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Instructions for Form 5471
Department of the Treasury
Internal Revenue Service
(Rev. January 2025)
(Use with the December 2024 revision of Form 5471 and separate Schedules H-1
and Q; the December 2023 revision of separate Schedule G-1; the December 2021
revision of separate Schedules E, 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.)
TREASURY/IRS
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Information Return of U.S. Persons
With Respect to Certain Foreign Corporations
What’s New
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 H-1 . . . . . . . . . . . . . . . .
Schedule I-1 . . . . . . . . . . . . . . . . .
Schedule J . . . . . . . . . . . . . . . . . .
Schedule M . . . . . . . . . . . . . . . . .
Schedule O . . . . . . . . . . . . . . . . .
Schedule P . . . . . . . . . . . . . . . . .
Schedule Q . . . . . . . . . . . . . . . . .
Schedule R . . . . . . . . . . . . . . . . .
Principal Business Activity Codes .
Future Developments
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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.
Oct 7, 2024
Changes to Form 5471. On page 6 of the form, new
lines 20a and 20b request information pertaining to any
Top-up Tax paid or accrued.
New separate Schedule H-1. This new schedule is
used to report a CFC's adjusted net income or loss for
corporate alternative minimum tax (CAMT) purposes. This
new schedule replaces Worksheet H-1 (which appeared
on page 37 of the January 2024 Instructions for Form
5471), with modifications.
Changes to separate Schedule Q. On page 4 of the
schedule, the shading for line 4, column (xv), was deleted.
As a result, the sum of loss allocations for subpart F
excluded groups can be entered in the new entry space
created by the deletion of the shading.
Changes to these instructions. These instructions
have been updated for the aforementioned changes to
Form 5471 and separate Schedule Q. In addition,
instructions for previous Worksheet H-1 have been
updated and are included in the instructions for new
Schedule H-1.
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, Schedules E, I-1, J, P, and Q), inclusion
of a single instance of that schedule for any separate
category will meet the requirement.
Cat. No. 49959G
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, H-1, I-1, J, M, P, Q, and R.
Note. Complete a separate Form 5471 and all applicable
schedules for each applicable foreign corporation.
Category 1a Filer
A Category 1a filer is a Category 1 filer that is not a
Category 1b or 1c filer.
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 (defined below). 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 I.R.B. 982, to similarly situated
Category 1 filers.
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When and Where To File
Attach Form 5471 to your income tax return (or, if
applicable, partnership or exempt organization return) and
file both by the due date (including extensions) for that
return.
Categories of Filers
Category 1 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.
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 controlled foreign corporation (CFC) (see
Category 5 Filers, later, for definition); or
2. Any foreign corporation with respect to which one or
more domestic corporations are U.S. shareholders.
However, if a passive foreign investment company
(PFIC) (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.
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 (defined below) of a
foreign-controlled section 965 SFC (defined below). 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 I.R.B. 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 under Category
1b Filer, earlier.
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:
• The section 965 SFC (or foreign-controlled section 965
SFC) has accumulated earnings and profits (E&P) related
Instructions for Form 5471 (Rev. 01-2025)
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).
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.
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.
Category 2 Filer
This category includes a U.S. citizen or resident who is an
officer or director of a foreign corporation in which a U.S.
person (defined below) has acquired (in one or more
transactions):
1. Stock that meets the 10% stock ownership
requirement (defined below) with respect to the foreign
corporation, or
2. An additional 10% or more (in value or voting
power) of the outstanding stock of the foreign corporation.
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• 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 Regulations section 1.6038-2(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 I.R.B. 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.
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 I.R.B. 982, and extends it to Category 1
filers.
Other filing exceptions. Certain other filing exceptions
apply to all categories of filers. See Additional Filing
Exceptions, later.
Instructions for Form 5471 (Rev. 01-2025)
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.
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.
3
Other filing exceptions. Certain other filing exceptions
apply to all categories of filers. See Additional Filing
Exceptions, later.
must file Form 5471 and a separate Schedule O to report
changes in the ownership of the FSC.
Category 3 Filer
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.
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.
This category includes:
1. A U.S. person (defined below) 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 (defined below) 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.
Category 3 Filers—Exception From Filing
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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).
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)
4
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, later.
Category 4 Filer
This category includes a U.S. person (defined below) who
had control (defined below) of a foreign corporation during
the annual accounting period of the foreign corporation.
U.S. person. For purposes of Category 4, a U.S. person
is:
1. A citizen or resident of the United States;
2. A nonresident alien for whom an election is in effect
under section 6013(g) to be treated as a resident of the
United States;
3. An individual for whom an election is in effect under
section 6013(h), relating to nonresident aliens who
become residents of the United States during the tax year
and are married at the close of the tax year to a citizen or
resident of the United States;
4. A domestic partnership;
5. A domestic corporation; and
6. An estate or trust that is not a foreign estate or trust,
as defined in section 7701(a)(31).
See Regulations section 1.6038-2(d) for exceptions.
Control. 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.
Instructions for Form 5471 (Rev. 01-2025)
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 section
1.6038-2(b) and (c).
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 respect to the FSC under section 951(a)
(as described above).
Additional Information for Category 4 Filers
Other filing exceptions. Certain other filing exceptions
apply to all categories of filers. See Additional Filing
Exceptions, later.
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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;
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 section 927(c) and (d)(1), as in effect before its
repeal); and
3. All other FSC income that is not foreign trade
income or investment income or carrying charges.
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.
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 Regulations section 1.6038-2(l) for
additional information.
Instructions for Form 5471 (Rev. 01-2025)
Category 5 Filers
In general, a Category 5 filer is a person who was a U.S.
shareholder (defined below) that owned stock in a foreign
corporation that was a CFC (defined below) 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 (defined below) who:
1. 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 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 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
5
CFC includes a foreign corporation described in section
953(c)(1)(B).
Category 5a Filer
A Category 5a filer is a Category 5 filer that is not a
Category 5b or 5c filer.
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 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 section 927(c) and (d)(1), as in effect before its
repeal); and
3. All other FSC income that is not foreign trade
income or investment income or carrying charges.
