 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 2022 Form 5471, Schedule E,
General Category, Part I, Section 1, for
CFC1.
• Line 1, column (a): CFC1
• Line 1, column (b): 1000123
• Line 1, column (d): XX
• Line 1, column (e): 2022/12/31
• Line 1, column (f): 2022/12/31
• Line 1, column (g): 50u
• Line 1, column (i): u
• Line 1, column (j): 10u
• Line 1, column (k): 1.0000
• Line 1, column (l): $10
• Line 1, column (m): 10u
An amended 2017 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, Section 1, with the
following entries for the general category
of income.
• Line 1, column (a): CFC1
• Line 1, column (b): 1000123
• Line 1, column (d): XX
• Line 1, column (e): 2017/12/31
• Line 1, column (f): 2017/12/31
• Line 1, column (g): 15u
• Line 1, column (i): u
• Line 1, column (j): 1.20u
• Line 1, column (k): 1.6667
• Line 1, column (l): $2
• Line 1, column (m): 1.20u

DRAFT AS OF
March 10, 2023

Column (d)

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 (e)
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.

Column (g)
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
(j).

Column (h)
Check the box if taxes were paid on U.S.
source income.

Column (i)
Enter the three-letter currency code for the
local currency in which the tax is payable.
Currency codes are available at www.sixgroup.com/en/products-services/financialinformation/datastandards.html#scrollTo=currency-codes.

Column (j)
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).

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 2 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 (m)
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 5

Report the total of the amounts listed in
column (l) on this line 5. This total should
also be reported on Schedule E-1, line 4.

Line 6

Report the total of the amounts listed in
column (m) on this line 6. This total and
the amount reported on line 3 of
Schedule E, Part III, are the appropriate
reduction to current year E&P for income
taxes. 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
foreign source taxable income with
respect to CFC1’s foreign tax year ending
December 31, 2022. 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, 2022, a refund of 3u from Country X on
-26-

Section 2—Taxes Deemed Paid
(Section 960(b))
The purpose of Section 2 is to track
deemed-paid foreign income taxes with
respect to current year PTEP distributions
from lower-tier foreign corporations to the
foreign corporation with respect to which
this Schedule E (Form 5471) is being
completed (“the foreign corporation”).
Report a PTEP distribution by a
lower-tier foreign corporation in Section 2
only if foreign income taxes are deemed
paid under section 960(b) by the foreign
corporation with respect to such PTEP
distribution.
The only foreign taxes of the
distributing foreign corporation that may
be treated as deemed paid under section
960(b) are foreign taxes paid, accrued, or
deemed paid by the distributing foreign
corporation with respect to the receipt of a
Instructions for Form 5471 (Rev. 01-2023)

PTEP distribution from another lower-tier
foreign corporation below the distributing
foreign corporation. Accordingly, there can
be no deemed-paid foreign taxes with
respect to a PTEP distribution from a
lower-tier foreign corporation that is the
lowest foreign-tier foreign corporation in a
chain, and therefore no such distributions
will be reported in Section 2. See
Regulations section 1.960-1(d)(3)(ii)(B).

PTEP Group Classification
Taxes related to
previously taxed E&P

PTEP Group Code

Reclassified section
965(a) PTEP

R965a

Reclassified section
965(b) PTEP

R965b

General section 959(c)
(1) PTEP

959c1

Reclassified section
951A PTEP

R951A

Reclassified section
245A(d) PTEP

R245Ad

Section 965(a) PTEP

965a

Section 965(b) PTEP

965b

Section 951A PTEP

951A

Column (i)
Enter the U.S. dollar amount of the
recipient foreign corporation's income
taxes deemed paid that are properly
attributable to the PTEP distribution
reported in column (f) and not deemed to
have been paid by the domestic
corporation for any prior tax year.

DRAFT AS OF
March 10, 2023

Any foreign income taxes paid or
accrued (but not deemed paid) by the
foreign corporation with respect to a PTEP
distribution from a lower-tier foreign
corporation (whether or not such PTEP
distribution is reported in Section 2), such
as withholding taxes imposed on the
PTEP distribution, are reported in Section
1.

Column (a)

Enter the name of each lower-tier foreign
corporation that made a PTEP distribution
with respect to which a deemed-paid tax is
determined in the current year by the
foreign corporation with respect to which
this Schedule E (Form 5471) is being
completed.

Column (b)
Enter the employer identification number
(EIN) or reference ID number of the
lower-tier foreign corporation listed in
column (a). A reference ID number is
required only in cases in which no EIN
was entered for the lower-tier foreign
corporation. Filers are permitted to enter
both an EIN and a reference ID number.
See Item 1b(2)—Reference ID Number for
more information about reference ID
numbers.

Column (c)
Enter the applicable two-letter codes (from
the list at IRS.gov/CountryCodes).

Column (d)
Enter the code which describes the PTEP
group classification (as set forth in
Regulations section 1.960-3(c)(2)). Please
enter the applicable PTEP group code
from the following list.

Section 245A(d) PTEP

245Ad

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

951a1A

Column (e)
Enter the year in which the U.S.
shareholder included income of the
lower-tier foreign corporation under
section 951(a) or section 951A and
established the PTEP account to which
the distribution is attributed. This is the
annual PTEP account. See Regulations
section 1.960-3(c)(1).

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.

Columns (a) and (b)
See Part I Taxes for Which a Foreign Tax
Credit Is Allowed, earlier, for instructions
regarding these columns.

Column (c)

Column (f)
Enter the PTEP distribution with respect to
the PTEP group within the annual PTEP
account identified in column (d) and
column (e) in the functional currency of the
distributing lower-tier foreign corporation.
If there is a PTEP distribution related to
more than one PTEP group within an
annual PTEP account, complete a
separate line for each PTEP group within
an annual PTEP account.

Column (g)
Enter the total amount of the lower-tier
foreign corporation’s PTEP in the PTEP
group within the annual PTEP account
identified in column (d) and column (e).
Enter such amount in the functional
currency of the distributing lower-tier
foreign corporation.

Column (h)
Enter the total amount of the lower-tier
foreign corporation’s PTEP group taxes
with respect to the PTEP group within the
annual PTEP account identified in column
(d) and column (e). Enter this amount in
U.S. dollars. To determine the appropriate
translation rate, see section 986(a).
Instructions for Form 5471 (Rev. 01-2023)

Note. With respect to distributions of
PTEP resulting from inclusions under
section 965, report the taxes properly
attributable to such PTEP without
reduction for the foreign tax credit
disallowance.

-27-

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 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.

Columns (a), (b), and (c)

In columns (a), (b), and (c), report only the
foreign income taxes the foreign
corporation pays or accrues attributable to
the subpart F income group, the tested
income group, and the residual income
group, respectively. Use Schedule Q to
determine the taxes attributable to each
income group. 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.
Do not include foreign income taxes that
are disallowed and are reported on
Schedule E, Part III. Do not include taxes
paid or accrued by the foreign corporation
with respect to its receipt of a PTEP
distribution, even if those amounts were
included in the total entered on line 5,
column (l), of Schedule E, Part I, Section
1. These are reported in column (e). Do
not include taxes deemed paid by the
foreign corporation with respect to its
receipt of a PTEP distribution. These are
also reported in column (e).

Line 1b. If the balance on line 16 of 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 on this line. See Corrections to
Form 5471, earlier. Do not include any
adjustments required to be reported on
line 7 or 12. Attach a statement that
includes an explanation and the dollar
amount of each such adjustment, along
with a total that equals the amount entered
on line 1b.

DRAFT AS OF
March 10, 2023

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)
Report foreign income taxes related to the
current tax year that have been
suspended due to the rules of section 909.

Column (h)
Enter taxes for which a foreign tax credit is
disallowed other than those detailed in
columns (c) through (g). Such taxes may
include, but are not limited to, taxes
attributable to section 245A(d) income,
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.

Column (i)
For each line in this column, enter the total
amount for each payor in columns (c)
through (h).

Line 3

Total each amount in column (i) 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 (on pages 2 and 3 of
separate Schedule E) to report the
cumulative balance of foreign income
taxes paid or accrued by a CFC by
separate category of income.
Enter amounts in U.S. dollars unless
otherwise noted.