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Category 5b Filer
A person is a Category 5b filer if they are an unrelated
section 958(a) U.S. shareholder (defined below) of a
foreign-controlled CFC (defined below). 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 I.R.B. 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 (defined below) of a
foreign-controlled CFC (defined below). 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 I.R.B. 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 CFC” has the same meaning
as defined in Category 5b Filer, earlier.
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;
6
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.
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 Regulations section 1.6038-2(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 I.R.B. 341, for additional
information.
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.
Instructions for Form 5471 (Rev. 01-2025)
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 I.R.B.
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 next.
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
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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
Separate Schedule H-1
3
3
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. shareholder. only need to complete Schedule E (they can leave Schedule E-1 blank). See Rev. Proc. 2019-40 for more details.
3
Schedule H-1 is required for any U.S. shareholder that is an applicable corporation for corporate alternative minimum tax (CAMT) purposes. See Instructions for
Form 4626.
Instructions for Form 5471 (Rev. 01-2025)
7
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 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.
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.
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Domestic corporations. Shareholders are not required
to file Form 5471 for a foreign insurance company that has
elected (under section 953(d)) to be treated as a domestic
corporation and has filed a U.S. income tax return for its
tax year under that provision. See Rev. Proc. 2003-47,
2003-28 I.R.B. 55, available at IRS.gov/irb/
2003-28_IRB#RP-2003-47, for procedural rules regarding
the election under section 953(d).
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:
• 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 CFC
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 tax year that includes the acquisition date (see the
Instructions for Form 8023 for details).
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.
8
For more information, see Regulations section
1.6011-4. Also, see the Instructions for Form 8886.
Penalties. The U.S. shareholder may have to pay a
penalty if it is required to disclose a reportable transaction
under section 6011 and fails to properly complete and file
Form 8886. Penalties 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.
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.
Instructions for Form 5471 (Rev. 01-2025)
See Regulations sections 1.6038-1(j)(4) and 1.6038-2(k)
(3) for alleviation of this penalty in certain cases.
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.
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 employer identification number
(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).
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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.
Example. During its annual accounting period, the
foreign corporation paid income taxes of 30,255,400 Yen
Instructions for Form 5471 (Rev. 01-2025)
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
C:DC:TS:CAR:MP:P:TP
1111 Constitution Ave. NW
Room 6554
Washington, DC 20224
Exception. If a computer-generated Form 5471 and its
schedules conform to and do not deviate from the official
form and schedules, they may be filed without prior
approval from the IRS.
Important. Be sure to attach the approval letter to Form
5471. However, if the computer-generated form is
identical to the IRS-prescribed form, it does not need to go
through the approval process, and an attachment is not
necessary.
Every year, the IRS issues a revenue procedure to
provide guidance for filers of computer-generated forms.
In addition, every year, the IRS issues Pub. 1167, General
Rules and Specifications for Substitute Forms and
Schedules, which reprints the most recent applicable
revenue procedure. Pub. 1167 is available at IRS.gov/Pub.
1167.
Dormant Foreign Corporations
Rev. Proc. 92-70, 1992-2 C.B. 435, provides a summary
filing procedure for filing Form 5471 for a dormant foreign
corporation (defined in section 3 of Rev. Proc. 92-70). This
summary filing procedure will satisfy the reporting
requirements of sections 6038 and 6046.
If you elect the summary procedure, complete only
page 1 of Form 5471 for each dormant foreign corporation
as follows.
9
• 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.
Specific Instructions
Important. If the information required in a given section
exceeds the space provided within that section, do not
enter “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.
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File this summary return in the manner described under
When and Where To File, earlier.
Identifying Information
Treaty-Based Return Positions
Annual Accounting Period
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.
CAUTION
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. Enter “Corrected” at the top of the form and
attach a statement identifying the changes.
Foreign Disregarded Entities and Branches
If the foreign corporation for which you are furnishing
information is the tax owner of a foreign disregarded entity
(FDE) or foreign branch (FB), or a partner in a partnership,
the amounts reported on Form 8858, Schedules K-1 and
K-3 of Form 1065, or Schedules K-1 and K-3 of Form
8865 must be included in determining the amounts
reported on Form 5471. 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.
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 for any purpose 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#RP-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.
Name of Person Filing This Return
The name of the person filing Form 5471 is generally the
name of the U.S. person described in the applicable
category or categories of filers (see Categories of Filers,
earlier). However, in the case of a consolidated return,
enter the name of the U.S. parent in the field for “Name of
person filing this return.” Be sure to list each U.S.
shareholder of the foreign corporation in Schedule B, Part
I.
Name change. If the name of either the person filing the
return or the corporation whose activities are being
reported changed within the past 3 years, show the prior
name(s) in parentheses after the current name.
Address
Include the suite, room, or other unit number after the
street address. If the post office does not deliver mail to
10
Instructions for Form 5471 (Rev. 01-2025)
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
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.
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The identifying number of an individual is his or her social
security number (SSN). The identifying number of all
others is their 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.
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.
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 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.
Item D—Final Year
Item G—Alternative Information Code
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
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 occurred, or an
election to treat the foreign corporation as a disregarded
entity has been made. If this item D is checked, complete
Schedule O.
Item E—Excepted Specified Foreign Financial
Assets
Check the item E checkbox if any excepted specified
foreign financial assets are reported on Form 5471. If this
is the case, you do not have to also report these assets on
Form 8938. 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.
Item F—Alternative Information Under Rev. Proc.
2019-40
Check the item F checkbox 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
Instructions for Form 5471 (Rev. 01-2025)
If the item F checkbox is checked, enter the applicable
code from the list provided below.
Audited separate-entity financial statements of the foreign
01 corporation that are prepared in accordance with U.S. generally
accepted accounting principles (U.S. GAAP).
Audited separate-entity financial statements of the foreign
02 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
03
accepted accounting principles of the jurisdiction in which the
foreign corporation is organized (“local-country GAAP”).
04
Unaudited separate-entity financial statements of the foreign
corporation that are prepared in accordance with U.S. GAAP.
05
Unaudited separate-entity financial statements of the foreign
corporation that are prepared on the basis of IFRS.
06
Unaudited separate-entity financial statements 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 corporation for
08 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,
11
information described in code 03 above qualifies as
alternative information only if information described in
codes 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
reference ID number in item 1b(2). If applicable, enter the
reference ID number you have assigned to the foreign
corporation identified in item 1a.
A “reference ID number” is a number established by or
on behalf of the U.S. person identified at the top of page 1
of the form that is assigned to a foreign corporation with
respect to which Form 5471 reporting is required. These
numbers are used to uniquely identify the foreign
corporation in order to keep track of the corporation from
tax year to tax year.
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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).
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.
A separate Schedule H-1 must be attached for each
person described in Category 4, 5a, 5b, or 5c. For each
Category 4, 5a, 5b, or 5c filer that is required to file
Schedule H-1, send a copy of their separate
Schedule H-1 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 Schedule P (Form 5471) if the person is
CAUTION 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 in item
1b(2) only in cases where no EIN was entered in item
1b(1) for the foreign corporation. However, filers are
permitted to enter both an EIN in item 1b(1) and a
12
The reference ID number must meet the requirements
set forth below.
Note. Because reference ID numbers are established by
or on behalf of the U.S. person filing Form 5471, there is
no need to apply to the IRS to request a reference ID
number or for permission to use these numbers.
Note. The reference ID number assigned to a foreign
corporation on Form 5471 generally has relevance only on
Form 5471, its schedules, and any other form that is
attached to or associated with Form 5471, and generally
should not be used with respect to that foreign corporation
on any other IRS forms. However, the foreign corporation’s
reference ID number should also be entered on Form
8858 if the foreign corporation is listed as a tax owner of
an FDE or 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 below) 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.
Correlation issues. There are some situations that
warrant correlation of a new reference ID number with a
previous reference ID number when assigning a new
reference ID number to a foreign corporation. For
example:
• In the case of a merger or acquisition, a Form 5471 filer
must use a reference ID number that correlates the
Instructions for Form 5471 (Rev. 01-2025)
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
in item 1b(1) of Form 5471 and the old reference ID
number must be entered in item 1b(2). In subsequent
years, the Form 5471 filer may continue to enter both the
EIN in item 1b(1) and the reference ID number in item
1b(2), but must enter at least the EIN in item 1b(1).
You must correlate the reference ID numbers as
follows: Enter the new reference ID number in item 1b(2)
and enter the previous reference ID number(s) in item
1b(3). 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.
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
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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, items 1b(2) and 1b(3). On all
separate schedules for Form 5471, please enter only the
current reference ID number in the applicable entry space.
Item 1b(3)—Previous Reference ID Number(s), if
Any
See Correlation issues, earlier.
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.
Effective beginning with tax year 2022, several
changes were made to the principal business
CAUTION 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 six-group.com/en/productsservices/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.
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 Schedule C, Schedule F, and Schedule H, later.
Instructions for Form 5471 (Rev. 01-2025)
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 I, for U.S. persons that owned
(on the last day of the foreign corporation’s tax 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 an 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.
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.
Schedule C
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
13
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 Lines 23 and
24, later. Enter unrealized gain or loss on line 8a and
realized gain or loss on line 8b.
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.
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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 and deferred income tax
expense (benefit) on line 21b.
Note. If there is an income tax expense amount on
line 21a or 21b, subtract that amount from the line 19 net
income or (loss) amount in arriving at line 22 current year
net income or (loss) per the books. If there is an income
tax benefit amount on line 21a or 21b, add that amount to
the line 19 net income or (loss) amount in arriving at
line 22 current year net income or (loss) per the books.
Lines 23 and 24. Enter amounts defined in ASC 220
(Income Statement—Reporting Comprehensive Income).
Line 23a. Enter foreign currency translation
adjustments before the income tax expense (benefit) is
allocated.
Line 23b. Enter other comprehensive income such as
foreign currency gains or losses on certain hedging
transactions, pensions and other post-retirement benefits,
and certain investments available-for-sale.
Line 23c. Enter the income tax expense (benefit)
allocated to OCI items in the intraperiod allocation.
Important. Differences between the functional currency
amount of income tax expense (benefit) reported on
line 21 and the amount of taxes that reduce or increase
U.S. 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
14
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.
Question 3
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 you
are required to attach Form 8858 to Form 5471, the
amounts reported on certain schedules on Form 8858
must be included in determining the amounts reported on
the equivalent schedules as follows.
IF amounts were reported on...
THEN take those amounts into
account (converting from GAAP to
tax as necessary) when
determining the amounts to be
reported on...
Form 8858, Schedule C
Form 5471, Schedule C.
Form 8858, Schedule F
Form 5471, Schedule F.
Form 8858, Schedule H
Schedule H (Form 5471).
Form 8858, Schedule J
Schedules E and E-1 (Form 5471).
Schedule M (Form 8858)
Schedule M (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.
Instructions for Form 5471 (Rev. 01-2025)
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.
foreign-derived intangible income (FDII), and enter the
amounts requested on lines 6b, 6c, and 6d. Enter U.S.
dollar amounts on lines 6b, 6c, and 6d, translated from
functional currency at the average exchange rate for the
foreign corporation's tax year (see section 989(b)). See
Form 8993 and its instructions for information on the
section 250 deduction. If no deduction is being claimed,
check the “No” box on line 6a and go to line 7.
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The term “base erosion payment” generally means any
amount paid or accrued by the U.S. filer to a foreign
corporation that is a related party to the U.S. filer within the
meaning of section 59A(g) and with respect to which a
U.S. deduction is allowed under chapter 1 of the Code.
See section 59A(d)(1). Base erosion payments also
include amounts received or accrued by the foreign
corporation in connection with the acquisition of
depreciable or amortizable property (section 59A(d)(2)),
reinsurance payments (section 59A(d)(3)), and certain
payments relating to expatriated entities (section 59A(d)
(4)).
The term “base erosion tax benefit” generally means
any U.S. deduction 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.
Questions 5a and 5b
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.
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
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.
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 (Form
5471), 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.
Check the “Yes” box on line 6a if the filer is claiming a
deduction under section 250 with respect to
Instructions for Form 5471 (Rev. 01-2025)
15
Form 5471, Schedule G, Line 14
Question
See Worksheet A in If “Yes,”
Code
the Schedule I
corresponding description
instructions
code to enter
on Schedule G,
line 14
If “Yes,” content of
statement to be
attached to Form
5471
1
During the tax year, was the sum of the CFC’s foreign base
company income (determined without regard to deductions)
and gross insurance income less than the lesser of 5% of
gross income or $1 million?