On line 9, report reductions for the
portion of such taxes that are deemed
paid by a U.S. shareholder with respect to
an inclusion under section 951(a) or 951A.
On line 15, report reductions for foreign
income taxes attributable to the column
(b) tested income group that are not
deemed paid as a result of the inclusion
percentage or the 80% limitation. Also, on
line 15, report any other reductions to the
three income groups in columns (a), (b),
and (c) necessary to achieve a zero
balance on line 16. Attach a statement
explaining why such taxes were not
deemed paid under section 960. The
balance of foreign income taxes paid or
accrued with respect to the three income
groups that is entered on line 16 should
equal zero after taking into account the
reductions.

Column (d)

Use column (d) to report taxes suspended
under section 909.

Columns (e)(i) through (e)(x)

Report foreign income taxes paid or
accrued with respect to E&P described in
sections 959(c)(1) and (c)(2). See
instructions for Schedule J, Column (e),
for specific information about the ten
PTEP group columns. Also see
Regulations section 1.960-3(c)(2) for
additional information regarding the ten
PTEP groups.

Specific Instructions Related to
Lines 1 through 16
Line 1a. This amount should equal the
amount that was reported as the balance
on line 16 of the prior year Schedule E-1.
-28-

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.
Line 3a. A tax reported on Schedule E,
Part I, Section 1, line 5, column (l) for
which column (c) was checked because
such tax was unsuspended in the current
year, should be included as a positive
amount in column (a), (b), (c), or (e), as
appropriate. Such tax should also be
reflected as a negative amount in column
(d).
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.
Such taxes are also reported on
Schedule E, Part III, column (g).
Line 4. The total reported on Schedule E,
Part I, Section 1, line 5, column (l), should
be separated into columns (a) through (e)
according to the type of income or E&P to
which such taxes relate. Therefore, for
example, taxes paid or accrued with
respect to the receipt of a PTEP
distribution are reported in column (e), and
taxes paid or accrued with respect to
current year subpart F income of the
foreign corporation are reported in column
(a).
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

Instructions for Form 5471 (Rev. 01-2023)

Domestic Corporation, CFC1, CFC2, and
CFC3 is the U.S. dollar. During Year 1,
CFC 3 has subpart F income, after foreign
income tax, of $100 with respect to which
it pays $20 of foreign income tax. Such tax
is properly attributable to subpart F
income of CFC 3 and is reported on line 4,
column (a) of Schedule E-1 of CFC 3’s
Form 5471. During Year 1, Domestic
Corporation reports an inclusion under
section 951(a)(1) of $100 and deemed
paid taxes of $20 under section 960(a) 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 earnings
and profits that were included as subpart F
income and is reported on line 4, column
(e)(x), of Schedule E‐1 of CFC2’s Form
5471.

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. See line 15 with
respect to reporting tested taxes not
deemed paid as a result of the inclusion
percentage or the application of the 80%
limitation.

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. An example of
amounts reported on line 12 is taxes
attributable to PTEP distributions to
shareholders ineligible to claim a foreign
tax credit under section 960(b)(1) (such as
foreign corporations).

DRAFT AS OF
March 10, 2023

Line 5. 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).
Line 6. Enter foreign income taxes
properly attributable to PTEP and not
previously deemed paid (from
Schedule E, Part I, Section 2, line 5,
column (i)). The total reported on
Schedule E, Part I, Section 2, line 5,
column (i) should be broken out on
Schedule E-1, line 6, columns (e)(i)
through (e)(x) based on the type of PTEP
to which such taxes relate.

Example 2. The facts are the same as
in Example 1, except that, in addition,
CFC2 distributes $36 to CFC1 in Year 3.
CFC1 is deemed to pay the $4 of
withholding tax paid by CFC2 in Year 2.
See section 960(b). Such tax is
attributable to previously taxed subpart F
income and is reported on line 6, column
(e)(x), of Schedule E‐1 of CFC1’s Form
5471. Such tax is also reported as a
negative number on line 10, column (e)(x),
of Schedule E‐1 of CFC2’s Form 5471.
Line 7. 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.
Line 9. A domestic corporation is
deemed to pay foreign income taxes
attributable to inclusions under section
951(a)(1). See section 960(a). Amounts
reported on line 9 should be negative
numbers.
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
Instructions for Form 5471 (Rev. 01-2023)

Line 10. A domestic corporation is
deemed to pay foreign income taxes with
respect to distributions of previously taxed
E&P. Section 960(b)(1). Amounts reported
on line 10 should be negative numbers.
Taxes are deemed paid by a domestic
corporation that is a U.S. shareholder or a
foreign corporation that is a controlled
foreign corporation with respect to
distributions of PTEP that it receives.
Report on line 10, column (e), the taxes
that relate to PTEP of the foreign
corporation that are deemed paid by a
shareholder of the foreign corporation,
either an upper-tier foreign corporation or
a U.S. shareholder, with respect to a
distribution of PTEP made by the foreign
corporation.
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)(x), of
CFC1’s Form 5471, Schedule E-1.
See Example 2 for reporting on line 10
with respect to taxes on distributions from
CFC3 to CFC2.
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)(vi)
through (e)(x) and as positive numbers in
columns (e)(i) through (e)(v).
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)(x), and
a positive $4 will be recorded on line 11,
column (e)(iii).

-29-

Line 15. Enter the reduction to the
column (b) tested income group for tested
income taxes not deemed paid. See
Regulations section 1.960-1. This includes
taxes attributable to the column (b) tested
income group that were not deemed paid
as a result of the domestic corporation’s
inclusion percentage or as a result of the
application of the 80% limit. See section
960(d). Enter the reduction to the three
income groups in columns (a), (b), and (c)
for other taxes not deemed paid. See
Regulations section 1.960-1. This includes
taxes that are properly attributable to a
subpart F income group but were not
deemed paid because there was no
subpart F income with respect to that
income group in the current year.
Note. If necessary, enter negative
amounts on line 15 of columns (a), (b),
and (c) in amounts sufficient to reduce
line 16, columns (a), (b), and (c), to zero.
Attach a statement explaining why such
taxes were not deemed paid under section
960.

Schedule G-1
Note. A separate Schedule G-1 must be
filed for each cost sharing arrangement
(CSA) as defined in Regulations section
1.482-7(b) in which the foreign corporation
was a controlled participant (as defined in
Regulations section 1.482-7(j)) during the
tax year. All amounts should be reported
in U.S. dollars.
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 of foreign corporation. If applicable, use the reference ID
number shown on Form 5471, page 1,
Item 1b(2).
Question 4. Enter the foreign
corporation’s share of reasonably
anticipated benefits (RAB) for the CSA
during the tax year. See Regulations
section 1.482-7(e) for rules on a
determining and updating controlled
participant’s RAB share. If the foreign

corporation applied more than one RAB
share during the tax year in determining its
share of intangible development costs
(IDCs), enter the RAB share that was
applied to IDCs incurred at the end of the
year. See Regulations section 1.482-7(d)
for more information on IDCs.
Question 5a. Check the “Yes” box if the
U.S. taxpayer made any platform
contributions as defined in Regulations
section 1.482-7(c) to the CSA during the
tax year. If “Yes,” complete lines 5b and
5c.

total amount of stock-based compensation
taken into account as an IDC for the tax
year pursuant to such election. If the
taxpayer attaches the statement
described in the previous sentence, then
in the entry space provided for line 6b the
taxpayer should include the total amount
of stock-based compensation taken into
account as an IDC, including stock-based
compensation pursuant to the election
described above and any not subject to
such election.
Check the appropriate box on line 6c to
indicate whether any stock-based
compensation was granted during the
term of the CSA to individuals who
performed functions in business activities
that generate cost shared intangibles that
were not treated as directly identified with,
or reasonably allocable to, the IDA as
defined in Regulations section 1.482-7(d)
(1)(i). This would include stock-based
compensation granted in earlier years
(which could give rise to deductions in the
current tax year) that were not treated as
identified with or reasonably allocable to
the IDA.

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).

DRAFT AS OF
March 10, 2023

Questions 5b and 5c. Enter the foreign
corporation's 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 on line 5b. The total present
value of all platform contributions made by
the U.S. taxpayer during the tax year
should be entered 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).
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, check the appropriate
boxes on line 5c 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.

Questions 6b and 6c. See generally
Regulations section 1.482-7 for more
information on determining whether
stock-based compensation is directly
identified with, or reasonably allocable to,
the intangible development activity (IDA)
under the CSA. See Regulations section
1.482-7(d)(3) and Notice 2005-99 for
more information on determining the
measurement and timing of stock-based
compensation IDCs, including an election
available with respect to options on
publicly traded stock and certain other
stock-based compensation. If the taxpayer
made the election described in
Regulations section 1.482-7(d)(3)(iii)(B) or
Notice 2005-99, the taxpayer should
attach a statement to Form 5471
explaining that the taxpayer made such
election and include in such statement the

Questions 7a and 7b. For the tax year,
enter the total amount of IDCs for the CSA
on line 7a. See Regulations section
1.482-7(d) for more information on IDCs.
On line 7b, enter the amount of IDCs
allocated to the foreign corporation for the
tax year based on the foreign
corporation’s RAB share.

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 specific instructions for
Item F—Alternative Information Under
Rev. Proc. 2019-40, earlier, for more
details.
Note. Category 5b and 5c filers are not
required to file Schedule H for
foreign-controlled CFCs.
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 of foreign corporation. If applicable, use the reference ID

-30-

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 22 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 21, 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
currency 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

Instructions for Form 5471 (Rev. 01-2023)

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.
Schedule H is only prepared for the
general, passive, and section 901(j)
categories of income. For example, if U.S.
GAAP income reported on Schedule C
contains items related to PTEP, include
the necessary adjustments on line 2i of
Schedule H for the appropriate category of
income (general or passive) and attach a
statement that itemizes and explains
those adjustments. Report adjustments for
foreign taxes related to the PTEP on
line 2g. This adjustment is necessary
because foreign taxes imposed on PTEP
distributions do not reduce current year
E&P. Foreign taxes imposed on PTEP
distributions reduce PTEP and are
reported on Schedule J, line 6.

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.

line 6 must include the code for passive
category income (PAS) in the entry space
for separate category (at the top of
Schedule I-1). This is the case even if the
Schedule I-1 also includes general
category income. With respect to a
taxpayer completing Schedule I-1 with
respect to a foreign corporation with only
general category income (and no passive
category income) on line 6, the taxpayer
should enter the code “GEN” in the entry
space for separate category.

DRAFT AS OF
March 10, 2023

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. During Year 1, Domestic
Corporation reports an inclusion under
section 951(a)(1) of $100 as a result of
subpart F income of CFC2. During Year 2,
CFC2 distributes $40 to CFC1. CFC1
pays withholding tax of $4 on the
distribution from CFC2. Such tax is related
to previously taxed subpart F income. On
Domestic Corporation’s financial
statements, Domestic Corporation reports
the $4 withholding tax as current income
tax expense. Domestic Corporation
reports on CFC1’s Form 5471,
Schedule H, on line 2g, a positive
adjustment for the $4 of tax on the PTEP
distribution.
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 5c. The line 5c current year E&P
amount may include amounts with respect
to the general category, passive category,
or section 901(j) category. See
Regulations section 1.960‐1(d)(2). Enter
on lines 5c(i), 5c(ii), 5c(iii)(A), 5c(iii)(B),
5c(iii)(C), and 5c(iii)(D), as applicable, the
portion of the line 5c current year E&P
amount with respect to each applicable
category of income. If applicable for lines
5c(iii)(A), 5c(iii)(B), 5c(iii)(C), and 5c(iii)
(D), also enter the country code for the
sanctioned country using the two-letter
codes (from the list at IRS.gov/
CountryCodes).
Note. The amounts reported on line 5c
include both foreign source and U.S.
source income.
Instructions for Form 5471 (Rev. 01-2023)

Line 5e. Enter the exchange rate used in
computing line 5d. Report the exchange
rate using the "divide-by convention"
specified under Reporting Exchange
Rates on Form 5471.

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, or Form 1116, 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 specific instructions for
Item F—Alternative Information Under
Rev. Proc. 2019-40, earlier, 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 on
-31-

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.
The amount of gross income entered on
line 1 will generally be a positive amount.
However, if a CFC’s cost of goods sold
exceeds its gross receipts, a negative
amount is permitted on line 1.
Line 2. Enter the CFC’s exclusions as
described in Regulations section
1.951A-2(c).
Line 2a. Enter the amount of the
CFC’s income or loss described in section
952(b), which is generally income or loss
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 or loss 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
(include amounts excluded from tested
income under Regulations section
1.951A-2(c)(7)).
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.

(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).

Line 2e. Enter the amount of the
CFC’s taxable income or loss 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.

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.

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).

DRAFT AS OF
March 10, 2023

Line 3. Combine lines 2a through 2e. The
line 3 result can be positive or negative.
Line 4. Subtract line 3 from line 1 and
enter the result on line 4. The line 4 result
can be positive or negative. For example:
Line 1
gross
income
Line 3 total
exclusions
Line 4
(line 1
minus
line 3)

$1,000 $1,000
800

$200

(800)

$(1,000) $(1,000)
800

(800)

$1,800 $(1,800)

$(200)

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). See section 951A(c)(2)(A)(ii) and
Regulations section 1.951A-2(c)(3).
Line 6. Subtract line 5 from line 4 and
enter the result on line 6. The line 6 result
can be positive or negative. See the line 4
instructions above for examples. 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 group. 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.
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)

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 is generally determined based
on the average of the adjusted basis in the
property as of the close of each quarter of
the partnership’s tax year that ends with or
within the CFC’s tax 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.
Line 9a. Enter the amount of interest
expense included on line 5. See the

-32-

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 10a. Enter the amount of interest
income included on line 4. See the
instructions for Line 6 for foreign currency
translation.
Line 10b. Enter the CFC’s qualified
interest income, as defined in Regulations
section 1.951A‐4(b)(2)(iii).
Line 10c. Subtract line 10b from
line 10a and enter the result on line 10c.

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 1b, 1c, 5b, and 5c filers
are not required to file Schedule J for
foreign-controlled section 965 SFCs or
foreign-controlled CFCs.
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 of foreign corporation. If applicable, use the reference ID
number shown on Form 5471, page 1,
Item 1b(2).
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, except
foreign branch category income. A foreign
Instructions for Form 5471 (Rev. 01-2023)

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, except 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).

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.

1. PTEP attributable to, or reclassified
as, investments in U.S. property (section
959(c)(1)(A) amounts).
2. PTEP attributable to subpart F
income inclusions (not described in any
other column) and reclassified as
investments in U.S. property.
3. PTEP attributable to inclusions
under previous section 951(a)(1)(C) and
subpart F income inclusions reclassified
as investments in excess passive assets.
• 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 described in the
following three subgroups (which are
aggregated into a single PTEP group).
1. PTEP attributable to hybrid
dividends under section 245A(e)(2) and
reclassified as investments in U.S.
property.
2. PTEP attributable to section 1248
amounts under section 959(e) and
reclassified as investments in U.S.
property.
3. PTEP attributable to section 1248
amounts from the gain on the sale of
foreign corporation stock by a CFC and
reclassified as investments in U.S.
property.
• Column (e)(vi) is PTEP attributable to
section 965(a) inclusions (section 959(c)
(2) amounts). Do not include in column (e)
(vi) E&P reported in column (e)(vii).
• Column (e)(vii) is E&P treated as PTEP
under section 965(b)(4)(A) (section 959(c)
(2) amounts).
• Column (e)(viii) is PTEP attributable to
section 951A inclusions (section 959(c)(2)
amounts).
• Column (e)(ix) is PTEP described in the
following three subgroups (which are
aggregated into a single PTEP group).
1. PTEP attributable to hybrid
dividends under section 245A(e)(2).
2. PTEP attributable to section 1248
amounts under section 959(e).
3. PTEP attributable to section 1248
amounts from the gain on the sale of a
foreign corporation stock by a CFC.
• Column (x) is PTEP attributable to
section 951(a)(1)(A) inclusions (section
959(c)(2) amounts) not otherwise
described in the instructions for columns
(e)(vi) through (ix).