In other words, is
line 7 less than line 8
and less than $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
(a) arise out of commodity hedging transactions; (b) 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 (c) 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?
BN
Business
needs
Amount excluded
6
During the tax year, did the CFC receive, from a person other
than a related person within the meaning of section 954(d)(3),
rents or royalties that were derived in the active conduct of a
trade or business?
In other words, are
any amounts
described in section
954(c)(2)(A)
excluded from line 1a
of Worksheet A?
ARR
Active rents/
royalties
Amount excluded
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?
EF
Certain
export
financing
Amount excluded
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?
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
16
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Instructions for Form 5471 (Rev. 01-2025)
Form 5471, Schedule G, Line 14 (continued)
Question
See Worksheet A in
the Schedule I
instructions
If “Yes,”
corresponding
code to enter
on Schedule G,
line 14
Code
description
If “Yes,” content
of statement to be
attached to Form
5471
In other words, are
any amounts
described in section
954(c)(2)(C)(ii)
excluded from line 1a
of Worksheet A?
SD
Securities
dealers
Amount excluded
10 During the tax year, did the CFC receive dividends* or
interest** from a related person that (a) 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 (b) 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 E&P 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 (a) and (b)).
**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?
*Interest, rents, or royalties (other than interest, rents, or
royalties that create or increase a deficit that may reduce the
subpart F income of the payor or another CFC).
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, a
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, a
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
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?
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Instructions for Form 5471 (Rev. 01-2025)
Same country Amount excluded
manufacturing
17
Form 5471, Schedule G, Line 14 (continued)
Question
See Worksheet A in If “Yes,”
the Schedule I
corresponding
instructions
code to enter
on Schedule G,
line 14
Code
description
If “Yes,” content
of statement to be
attached to Form
5471
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 Amount excluded
sales/use
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
Amount excluded
manufacturing
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 (a) 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 (b) 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 defined in section 953(e)(3)) that derived
qualified insurance income (as defined in section 954(i)(2))?
In other words, are
any amounts
excluded from 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
18
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Instructions for Form 5471 (Rev. 01-2025)
Form 5471, Schedule G, Line 14 (continued)
Question
22
In determining the pro rata share of subpart F income or
tested items of the U.S. person filing this return, was the
amount of distributions by the CFC during the tax year and
described in section 951(a)(2)(B) greater than zero?
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)?
See Worksheet A in If “Yes,”
the Schedule I
corresponding
instructions
code to enter
on Schedule G,
line 14
Code
description
If “Yes,” content
of statement to be
attached to Form
5471
In other words, is
line 58 of Worksheet
A greater than zero?
Pro Rata
Share
The amounts from
lines 58 and 59 of
Worksheet A
Other
Amount excluded,
reduction amount,
or other amount not
reported or
reportable
PRS
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XX
Question 15
Question 18a
Question 16
Question 18b
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.
For the foreign corporation’s annual accounting period
with respect to which reporting is being made on this Form
5471, if the foreign corporation is required to file a U.S.
income tax return (for example, Form 1120-F), check the
“Yes” box if the foreign corporation has previously
disallowed interest expense under section 163(j) carried
forward to the current tax year. If “Yes,” enter the amount
from the prior year Form 8990, line 31.
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 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).
Instructions for Form 5471 (Rev. 01-2025)
Check the “Yes” box if during the tax year the filer had any
loans to or from the foreign corporation to which the
safe-haven rate rules of Regulations section 1.482-2(a)(2)
(iii)(B) are applicable, and for which the filer used a rate of
interest within the relevant safe-haven range of
Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to
130% of the applicable federal rate for the relevant term).
Check the “Yes” box if during the tax year the filer had any
loans to or from the foreign corporation to which the
safe-haven rate rules of Regulations section 1.482-2(a)(2)
(iii)(B) are applicable, and for which the filer used a rate of
interest outside the relevant safe-haven range of
Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to
130% of the applicable federal rate for the relevant term).
Questions 19a and 19b
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).
Question 19a
Check the “Yes” box if the filer issued a covered debt
instrument in any of the transactions described in
Regulations section 1.385-3(b)(2) with respect to the
foreign corporation during the tax year. Also check the
“Yes” box if the filer issued or refinanced indebtedness
owed to a foreign corporation during the 36 months before
or after the date of a distribution or acquisition described
in Regulations section 1.385-3(b)(3)(i) made by the filer,
and either the issuance or refinance of indebtedness, or
the distribution or acquisition, occurred during the tax
year. 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). Apply Regulations section 1.385-3(f) in
the case of a controlled partnership within the meaning of
Regulations section 1.385-1(c)(1).
Debt that the filer treats as stock pursuant to
Regulations section 1.385-3 should still be included when
completing line 19a.
19
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 (FMV) 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
FMV of the property distributed and/or acquired).
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).
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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
sections 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).
Questions 20a and 20b
Certain jurisdictions have enacted legislation to implement
the GloBE Model Rules for the Qualified Domestic
Minimum Top-up Tax (QDMTT), Income Inclusion Rule
(IIR), and UTPR. See Org. for Econ. Coop. & Dev.
[OECD], Tax Challenges Arising from the Digitalization of
the Economy - Global Anti-Base Erosion Model Rules
(Pillar Two) (Dec. 14, 2021), DOI.org/10.1787/782bac33en. Under these rules, if the Effective Tax Rate (ETR) for a
jurisdiction is below 15%, Top-up Tax may be imposed.
The amount of Top-up Tax is determined by multiplying
the Top-up Tax Percentage (the positive excess of 15%
over the ETR in the jurisdiction) by the Excess Profits (the
positive amount of the Net GloBE Income in such
jurisdiction that exceeds a Substance-based Income
Exclusion). The Top-up Tax is collected under the QDMTT,
IIR, and/or UTPR.
If the foreign corporation paid or accrued any Top-up
Tax during the tax year, check the "Yes" box for Question
20a on page 6 of the form and enter the amount of
QDMTT, IIR, and/or UTPR (or similar tax) paid or accrued
during the tax year in the space provided on lines 20b(1),
20b(2), and 20b(3).
For more information, see Notice 2023-80, I.R.B.
2023-52 1583 available at IRS.gov/IRB/
2023-52_IRB#NOT-2023-80.