DRAFT AS OF
March 10, 2023

Note. A separate Schedule J should not
be completed for the section 951A
category. Reclassified section 951A PTEP
and section 951A PTEP that is in the
section 951A category should be reported
on the general category Schedule J.

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.

Note. For purposes of this Schedule J,
include in each separate category of
income, foreign source and U.S. source
income.

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.

Important. In addition to the separate
category codes referred to above, if you
have more than one of the categories of
income referred to above, you must
complete and file a separate Schedule J
using code “TOTAL” that aggregates all
amounts listed for each line and column in
Part I of all other Schedules J.

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
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 amount of
the other U.S. shareholder’s section 951A
inclusion that is allocated to the CFC
because the first U.S. shareholder does
not have information with respect to the
second U.S. shareholder’s net CFC tested
income or pro rata share of 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 Functional Currency. 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.

Instructions for Form 5471 (Rev. 01-2023)

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 section 1.964-1(a) through
(d), and 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 13,
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 group.
• Columns (e)(i) and (e)(ii) are PTEP
originally attributable to inclusions under
section 965(a) and E&P treated as PTEP
under 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 described in the
following three subgroups (which are
aggregated into a single PTEP group).

-33-

Schedule J reports PTEP by subgroups
because those groups may be subject to
different rules under sections 960, 965(g),
245A(e)(3), and 986(c). The different rules
are applicable for individuals, as well as
corporations, estates, and trusts. For
example, an individual U.S. shareholder
who receives a distribution of PTEP
originally attributable to inclusions under
section 965(a) may only claim a credit for

a portion of the foreign taxes attributable
to a distribution of such PTEP. See section
965(g) and Regulations section 1.965-5
for more information. This is the case for
both direct foreign tax credits (that is,
those foreign taxes paid or accrued
directly by the shareholder upon receipt of
the PTEP distribution and allowed as a
credit under sections 901 or 903) and
indirect foreign tax credits (that is, those
taxes deemed paid by the shareholder
with respect to taxes originally paid or
accrued by the CFC under section
960(b)). With respect to direct credits, this
reduction applies regardless of whether
such individual made an election under
section 962. Therefore, the reporting on
Schedule J is necessary regardless of
whether the U.S. shareholder made a
section 962 election.

numbers on line 2a of column (a), (b), (c),
or (e), as applicable.

receipt of a distribution of PTEP from a
lower‐tier foreign corporation.

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.

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 4, column (e)
(x), as a positive number, the $40 PTEP
distribution. Domestic Corporation reports
on line 6, column (e)(x), as a negative
number, the $4 of tax on the PTEP
distribution.

Line 3. Enter the current year E&P (or
deficit in E&P) amount from the applicable
line 5c of Schedule H (Form 5471). For
example, if you are completing Schedule J
for the passive category (that is, you have
entered "PAS" on line a at the top of
page 1 of Schedule J), enter the current
year E&P (or deficit in E&P) amount from
Schedule H (Form 5471), line 5c(ii), in the
applicable column. Line 3 should never
have an amount entered in column (e).

DRAFT AS OF
March 10, 2023

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 reasons for 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.
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

Line 4. Report as a positive number E&P
attributable to distributions of PTEP 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
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. Negative amounts
are hovering deficits reported in column
(d) of line 5a.

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
-34-

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.
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 columns
(e)(vi) through (e)(x), as applicable.
Amounts reported as positive numbers on
line 8 of column (e)(viii) 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.
In that case, see the example in the
instructions for Schedule P for reporting
information.
Note. The amount reported on line 8 will
not necessarily equal the tested income
reported on Schedule I-1. For an example
of when this might occur, see Regulations
section 1.951A-5(b)(2)(ii).
Line 9. Report actual distributions as
negative numbers.
Instructions for Form 5471 (Rev. 01-2023)

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).
Note. The total of all amounts entered in
Schedule R (Form 5471), column (d) must
equal the amount on line 9, column (f) of
the Schedule J (Form 5471) that is filed
with code “TOTAL” entered on line a of
that Schedule J.

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.”

If an amount is entered on line 14, you
must attach a statement that includes the
following information. Column (a) of the
attached statement should provide a
description of the type of other amounts
received during the annual accounting
period. Columns (b) through (f) should
request dollar amounts of the specified
other amounts received during the annual
accounting period by the foreign
corporation from the persons listed in the
headings for columns (b) through (f).
These headings must comport to those
used on the Schedule M (Form 5471) to
which this statement is attached. The
attached statement must include a “totals”
line that ties into the amounts reported in
each column of line 14.
If an amount is entered on line 29, you
must attach a statement that includes the
following information. Column (a) of the
attached statement should provide a
description of the type of other amount
paid during the annual accounting period.
Columns (b) through (f) should request
dollar amounts of the specified other
amounts paid during the annual
accounting period by the foreign
corporation to the persons listed in the
headings for columns (b) through (f).
These headings must comport to those
used on the Schedule M (Form 5471) to
which this statement is attached. The
attached statement must include a “totals”
line that ties into the amounts reported in
each column of line 29.

DRAFT AS OF
March 10, 2023

Line 10. Use line 10 to report
reclassifications of section 959(c)(2) PTEP
in columns (e)(vi) through (e)(x) to section
959(c)(1) PTEP in columns (e)(i) through
(e)(v). 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)(vi) through (e)(x)
and positive numbers in columns (e)(i)
through (e)(v), as applicable.
Line 11. Use this line to report E&P not
previously taxed, which is treated as
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

Instructions for Form 5471 (Rev. 01-2023)

Reference ID number of foreign corporation. Use the reference ID number
shown on Form 5471, line 1b(2).

Lines 4 and 19. Report on these lines
platform contribution transaction
payments received and paid by the foreign
corporation (without giving effect to any
netting of payments). 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 20. Report on these lines
cost sharing transaction payments
received and paid by the foreign
corporation (without giving effect to any
netting of payments). See Regulations
section 1.482-7(b)(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 20.
Lines 9 and 24. Report on line 9 the sum
of tiered hybrid dividends received by the
foreign corporation during its tax year.
Report on line 24 the sum of hybrid
dividends or tiered hybrid dividends paid
by the foreign corporation during its tax
year.
Lines 10 and 25. 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 13 and 28. Report on these lines
loan guarantee fees received (line 13) and
loan guarantee fees paid (line 28). See
section 482.
Lines 14 and 29. Report on these lines
“other amounts received” (line 14) and
“other amounts paid” (line 29).

-35-

Lines 31 and 33. 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 receivable or
payable arising in connection with the
provision of services or the sale or
processing of property. Only net accounts
receivable and payable to the extent that
the CFC’s books net the accounts payable
against the receivable as payment of the
accounts receivable.
Lines 32 and 34. 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 31 and 33.
Accrued payments and receipts. A
corporation that uses an accrual method
of accounting must use accrued payments
and accrued receipts for purposes of
computing the total amount to enter on
each line of Schedule M.

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
meaning of section 958(a)(2)) by the
shareholder listed in column (a).

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 is also 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.

DRAFT AS OF
March 10, 2023

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 of foreign corporation. 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 (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, 2022, 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, 2022” 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 Section 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

-36-

Schedule P

Use Schedule P to report the PTEP in the
U.S. shareholder’s annual PTEP accounts
with respect to a CFC in the CFC’s
functional currency (Part I) and the U.S.
shareholder’s U.S. dollar basis in that
PTEP (Part II). For purposes of the
preceding sentence, a CFC includes 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 1a, 1b, 4, 5a,
or 5b filer.
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 GILTI
inclusion of Corporation A or B.
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 (h), $50x of PTEP as a
result of its section 951A inclusion with
Instructions for Form 5471 (Rev. 01-2023)

respect to CFC1. Corporation A will report
$20x of PTEP as a result of its section
951A inclusion on its Form 5471,
Schedule P, line 7, column (h), 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)
(viii). 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)(viii). 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)
(viii), and the corresponding reduction to
CFC1’s E&P described in section 959(c)
(3) on Schedule J, Part I, line 1b, column
(a).

income, foreign source and U.S. source
income.
Important. In addition to the separate
category codes referred to above, if you
have more than one of the categories of
income referred to above, you must
complete and file a separate Schedule P
using code "TOTAL" that aggregates all
amounts listed for each line and column of
all other Schedules P.

In general, a taxpayer that is subject to
tax as a domestic corporation that is a
U.S. shareholder (“corporate U.S.
shareholder”) of a CFC is deemed to pay
all or a portion of the foreign income taxes
paid or accrued by the CFC that are
properly attributable to subpart F income
or tested income included in gross income
by the corporate U.S. shareholder. See
section 960(a) and (d). A corporate U.S.
shareholder may claim a credit for such
foreign taxes, subject to certain limitations.

DRAFT AS OF
March 10, 2023

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 of foreign corporation. 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. A separate Schedule P should not
be completed for the section 951A
category. Reclassified section 951A PTEP
and section 951A PTEP that is in the
section 951A category should be reported
on the Schedule P completed for the
general category.
Note. For purposes of this Schedule P,
include in each separate category of
Instructions for Form 5471 (Rev. 01-2023)

Part I

Enter amounts in the functional currency
of the foreign corporation as reported on
Form 5471, page 1, Item 1h Functional
Currency.
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.

Part II
Dollar basis. Enter amounts in U.S.
dollars. The U.S. shareholder’s U.S. dollar
basis in PTEP is generally equal to the
U.S. dollar amount of E&P that the U.S.
shareholder previously included in gross
income. See Regulation sections 989(b)
(1) and (3), 1.951A-1(d)(1), and
1.965-1(b)(1) and (2).
The U.S. shareholder’s U.S. dollar
basis is used by the U.S. shareholder to
determine the amount of foreign currency
gain or loss on the PTEP that the U.S.
shareholder is required to recognize under
section 986(c).
Columns (a) through (k). Use columns
(a) through (k) to report the opening
balance of, current year additions and
subtractions to, and the closing balance
of, the PTEP in the U.S. shareholder’s
annual PTEP accounts with respect to a
CFC.
Columns (a) through (j) of Schedule P
correspond to Schedule J, columns (e)(i)
through (e)(x). See the instructions for
Schedule J for specific line instructions.
Line 1b. If there is a difference between
last year’s ending balance on Schedule P
and the amount that should be last year’s
ending balance, taking into account
modifications in Schedule P, 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.

Schedule Q

Use Schedule Q to report the CFC’s
income, deductions, taxes, and assets by
CFC income groups for purposes of
sections 960(a) and (d).
-37-

Note. If an individual, estate, or trust that
is a U.S. shareholder of a CFC makes an
election under section 962 (“962 electing
shareholder”), any inclusions under
section 951 or section 951A of the U.S.
shareholder will be treated as received by
a corporate U.S. shareholder for purposes
of section 960. See section 962(b) and
Regulations section 1.962-2(b). As a
result, these U.S. shareholders may also
claim a foreign tax credit for foreign
income taxes deemed paid with respect to
such inclusions. See sections 962(a)(1)
and 951A(f)(1)(A).
Note. See also section 1293(f) for
inclusions with respect to a passive
foreign investment company.
To calculate the foreign taxes deemed
paid by the corporate U.S. shareholder
(including a 962 electing shareholder),
determine for each of its CFCs the
income, deductions, and taxes that are
assigned to each separate category of
income and each income group within
each separate category. See Regulations
section 1.960-1(c)(1). The income groups
include the subpart F income groups, the
tested income group, and the residual
income group.

Computer Generated
Schedule Q

Expand the Schedule Q if you are
reporting with respect to more than two
units. Specifically, if you are reporting with
respect to more than two units, add to
pages 1 and 2, as appropriate, new lines
(3), (4), (5), etc. in all necessary locations.

Specific Instructions for
Schedule Q
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 of foreign corporation. If applicable, use the reference ID
number shown on Form 5471, page 1,
item 1b(2).

Line A. Complete a separate Schedule Q
for each applicable separate category of
income. Enter the appropriate code from
the table below for the separate category
of income with respect to which the
Schedule Q is being completed.

Codes for Categories of Income

category of a CFC are on line 1 (“subpart
F income groups”). See Regulations
section 1.960-1(d)(2)(ii)(B). Each single
item of foreign base company income (as
defined in Regulations section 1.954-1(c)
(1)(iii)) is a separate subpart F income
group. With respect to a CFC, Regulations
section 1.954-1(c)(1)(iii)(A)(2) identifies as
a single item of income all foreign base
company income (other than foreign
personal holding company income) that
falls within both a single separate category
(typically, general category income) and a
single category of foreign base company
income described in each of Regulations
sections 1.954-1(c)(1)(iii)(A)(2)(i) through
(v). For example, with respect to line 1g,
there is a single subpart F income group
within the general category that consists of
all of a CFC’s foreign base company sales
income.

DRAFT AS OF
March 10, 2023

Code Category of Income
PAS

Passive category income

901j

Section 901(j) income

GEN

General category income

If code 901j is entered on line A, enter
on line 1m, column (a), the country code
for the sanctioned country using the
two-letter codes (from the list at IRS.gov/
CountryCodes).

Important. In addition to the separate
category codes referred to above, if you
have more than one of the categories of
income referred to above, you must
complete and file a separate Schedule Q
using code “TOTAL” that aggregates all
amounts listed for each line and column in
all other Schedules Q.

Line B. If category code “PAS” is entered
on line A, a separate Schedule Q must be
completed for each applicable grouping
under Regulations section 1.904-4(c)(3).
See Regulations sections 1.954-1(c)(1)(iii)
(B) and 1.904-4(c)(3) through (5). Enter on
line B the appropriate code from the table
below for each of the following groups
under Regulations section 1.904-4(c)(3):

Codes for Passive Groups
Code Passive Group
i

All passive income received during the tax
year that is subject to a withholding tax of
15% or greater must be treated as one
item of income. See Regulations section
1.904-4(c)(3)(i).

ii

All passive income received during the tax
year that is subject to a withholding tax of
less than 15% (but greater than zero)
must be treated as one item of income.
See Regulations section 1.904-4(c)(3)(ii).

iii

All passive income received during the tax
year that is subject to no withholding tax
or other foreign tax must be treated as one
item of income. See Regulations section
1.904-4(c)(3)(iii).

iv

section 1.904-4(c)(4). This is one reason
that, in the case of a CFC, tested
unit-by-tested unit reporting is required
with respect to the income groups on lines
1a through 1j and line 3. A foreign
corporation that is not a CFC, but that is a
noncontrolled 10%-owned foreign
corporation must report this information on
a foreign QBU-by-foreign QBU basis. This
would be the case, for example, if you are
completing Schedule Q for purposes of
attaching it to Schedules K-2 and K-3 for
purposes of section 1293(f).
To figure the amounts to enter on lines
1a through 1j, on lines (1), (2), etc., under
each line 1a through 1j, enter the name of
each unit of the foreign corporation (the
relevant unit being each tested unit in the
case of a CFC and each QBU in the case
of a 10%-owned foreign corporation),
including the foreign corporation itself, and
the information required in each column (i)
through (xvi) with respect to the amount in
each subpart F income group within each
category for each unit.
On lines (1), (2), etc., under line 4,
enter the name of each unit and enter the
information required for columns (i)
through (xvi) for each unit, but do not enter
amounts excluded from subpart F income
under the subpart F high-tax exception
(those amounts are reported on lines (1),
(2), etc., under lines 1a through 1j) or
tested income under the GILTI high-tax
exclusion (those amounts are reported on
lines (1), (2), etc., under line 3).

All passive income received during the tax
year that is subject to no withholding tax
but is subject to foreign tax other than a
withholding tax must be treated as one
item of income. See Regulations section
1.904-4(c)(3)(iv).