Schedule I
Use Schedule I to report in U.S. dollars the U.S.
shareholder's pro rata share of income from the foreign
corporation reportable under subpart F and other income
realized from a corporate distribution.
Certain filers may be able to use alternative information
(as defined in section 3.01 of Rev. Proc. 2019-40) to
determine certain amounts in this schedule. See 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
20
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.
Line 1c
Enter the U.S. shareholder's 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.
Line 1d
Enter the U.S. shareholder's 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.
Instructions for Form 5471 (Rev. 01-2025)
Use Worksheet A 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.
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.
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• Adjusted net foreign base company income (Worksheet
A, lines 1 through 17).
• Adjusted net insurance income (Worksheet A, line 18).
• Adjusted net related person insurance income
(Worksheet A, line 19).
• International boycott income (Worksheet A, line 20).
• Illegal bribes, kickbacks, and other payments
(Worksheet A, line 21).
• Income described in section 952(a)(5) (Worksheet A,
line 22).
Important. If the subpart F income of a 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 the U.S.
shareholder's pro rata share of such recapture amount to
the result from Worksheet A, line 69, and include the
combined amount on line 1h (Other subpart F income).
See Line 37. Current E&P limitation, later, for a discussion
of the current year E&P limitation. See also Regulations
section 1.952-1(f) for further guidance on
recharacterization of E&P as subpart F income.
Line 2
Report on line 2 the section 956 amount with respect to
the U.S. shareholder. See Worksheet B, line 19.
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 the section 245A
dividends received deduction.
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.
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.
Reserved for future use.
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 4
Line 5d
Line 3
Enter the U.S. shareholder's pro rata share of 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
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 results on Schedule 1 (Form 1040),
line 8n (other income - section 951(a) inclusion), or on the
comparable line of other noncorporate tax returns.
Instructions for Form 5471 (Rev. 01-2025)
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.
21
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 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.
Line 8a
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.
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
22
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.
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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 8c
differences between the starting and ending balances
reported on line 8c.
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.
A domestic corporation that is a U.S. shareholder with
respect to a CFC must maintain a hybrid deduction
account with 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.
Instructions for Form 5471 (Rev. 01-2025)
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
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))
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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 (Rev. 01-2025)
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
23
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
33
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)) . . . . . . . . . . . . . . . . . .
Illegal bribes, kickbacks, and other payments (section 952(a)(4)) . . . . . . . . . . . . .
Income described in section 952(a)(5) (see instructions)
. . . . . . . . . . . . . . .
Subpart F income before application of section 952(b) and (c), section 959(b), and section 961(c). 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) and section 961(c) basis 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
-0Exclusions 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 connected
with a U.S. trade or business (section 952(b)) . . . . . . . . . . .
30
-0Exclusions 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
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18e
19e
20
21
22
23
26
29
32
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 (section
952(b)) . . . . . . . . . . . . . . . . . . . . . . . .
33
Exclusions under section 959(b) that apply to line 16e, 18e, 19e, 20, 21, and
22 amounts . . . . . . . . . . . . . . . . . . . . . .
34
35
Other subpart F income. Subtract the sum of lines 33 and 34 from the sum of lines
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 . . . . . . . . . . . . . . . .
34
24
16e, 18e, 19e,
. . . . .
. . . . .
.
.
.
.
.
35
36
38
Instructions for Form 5471 (Rev. 01-2025)
Worksheet A
Worksheet A (continued) (See instructions.)
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
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.
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal . . . . . . . .
40
Section 954(d) subpart F Foreign Base Company Sales Income subtotal . . . . . . . . . .
41
Section 954(e) subpart F Foreign Base Company Services Income subtotal . . . . . . . . .
42
Other subpart F income subtotal . . . . . . . . . . . . . . . . . . . . . . .
43
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
46
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
49
Shareholder’s pro rata share of line 42 . . . . . . . . . . . . .
50
Shareholder’s pro rata share of export trade income that applies to line 50
51
amount (see section 970(a)) . . . . . . . . . . . . . . . . .
Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from line
50 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
52
Shareholder’s pro rata share of line 43 . . . . . . . . . . . . .
53
Shareholder’s pro rata share of export trade income that applies to line 53
amount (see section 970(a)) . . . . . . . . . . . . . . . . .
54
Other subpart F income subtotal. Subtract line 54 from line 53 . . . . . . . . . . . . .
55
Add lines 46, 49, 52, and 55 . . . . . . . . . . . . . . . . . . . . . . . . .
56
Divide the number of days in the tax year that the corporation was a CFC by
57
the number of days in the tax year and multiply the result by line 56 . . . .
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The amount of dividends received by any other person with respect to your
stock multiplied by a fraction, the numerator of which is the CFC's subpart F
income for the tax year and the denominator of which is the sum of the CFC's
subpart F income and tested income (section 951A(c)(2)(A) and Regulations
section 1.951A-2(b)(1)) for the tax year . . . . . . . . . . . . .
58
Divide the number of days in the tax year you did not own such stock by the
59
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. 01-2025)
61
62
63
64
65
66
67
68
69
25
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, forward contracts, option contracts, and similar
financial instruments (section 954(c)(2)(C)).
• Gains and losses from the sale or exchange of any
property that, in the hands of the CFC, is property
described in section 1221(a)(1).
Line 1c. Enter the excess of gains over losses from
transactions (including futures, forward, and similar
transactions) in any commodities. See section 954(c)(1)
(C) for exceptions. See section 954(c)(5) for a definition
and special rules relating to commodity transactions.
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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 see section 964(e)(4) and Regulations
section 1.245A-5 for an exception to, and limitation on,
section 954(c)(6), respectively.
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:
• Property that produces the type of income reportable on
line 1a;
• An interest in a trust, partnership, or REMIC; however,
see Line 1i, later, 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
26
Line 1d. Enter the excess of foreign currency gains over
foreign currency losses from section 988 transactions. An
exception applies to transactions directly related to the
business needs of a CFC.
Line 1e. Enter any income equivalent to interest,
including income from commitment fees (or similar
amounts) for loans actually made.
Line 1f. Include net income from notional principal
contracts (except a contract entered into to hedge
inventory property).
Line 1g. Include payments in lieu of dividends that are
made as required under section 1058.