Note. The grouping rules of Regulations
section 1.904-4(c)(3)(i) through (iv) apply
separately to income attributable to each
tested unit of a CFC. See Regulations

Line C. If code 901j is entered on line A,
enter the country code for the sanctioned
country using the two-letter codes from
the list at IRS.gov/CountryCodes.
Line D. Taxpayers are generally required
to complete a separate Schedule Q for
foreign source income in each separate
category and U.S. source income in each
separate category. On a given
Schedule Q, taxpayers are generally
required to check the box for either foreign
source income or U.S. source income, as
applicable. However, if a taxpayer has
entered code “TOTAL” on line A and the
total reported on that Schedule Q includes
both foreign source income and U.S.
source income, the taxpayer may check
both boxes on line D.
Line E. A separate Schedule Q is
required for foreign oil and gas extraction
income (FOGEI) and foreign oil related
income (FORI). If the Schedule Q is being
prepared to report the FOGEI or FORI of a
CFC, check the box for Item E. Indicate
the amount of FOGEI and FORI in each
income group.

Line 1. Subpart F Income
Groups

The separate subpart F income groups
within each applicable section 904
-38-

Use lines 1a through 1f to enter the
passive category foreign personal holding
company income of the CFC under the
appropriate income group (dividends,
interest, rents, royalties, and annuities; net
gain from certain property transactions;
net gain from commodities transactions;
net foreign currency gain; income
equivalent to interest; and other passive
category foreign personal holding
company income of the CFC), each of
which is also treated as a separate
subpart F income group under
Regulations section 1.960-1. See
Regulations section 1.954-1(c)(1)(iii)(B).
Note. Enter the following passive
category foreign personal holding
company income of the CFC on line 1e:
• Income from notional principal
contracts,
• Payments in lieu of dividends,
• Personal service contracts.
See section 954(c)(1)(F) through (H).
Attach a statement that includes all of
the information requested by Schedule Q
delineating the amount on line 1e for each
of the four groups reporting on line 1e. For
example, if both income equivalent to
interest and income from notional principal
contracts are included on line 1e, on the
statement, identify the amount related to
each of those income groups for each
column.
Use lines 1g through 1j to enter the
foreign base company sales income,
foreign base company services income,
full inclusion income, and insurance
income described in section 952(a)(1) of
the CFC.
To figure the amounts to enter on lines
1a through 1j, on lines (1), (2), etc., under
each line 1a through 1j, enter the name of
each QBU of the CFC, including the CFC
itself, and the information required in each
column (i) through (xvi) with respect to the
amount in each subpart F income group
Instructions for Form 5471 (Rev. 01-2023)

within each category for each QBU. On
lines 1a through 1j, enter the total for each
column by adding the amounts on lines
(1), (2), etc., excluding from such total any
amounts reported with respect to income
excluded from subpart F income under the
high-tax exception in section 954(b)(4)
(“subpart F high-tax exception”). These
amounts are included in the total amount
of residual income, which is reported on
line 4. As a result, the amounts included
on lines 1a through 1j for each column
may not equal the sum of the amounts
reported on lines (1), (2), etc., for each
column because any item excluded from
subpart F income by reason of the
high-tax election is included in the
summation on line 4 instead of the
summations on lines 1a through 1j. See
the instructions for column (xiv) and line 4.

Line 3. Tested Income Group

Use line 3 to report tested income in the
tested income group of the CFC (a “tested
income group”). See Regulations section
1.960-1(d)(2)(ii)(C). On lines (1), (2), etc.,
under line 3, enter the name of each
tested unit of the CFC (including the CFC
tested unit itself) and enter for each tested
unit the information required in columns (ii)
through (xvi), based on the tentative gross
tested income attributable to each tested
unit (without regard to any amounts
excluded under the GILTI high-tax
exclusion in Regulations section
1.951A-2(c)(7) (“GILTI high-tax
exclusion”)). If the GILTI high-tax
exclusion applies with respect to any
tested unit of the CFC, include the
amounts reported for columns (ii) through
(xiii), (xv), and (xvi) in the total reported on
line 4. See the instructions for line 4. As a
result, the total amount entered on line 3
may not equal the sum of the amounts
reported in columns (ii) through (xiii), (xv),
and (xvi) on lines 3(1), 3(2), etc., if any
tested unit’s tentative tested income is
excluded under the GILTI high-tax
exclusion (these amounts are included in
the total amounts reported on line 4). In
general, tested income will be in a single
tested income group within the general
category. Because a CFC cannot earn
section 951A category income or foreign
branch category income at the CFC level,
there is no tested income group within
either section 904 category. With respect
to the general category tested income
group of a CFC, GILTI inclusion amounts
and taxes with respect to the tested
income group will generally be treated as
income and deemed paid taxes in the
section 951A category. See Regulations
sections 1.904-4(g) and 1.904-6(e).

GILTI high-tax exclusion, in the
appropriate column on line 4.
Example. For line 1(a)(1), $100 of gross
income is reported in column (ii), $35 of
foreign tax is reported in each of columns
(x) and (xii), and the checkbox in column
(xiv) is checked. For line 1(a)(2), $75 of
gross income is reported in column (ii), $5
of foreign tax is reported in each of
columns (x) and (xii), and the checkbox in
column (xiv) is not checked. For line 3(1),
$200 of gross income is reported in
column (ii), $70 of foreign tax is reported in
each of columns (x) and (xii), and the
checkbox in column (xiv) is checked. For
line 3(2), $150 of gross income is reported
in column (ii), $10 of foreign tax is reported
in each of columns (x) and (xii), and the
checkbox in column (xiv) is not checked.
For line 4(1), $300 of gross income is
reported in column (ii) and $105 of foreign
tax is reported in column (x). On line 4(1),
both columns (xii) and (xiv) should be
blank in all cases. As a result, the amount
reported on line 4 for column (ii) is the sum
of the amounts reported in column (ii) on
lines 1(a)(1), 3(1), and 4(1), which equals
$600 ($100 + $200 + $300). The amount
reported in column (x), line 4, is the sum of
the amounts reported in column (x) on
lines 1(a)(1), 3(1), and 4(1), which equals
$210 ($35 + $70 + $105). No amount
should be reported in column (xii) of line 4
as foreign tax on residual amounts are not
creditable. The amounts reported on
line 1(a)(1) would not be included in the
total for line 1(a), but the amount reported
on line 1(a)(2) would be included in the
total reported on line 1(a). Similarly, the
amounts reported on line 3(1) would not
be included in the total reported on line 3,
but the amounts reported on line 3(2)
would be reported in the total reported on
line 3.

DRAFT AS OF
March 10, 2023

Example. For line 1(a)(1), gross income
of $50 is reported in column (ii), foreign tax
of $20 is reported in each of columns (x)
and (xii), and the checkbox in column (xiv)
is checked. For line 1(a)(2), gross income
of $100 is reported in column (ii), $5 of
foreign tax is reported in each of columns
(x) and (xii), and the checkbox in column
(xiv) is not checked. For line 1(a)(3), gross
income of $75 is reported in column (ii), $3
of foreign tax is reported in each of
columns (x) and (xii), and the checkbox in
column (xiv) is not checked. As a result,
the amount reported in column (ii) on
line 1(a) is the sum of the amounts
reported in column (ii) on line 1(a)(2) and
1(a)(3), which is equal to $175 ($100 +
$75). The amounts reported in columns (x)
and (xii) on line 1(a) are the sum of the
amounts reported in each column on lines
1(a)(2) and 1(a)(3), which is equal to $8
($5 + $3). The items reported on line 1(a)
(1), gross income of $50 and $20 of
foreign tax, are not included in the totals
reported on line 1(a). These amounts are
included in the totals for each respective
column on line 4. As a result, the amount
reported on line 4, column (ii), is increased
by $50 and the amount reported in column
(x) on line 4 is increased by $20. No
amount is reported on line 4, column (xii),
because foreign income taxes attributable
to high-tax exception or high-tax exclusion
income are not creditable.
On lines 1k through 1m, enter
international boycott income described in
section 952(a)(3), illegal bribes,
kickbacks, and other payments described
in section 952(a)(4), and income included
in a section 901(j) separate category
described in section 952(a)(5). See
Regulations section 1.960-1(d)(2)(ii)(B)
(2).

Line 2. Recaptured Subpart F
Income

Enter income that is recaptured as subpart
F income in the current year. See section
952(c)(2).