Line 1h. Enter amounts received:
• Under a contract under which the corporation is to
furnish personal services if (a) some person other than the
corporation has a right to designate (by name or by
description) the individual who is to perform the services,
or (b) the individual who is to perform the services is
designated (by name or by description) in the contract;
and
• From the sale or other disposition of such a contract.
Note. The above rules apply with respect to amounts
received for services under a particular contract only if at
some time during the tax year 25% or more in value of the
outstanding stock of the corporation is owned, directly or
indirectly, by or for the individual who has performed, is to
perform, or may be designated (by name or by
description) as the one to perform, such services.
Line 1i. For tax years beginning after December 31,
2004, in the case of any sale by a CFC of an interest in a
partnership with respect to which the CFC is a 25% owner
(defined below), such CFC is treated for purposes of
computing its foreign personal holding company income
as selling the proportionate share of the assets of the
partnership attributable to such interest. Thus, the sale of
a partnership interest by a CFC that meets the ownership
threshold constitutes subpart F income only to the extent
that a proportionate sale of the underlying partnership
assets attributable to the partnership interest would
constitute subpart F income. Do not report these amounts
on line 1b. Instead, report them on line 1i.
25% owner. For purposes of these rules, a 25%
shareholder is a CFC that owns directly 25% or more of
the capital or profits interest in a partnership. For purposes
of the preceding sentence, if a CFC is a shareholder or
partner of a corporation or partnership, the CFC is treated
as owning directly its proportionate share of any such
capital or profits interest held directly or indirectly by such
corporation or partnership. If a CFC is treated as owning a
Instructions for Form 5471 (Rev. 01-2025)
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
lesser 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 18b. Expenses. Do not enter expenses on this line
to the extent that their allocation and apportionment
reduces an item of insurance income below zero.
Note. In determining the amount of a net item of
insurance income, deductions or loss attributable to
disqualified basis and deductions attributable to
disqualified payments (Regulations section 1.951A-2(c)(5)
or (6)) are not allocated and apportioned to gross
insurance income.
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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 13b, 13d, 13e, 14b, 15b, and 16b. Expenses.
Adjusted net foreign base company income is calculated
by first determining the gross amount of each item of
income and then allocating and apportioning expenses to
such items of income. For more information, see section
954(b)(5) and Regulations section 1.954-1(c)(1)(i).
Expenses allocated and apportioned to an item of income
may reduce the item of income below zero, and any item
of income that is less than zero generally cannot offset
other items of income. For more information, see
Regulations section 1.954-1(c)(1)(ii). Do not enter
expenses on these lines of Worksheet A to the extent that
their allocation and apportionment reduces an item of
income below zero.
Note. In determining the amount of a net item of foreign
base company income, deductions or loss attributable to
disqualified basis and deductions attributable to
disqualified payments (Regulations section 1.951A-2(c)(5)
or (6)) are not allocated and apportioned to gross foreign
base company income.
Lines 13g, 14d, 15d, 16d, 18d, and 19d. Exception for
certain income subject 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).
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)).
Instructions for Form 5471 (Rev. 01-2025)
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:
1. Elects to treat its related person insurance income
for the tax year as income effectively connected with the
conduct of a trade or business in the United States,
2. Elects to waive all treaty benefits (other than from
section 884) for related person insurance income, and
3. Meets any requirement the IRS may prescribe to
ensure that any tax on such income is paid.
This election will not be effective if the corporation was
a disqualified corporation (as defined in section 953(c)(3)
(E)) for the tax year for which the election was made or for
any prior tax year beginning after 1986. See section
953(c)(3)(D) for special rules for this election.
Mutual life insurance companies. The related person
insurance income rules also apply to mutual life insurance
companies under regulations prescribed by the Secretary.
For these purposes, policyholders must be treated as
shareholders.
Line 19b. Expenses. Do not enter expenses on this line
to the extent that their allocation and apportionment
reduces an item of insurance income below zero.
Note. In determining the amount of a net item of
insurance income, deductions or loss attributable to
disqualified basis and deductions attributable to
disqualified payments (Regulations section 1.951A-2(c)(5)
27
or (6)) are not allocated and apportioned to gross
insurance income.
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).
shareholders of such CFC. As of the date these
instructions were revised, section 901(j) applied to Iran,
North Korea, Sudan, and Syria.
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 an 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.
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Line 21. Illegal bribes, kickbacks, and other payments. Enter the total of any illegal bribes, kickbacks, or
other payments (within the meaning of section 162(c))
paid by or on behalf of the corporation, directly or
indirectly, to an official, employee, or agent of a
government.
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.
28
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).
Instructions for Form 5471 (Rev. 01-2025)
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 section 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 . . . . . . . . . . . . . . . . . .
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) after reductions (if any) for current year distributions
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 . . . . . . . . .
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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. PTEP related to prior-year section 956
inclusions (see section 959(c)(1)(A)) and current-year or
prior-year subpart F inclusions (see section 959(c)(2))
reduce what would otherwise be the current year section
956 inclusion.
Note. PTEP resulting from subpart F inclusions (that is,
section 959(c)(2) PTEP) that reduced prior-year section
956 or 956A inclusions (see section 959(a) and (c)(1), and
Schedule J) should be reclassified as section 959(c)(1)
PTEP.
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 PTEP accounts. Thus, the U.S.
shareholders must:
Instructions for Form 5471 (Rev. 01-2025)
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
1. Compute the current year subpart F income
inclusion (potentially increasing the section 959(c)(2)
PTEP within the PTEP accounts),
2. Take into account current distributions (potentially
reducing the PTEP accounts and untaxed earnings and
profits), and
3. Compute the current section 956 inclusion
(increasing section 959(c)(1) PTEP and potentially
decreasing section 959(c)(2) PTEP in the PTEP
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 section 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 that was acquired by the foreign corporation before it
became a CFC is disregarded (that is, not included), but
not in excess of the amount of applicable earnings (as
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
29
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 year 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.
properly attributable to an income group within the general
category, passive category, or section 901(j) category.
See Regulations section 1.960-1(d)(2)(ii). A foreign
corporation may accrue or pay taxes properly attributable
to a PTEP group within any of the separate categories of
income, with the exception of foreign branch category
income. See Regulations section 1.960-3(c)(1).
If code 901j is entered on line a, enter on line b the
country code for the sanctioned country using the
two-letter codes (from the list at IRS.gov/CountryCodes).
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 code (from the list at IRS.gov/CountryCodes).
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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.
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 global intangible low-taxed income (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 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. Taxes with respect to all categories
of income listed in the Instructions for Form 1118, with the
exception of foreign branch income, may need to be
reported. A foreign corporation may accrue or pay taxes
30
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. territory for the foreign
corporation’s foreign tax year(s) that ends 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) or 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. Report them instead 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
adjustment. Instead, they should be reported in the year to
which such taxes relate. This may require an amended
return. See section 905(c). Adjustments include additional
payments, refunds, and downward adjustments for
accrued foreign taxes that are not paid within 2 years after
the close of the tax year to which such taxes relate.
Comparison to income tax expense reported on
Form 5471, Schedule C. 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
Instructions for Form 5471 (Rev. 01-2025)
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.
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).
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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, a 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 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 1b(2)—Reference ID
Number, earlier, for more information about reference ID
numbers.
Column (c)
Check the box if the foreign income taxes reported in
column (j) were paid or accrued by the foreign 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.
Column (d)
Enter the two-letter codes (from the list at IRS.gov/
CountryCodes) of all foreign countries and U.S. territories
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 (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 six-group.com/en/products-services/financialinformation/data-standards.html#scrollTo=currencycodes.
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).
Columns (k) and (l)
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).
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 (e)
Column (m)
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
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
Instructions for Form 5471 (Rev. 01-2025)
31
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
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”).
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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, 2023. 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, 2023, a
refund of 3u from Country X on 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 2023
Schedule E (Form 5471), Part I, Section 1, for CFC1 with
respect to the General Category Income separate
category.
• Line 1, column (a): CFC1
• Line 1, column (b): 1000123
• Line 1, column (d): XX
• Line 1, column (e): 2023/12/31
• Line 1, column (f): 2023/12/31
• 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
32
Section 2—Taxes Deemed Paid (Section 960(b))
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 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).
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 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, earlier, for more
information about reference ID numbers.
Column (c)
Enter the applicable two-letter code (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.
Instructions for Form 5471 (Rev. 01-2025)
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
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.
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.
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Section 965(a) PTEP
965a
Section 965(b) PTEP
965b
Section 951A PTEP
951A
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).
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).
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)
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.
Column (i)
Column (f)
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.
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 territory of the United
States are allowed as a credit. See section 901(b).
Instructions for Form 5471 (Rev. 01-2025)
33
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.
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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.
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).
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%
34
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 section 959(c)(1) and (c)(2). See the
instructions for Schedule J, Column (e), later, 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.
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.
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).
Instructions for Form 5471 (Rev. 01-2025)
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 Domestic
Corporation, CFC1, CFC2, and CFC3 is the U.S. dollar.
During Year 1, CFC3 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 CFC3 and is reported on line 4,
column (a), of Schedule E-1 of CFC3’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.
deemed to pay foreign income taxes equal to 80% of the
product of (a) such domestic corporation’s inclusion
percentage, multiplied by (b) the aggregate tested foreign
income taxes paid or accrued by the CFC. For the
computation of such amount, see Form 1118, Schedule D.
Amounts reported on line 9 should be negative numbers.
See line 15 with respect to reporting taxes not deemed
paid as a result of the inclusion percentage or the
application of the 80% limitation.
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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 E1 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
Instructions for Form 5471 (Rev. 01-2025)
Line 10. A domestic corporation is deemed to pay foreign
income taxes with respect to distributions of PTEP. See
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 CFC
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, earlier, for reporting on line 10, column
(e)(x), of Schedule E-1 of CFC2's Form 5471 with respect
to taxes on distributions from CFC3 to CFC2.
Line 11. Foreign income taxes reclassified from section
959(c)(2) PTEP to section 959(c)(1) PTEP 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) PTEP account. CFC2 reclassifies such amount as
section 959(c)(1) PTEP on Schedule J. Accordingly, $4 of
foreign income taxes related to section 959(c)(2) PTEP is
reclassified to section 959(c)(1) PTEP 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).
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).
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
35
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.
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.
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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.
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
36
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 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.
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
year 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 Item
F—Alternative Information Under Rev. Proc. 2019-40,
earlier, for more details.
Instructions for Form 5471 (Rev. 01-2025)
Note. A separate Schedule H-1 must be attached for
each person described in Categories 4, 5a, 5b, and 5c
with respect to which reporting is furnished on this Form
5471 that is an applicable corporation within the meaning
of section 59(k).
Note. Category 5b and 5c filers are not required to file
Schedule H for foreign-controlled CFCs.
In the case of section 988 losses, determine whether
Form 8886 needs to be completed, as described under
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.
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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).
Special rules for DASTM. If the foreign corporation uses
DASTM, enter on line 1 the dollar GAAP income or (loss)
from line 22 of Schedule C. Enter on lines 2a through 4 the
adjustments made in figuring current E&P for U.S. tax
purposes. Report these amounts in U.S. dollars. Enter on
line 5b the DASTM gain or loss figured under Regulations
section 1.985-3(d).
Lines 2a through 2i. Certain adjustments (required by
Regulations section 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 year 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.
Instructions for Form 5471 (Rev. 01-2025)
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, 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 code (from the list
at IRS.gov/CountryCodes).
Note. The amounts reported on line 5c include both
foreign source and U.S. source income.
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 5e. Enter the exchange rate used in computing
line 5d. Report the exchange rate using the “divide-by
37
convention” specified under Reporting Exchange Rates
on Form 5471, earlier.
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.
Line 2a. Appropriate adjustments to applicable financial
statement income (AFSI) are made when the AFS
reporting year covers a period other than the CFC’s tax
year. See Proposed Regulations section 1.59A-3.
Line 2b. Enter the aggregate adjustment needed to:
• Exclude any items of income, expense, gain, and loss
resulting from the reporting CFC’s ownership of stock of a
foreign corporation, including acquiring or disposing of
such stock, reflected in the CFC’s financial statement
income (FSI); and
• Include any items of income, deduction, gain, and loss
resulting from the CFC’s ownership of stock of a foreign
corporation, including acquiring or transferring such stock,
for regular tax purposes (taking into account section
961(c) of the Code). See Proposed Regulations section
1.59A-6(c)(2).