Instructions for Form 5471 (Rev. 01-2023)

Line 4. Residual Income Group

Use line 4 to report the information
required in columns (i) through (xvi) that is
in a section 904 category but that is not of
a type that is included in one of the
subpart F income groups or a tested
income group and is therefore assigned to
the residual income group. See
Regulations section 1.960-1(d)(2)(ii)(D).
Enter the name of each QBU and enter the
information required for columns (i)
through (xvi) for each QBU on lines 4(1),
4(2), etc., but do not enter amounts
excluded from subpart F income under the
subpart F high-tax exception (those
amounts are reported on lines (1), (2), etc.
under lines 1a through 1i) or tested
income under the GILTI high-tax exclusion
(those amounts are reported on lines 3(1),
3(2), etc.). Enter the sum of the amounts
reported on lines 4(1), 4(2), etc., plus the
sum of amounts excluded from subpart F
income under the subpart F high-tax
exception and tested income under the

-39-

Column (i). Consistent with the reporting
requirement on Form 1118, enter the
two-letter code (from the list at IRS.gov/
CountryCodes) of each foreign country
and U.S. possession within which income
is sourced and/or to which taxes were
paid or accrued.
Column (ii). Enter the amount of gross
income of the CFC that is assigned to
each income group within each section
904 category.
Columns (iii) through (vii). Expenses.
Deductions of the CFC, including for
current year taxes, are allocated and
apportioned to the income groups to
determine net income (or loss) in each
income group and to identify the current
year foreign income taxes that relate to the
income in each income group for section
960 purposes. See Regulations sections
1.960-1(c)(1) and 1.960-1(d)(3)(ii). Enter
the expenses allocated and apportioned
to the item of gross income reported for
each QBU or tested unit as well as the

aggregate amount of such expenses
allocated and apportioned to each group.
See the instructions for lines 1 through 4.
Column (viii). Current year tax on reattributed income from disregarded payments. This column is used to report
current year tax imposed solely by reason
of the receipt of a disregarded payment
that is a reattribution payment. The current
year tax is allocated and apportioned to
the income group to which an amount of
gross income is assigned by reason of the
receipt of the reattribution payment. See
Regulations sections 1.960-1(d)(3)(ii)(A)
and 1.861-20(d)(3)(v)(B). Report current
year taxes allocated and apportioned to
the item of gross income reported for each
QBU or tested unit as well as the
aggregate amount of such foreign taxes in
each group. See the instructions for lines
1 through 4.

amount reported in column (xii) may not
be the same as the sum of the amounts in
columns (viii) through (x) if columns (viii)
through (x) include taxes that are not
creditable, including taxes paid or accrued
to sanctioned countries, foreign taxes
disallowed under section 901(k), (m), and
(l), and taxes paid or accrued to the United
States.

Schedule R

Schedule R is used to report basic
information pertaining to distributions from
foreign corporations. This information is
required by sections 245A, 959, and
986(c).

Name of Person Filing Form
5471

DRAFT AS OF
March 10, 2023

Column (ix). Current year tax on all
other disregarded payments. This
column is used to report current tax
imposed solely by reason of the receipt of
a disregarded payment other than a
reattribution payment, and which is
therefore either a remittance or a
contribution. See Regulations section
1.861-20(d)(3)(v)(C). Foreign tax imposed
by reason of a disregarded payment that
is a remittance is assigned to the income
groups based upon the assets of the
payor. See Regulations section
1.861-20(d)(3)(v)(C)(1). Foreign tax
imposed by reason of a disregarded
payment that is a contribution is assigned
to the residual grouping. See Regulations
section 1.861-20(d)(3)(v)(C)(2). Report
current year taxes allocated and
apportioned to the item of gross income
reported for each QBU or tested unit as
well as the aggregate amount of such
foreign taxes allocated and apportioned to
each group. See the instructions for lines
1 through 4.
Column (x). Other current year taxes.
Any other current year tax is allocated and
apportioned among the section 904
categories under the rules of Regulations
section 1.904-6(a) based on the portion of
the foreign taxable income (as
characterized under federal income tax
principles) that is assigned to a particular
section 904 category. Any other current
year foreign tax is allocated to the CFC
income group to which the items of foreign
gross income are assigned under the rules
of Regulations section 1.861-20. Report
current year taxes allocated and
apportioned to the item of gross income
reported for each QBU or tested unit as
well as the aggregate amount of such
foreign taxes allocated and apportioned to
each group. See the instructions for lines
1 through 4.

Column (xiii). Average asset value.
Foreign gross income that arises from a
disregarded payment that is treated as a
remittance for U.S. tax purposes is
assigned to an income group by reference
to the income groups to which the assets
of the payor taxable unit are assigned (or
would be assigned if the taxable unit were
a United States person) under the rules of
Regulations section 1.861-9 for purposes
of apportioning interest expense. This rule
uses the payor’s asset apportionment
percentages as a proxy for the
accumulated earnings of the payor taxable
unit from which the remittance is made.
For this purpose the assets of the taxable
unit making the remittance are determined
in accordance with the rules of
Regulations section 1.987-6(b) that apply
in determining the source and separate
category of exchange gain or loss on a
section 987 remittance, as modified in two
respects. See Regulations section
1.861-20(d)(3)(v)(C)(1). Report asset
values for each QBU or tested unit as well
as the aggregate amount of assets in each
group. See the instructions for lines 1
through 4.

Column (xiv). High-tax election. Check
the box in column (xiv) of the line
corresponding to any item of income with
respect to which the subpart F high-tax
exception applies. If any amount is
excluded under the subpart F high-tax
exception, do not include it in the total for
line 1a through 1j, but instead add the
amount to the total for line 4. See the
instructions for lines 1 and 4. If a GILTI
high-tax exclusion under Regulations
section 1.951A-2(c)(7)(viii) is effective with
respect to the CFC for the CFC inclusion
year, check the box in column (xiv) that
corresponds to the item(s) of income to
which the exception applies. If an amount
reported on line 3(1), 3(2), etc., is
excluded from gross income under the
GILTI high-tax exclusion, do not include it
in the total amount for line 3. Instead,
include the amounts in the total for line 4.
See the instructions for lines 3 and 4.
Column (xv). Loss allocation. This
column is used to report a reduction to
subpart F income in each applicable
income group when the foreign
corporation's subpart F income exceeds
current year E&P. See Regulations
sections 1.952-1(c) and (e) and 1.951A-6.

Column (xii). Foreign taxes for which
credit is allowed (U.S. dollars). The
-40-

The name of the person filing Form 5471
is generally the name of the U.S. person
described in the 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 of
Foreign Corporation

If applicable, use the reference ID number
shown on Form 5471, page 1, Item 1b(2).

Column (a): Description of distribution. The description should include
whether the distribution was cash or
noncash and taxable or nontaxable to
shareholders. Use code sections to
properly identify the taxable or nontaxable
consequences of the distribution. For
example, “taxable cash dividend eligible
for a dividends received deduction under
section 245A” or “nontaxable cash
distribution of PTEP.” Report parts of a
distribution on separate rows if the
distribution is partially taxable and partially
nontaxable, or if the distribution is either
taxable or nontaxable by reason of
different Code sections. For example, a
cash distribution of $100 that is a
nontaxable distribution of PTEP under
section 959(a) of $30, a taxable dividend
eligible for a dividends received deduction
under section 245A of $15, a taxable
dividend under section 301(c)(1) of $25, a
nontaxable distribution applied against
basis under section 301(c)(2) of $10, and
a taxable distribution treated as gain from
the sale or exchange of property under
section 301(c)(3) of $20, would be
reported on five rows.
If noncash distributions were made,
attach a statement and show both the tax
bases and fair market values.
Column (b): Date of distribution. Enter
the month, day, and year using the
following format: MM-DD-YYYY. For
example, June 30, 2022, would be
entered as “06-30-2022.”
Column (c): Amount of distribution in
foreign corporation's functional currency. The amount of a distribution is
generally the amount of any money paid to
the shareholder plus the fair market value
(FMV) of any property transferred to the
shareholder. However, this amount is

Instructions for Form 5471 (Rev. 01-2023)

reduced (but not below zero) by the
following liabilities.
• Any liability of the corporation the
shareholder assumes in connection with
the distribution.
• Any liability to which the property is
subject immediately before, and
immediately after, the distribution.

If PTEP were distributed, include on
Form 5471, Schedule I, line 6, any foreign
currency gain or loss on the distribution
that is recognized under section 986(c).
See the instructions for Form 5471,
Schedule I, Line 6 for details. With respect
to foreign currency gain or loss on a
distribution of GILTI: 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),
line 8z, or on the comparable line of other
noncorporate tax returns.

income of a U.S. shareholder under
section 951(a)(1) or section 951A.
Note. Amounts entered in Schedule R
(Form 5471), column (d) are also included
on line 9, column (f) of Schedule J (Form
5471) and Part I, line 8 of Schedule P
(Form 5471), both of which are completed
by separate category of income. If the filer
is required to complete Schedule J (Form
5471) with respect to more than one
category of income, the total of all
amounts entered in Schedule R (Form
5471), column (d) should equal the
amount entered on line 9, column (f) of the
Schedule J (Form 5471) that is filed with
code “TOTAL” entered on line a of that
Schedule J.

DRAFT AS OF
March 10, 2023

Column (d): Amount of E&P distribution in foreign corporation's functional
currency. A corporate distribution to a
shareholder is generally treated as a
distribution of earnings and profits. Report
distributions from current and
accumulated earnings and profits. Do not
report any part of a distribution that is not
from earnings and profits.
An actual distribution is first out of
PTEP, if any, and then out of the section
959(c)(3) balance. See section 959(c).

Note. E&P described in section 959(c)(3)
is generally E&P of the foreign corporation
that has not been included in gross

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.

Instructions for Form 5471 (Rev. 01-2023)

-41-

Principal Business Activity Codes
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
principal business activity codes are based on the North
American Industry Classification System.

Agriculture, Forestry, Fishing,
and Hunting

238900

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
retains title to the product, the company is considered a
manufacturer and must use one of the manufacturing
codes (311110-339900).
painting, wallcovering, flooring,
tile, & finish carpentry)
Other Specialty Trade
Contractors (including site
preparation)

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.

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 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

339900

Other Miscellaneous
Manufacturing

Wholesale Trade

DRAFT AS OF
March 10, 2023

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 (including farriers)
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,

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
315250 Cut & Sew Apparel Mfg (except
Contractors)
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
326200 Rubber Product Mfg

-42-

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 Products & Electronic
Cigarettes
424950 Paint, Varnish, & Supplies
424990 Other Miscellaneous Nondurable
Goods
Wholesale Trade Agents and Brokers
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
441227 Motorcycle, ATV, & All other
Motor Vehicle Dealers
441300 Automotive Parts, Accessories,
& Tire Retailers
Building Material and Garden
Equipment and Supplies Dealers
444110 Home Centers
444120 Paint & Wallpaper Retailers
444140 Hardware Retailers
444180 Other Building Material Dealers
444200 Lawn & Garden Equipment &
Supplies Retailers
Food and Beverage Retailers
445110 Supermarkets and Other
Grocery Retailers (except
Convenience)
445131 Convenience Retailers
445132 Vending Machine Operators
445230 Fruit & Vegetable Retailers
445240 Meat Retailers
445250 Fish & Seafood Retailers
445291 Baked Goods Retailers
445292 Confectionery & Nut Retailers
445298 All Other Specialty Food
Retialers
445320 Beer, Wine, & Liquor Retailers

Principal Business Activity Codes (Continued)
Furniture and Home Furnishings
Retailers
449110 Furniture Retailers
449121 Floor Covering Retailers
449122 Window Treatment Retailers
449129 All Other Home Furnishings
Retailers
Electronics and Appliance Retailers
449210 Electronic & Appliance Retailers
(including computers)
General Merchandise Retailers
455110 Department Stores
455210 Warehouse Clubs,
Supercenters,& Other General
Merch. Retailers
Health and Personal Care Retailers
456110 Pharmacies & Drug Retailers
456120 Cosmetics, Beauty Supplies, &
Perfume Retailers
456130 Optical Goods Retailers
456190 Other Health & Personal Care
Retailers
Gasoline Stations & Fuel Dealers
457100 Gasoline Stations (including
convenience stores with gas)
457210 Fuel Dealers (including Heating
Oil & Liquefied Petroleum)
Clothing and Accessories Retailers
458110 Clothing & Clothing Accessories
Retailers
458210 Shoe Retailers
458310 Jewelry Retaileres
458320 Luggage & Leather Goods
Retailers
Sporting, Hobby, Book, Musical
Instrument & Miscellaneous Retailers
459110 Sporting Goods Retailers
459120 Hobby, Toy, & Game Retailers
459130 Sewing, Needlework, & Piece
Goods Retailers
459140 Musical Instrument & Supplies
Retailers
459210 Book Retailers & News Dealers
(including newsstands)
459310 Florists
459410 Office Supplies & Stationery
Retailers
459420 Gift, Novelty, & Souvenir
Retailers
459510 Used Merchandise Retailers
459910 Pet & Pet Supplies Retailers
459920 Art Dealers
459930 Manufactured (Mobile) Home
Dealers
459990 All Other Miscellaneous Retailers
(including tobacco, candle, &
trophy retailers)
Nonstore Retailers
various Nonstore retailers sell all types of
merchandise using such
methods as Internet, mail-order
catalogs, interactive television, or
direct sales. These types of
Retailers should select the PBA
associated with their primary line
of products sold. For example,
establishments primarily selling
prescription and non-prescription
drugs, select PBA code 456110
Pharmacies & Drug Retailers.

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 & Express Delivery
Services
492210 Local Messengers & Local
Delivery
Warehousing and Storage
493100 Warehousing & Storage (except
lessors of mini-warehouses &
self-storage units)

Insurance Carriers and Related
Activities
524110 Direct Life, Health, & Medical
Insurance Carriers
524120 Direct Insurance (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.

541380 Testing Laboratories & Services
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, Public Relations, &
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

DRAFT AS OF
March 10, 2023

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 Limousine Service
485410 School & Employee Bus
Transportation
485510 Charter Bus Industry
485990 Other Transit & Ground
Passenger Transportation

Information

Motion Picture and Sound Recording
Industries
512100 Motion Picture & Video Industries
(except video rental)
512200 Sound Recording Industries
Publishing Industries
513110 Newspaper Publishers
513120 Periodical Publishers
513130 Book Publishers
513140 Directory & Mailing List
Publishers
513190 Other Publishers
513210 Software Publishers
Broadcasting & Content Providers &
Telecommunications
516100 Radio & Television Broadcasting
Stations
516210 Media Streaming, Social
Networks, & Other Content
Providers
517000 Telecommunications (including
Wired, Wireless, Satellite, Cable
& Other Program Distribution,
Resellers, Agents & Other
Telecommunications, & Internet
Service Providers)
Data Processing, Web Search Portals,
& Other Information Services
518210 Computing Infrastructure
Providers, Data Processing, Web
Hosting & Related Services
519200 Web Search Portals, Libraries,
Archives, & Other Info. Services

Finance and Insurance

Depository Credit Intermediation
522110 Commercial Banking
522130 Credit Unions
522180 Savings Institutions & 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)
522299 Intl, Secondary Market, & Other
Nondepos. 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
523150 Investment Banking & Securities
Intermediation
523160 Commodity Contracts
Intermediation
523210 Securities & Commodity
Exchanges
523900 Other Financial Investment
Activities (including portfolio
management & investment
advice)

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
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

-43-

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)

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)

Principal Business Activity Codes (Continued)
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
624410

721191
721199

Vocational Rehabilitation
Services
Childcare 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)

Bed & Breakfast Inns
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, Grill buffets, & Buffets
722515 Snack & Nonalcoholic Beverage
Bars

811420
811430

Reupholstery & Furniture Repair
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)

DRAFT AS OF
March 10, 2023
Accommodation and Food
Services

Accommodation
721110 Hotels (except Casino Hotels) &
Motels
721120 Casino Hotels

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
Automotive & Electronic) Repair
& Maintenance
811410 Home & Garden Equipment &
Appliance Repair & Maintenance

-44-

Other

999000

Unclassified Establishments
(unable to classify)