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Schedule H-1
Use Schedule H-1 to report the CFC’s adjusted net
income or loss for corporate alternative minimum tax
(CAMT) purposes. Enter the amounts on lines 1 through
2m in the currency in which the item originates (that is,
applicable financial statement (AFS) currency, functional
currency, or U.S. dollars).
Item a. The AFS currency is the currency in which the
applicable financial statements are denominated, which is
not necessarily the functional currency. See the Form
4626 instructions for determination of applicable financial
statements.
Item b. The exchange rate used to convert from AFS
currency to U.S. dollars is the weighted average exchange
rate. See Proposed Regulations section 1.56A-1(e).
Report the exchange rate using the "divide-by convention"
specified under Reporting Exchange Rates on Form 5471,
earlier.
Line 1. Enter the net income or (loss) set forth on the
applicable financial statement in AFS currency and, if not
already in U.S. dollars, convert to U.S. dollars using the
weighted average exchange rate. See Proposed
Regulations section 1.56A-1(e).
Lines 2a through 2m. Certain adjustments (required by
section 56A(c)) must be made to the foreign corporation’s
line 1 net book income or (loss) to determine its adjusted
net income or loss for CAMT purposes. These
adjustments may include both positive and negative
adjustments.
For adjustments denominated in AFS currency, the
AFS currency amount of the item is reported in the AFS
Currency column and translated into U.S. dollars at the
weighted average exchange rate for the year, and the U.S.
dollar amount of the item is reported in the U.S. Dollars
column. For adjustments denominated in functional
currency, the functional currency amount of the item is
reported in the Functional Currency column, and the
translated U.S. dollar amount of the item is reported in the
U.S. Dollars column. For adjustments already
denominated in U.S. dollars, report the amount directly in
the U.S. Dollars column.
For example, assume CFC1 has an adjustment item
related to consolidated financial statements of 100x local
currency, or LC, where LC is the currency in which the
AFS are denominated. Assume the weighted average
exchange rate for the year at issue is 1 LC : 1.1 USD. With
respect to that adjustment item, CFC1 will report the
following on line 2b: 100x in the AFS Currency column,
nothing in the Functional Currency column, and 110x in
the U.S. Dollars column.
38
Line 2g. Enter the adjustment(s) needed to exclude
dividends resulting from the CFC’s ownership of stock of a
foreign corporation reflected in the CFC’s FSI and include
dividends for regular tax purposes except for CAMT
excluded dividends as defined in Proposed Regulations
section 1.59A-6(c)(2)(iii)(B). Where the CFC owns stock
of a foreign corporation through a partnership, see
Proposed Regulations section 1.59A-6(c)(2)(iv).
Line 2h. Enter the adjustment(s) needed to include the
CFC’s distributive share of all partnership investment
AFSI. See Proposed Regulations section 1.59A-5.
Line 2i. If the CFC is itself an applicable corporation,
enter here as a reduction (or increase) the amount of the
CFC’s income (or loss) determined by taking into account
Proposed Regulations section 1.56A-7 (that is, income (or
loss) effectively connected with the conduct of a trade or
business within the United States). See Proposed
Regulations section 1.59A-6(c)(3).
Line 2j. Enter the adjustment(s) needed to disregard any
applicable income taxes taken into account in the CFC’s
AFS. See Proposed Regulations section 1.59A-8(b).
Line 2k. If the CFC owns a disregarded entity, enter the
adjustment(s) needed to treat the CFC and the
disregarded entity as a single CAMT entity for CAMT
purposes. See Proposed Regulations section 1.59A-9.
Line 2l. Enter an adjustment which is the difference
between the section 167 depreciation deductions on
section 168 property and the depreciation expense
included in the CFC’s AFS for such property. The
adjustment is negative if the section 167 depreciation
deduction on section 168 property exceeds the
depreciation expense included in the CFC’s AFS for such
property. The adjustment is positive if the depreciation
expense included in the CFC's AFS for section 168
property exceeds the section 167 depreciation deductions
on such property. See Proposed Regulations section
1.56A-15.
Line 2m. To the extent not otherwise reflected on lines 2a
through 2l, enter here any adjustments made to AFSI to
arrive at adjusted net income or loss. See Proposed
Regulations section 1.59A-6(c)(1).
Line 5. Enter the filer’s pro rata share (determined under
rules similar to the rules under section 951(a)(2)) of the
Instructions for Form 5471 (Rev. 01-2025)
amount on line 5. See Proposed Regulations section
1.59A-6(b)(1).
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 Item
F—Alternative Information Under Rev. Proc. 2019-40,
earlier, for more details.
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.
Line 2e. Enter the amount of the CFC’s taxable income
or loss from sources outside the United States and its
territories 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 territories.
• 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 territories.
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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 no longer completed
separately for each applicable category of income.
Therefore, Schedule I-1 is now completed once (for
general category income, passive category income, or
both). A Schedule I-1 that includes passive category
income on 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.
Note. The other reporting requirements of a taxpayer that
includes passive category income with general category
income on a Schedule I-1 do not change because the
taxpayer includes passive category income with general
category income on 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
Instructions for Form 5471 (Rev. 01-2025)
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
$(1,000)
$(1,000)
800
(800)
800
(800)
$200
$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). The amount entered on line 5 will
generally be a positive amount. However, a negative
amount is permitted on line 5.
Line 6. Subtract line 5 from 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).
39
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 9a. Enter the amount of interest expense included
on line 5. See Line 6, earlier, for foreign currency
translation.
Line 9b. Enter the CFC’s qualified interest expense, as
defined in Regulations section 1.951A-4(b)(1)(iii).
Line 9c. Enter the CFC’s tested loss QBAI amount, as
defined in Regulations section 1.951A-4(b)(1)(iv).
Line 9d. Subtract the sum of line 9b and line 9c from
line 9a and enter the result on line 9d.
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Line 8. If the CFC has a tested loss on line 6, enter zero.
If the CFC has tested income on line 6, enter the qualified
business asset investment (QBAI) (defined below). This
amount must be converted from functional currency to
U.S. dollars using the average exchange rate for the year
of the CFC. See Regulations section 1.951A-1(d)(1).
Qualified business asset investment (QBAI). QBAI
is the average of the CFC's aggregate adjusted bases, as
of the close of each quarter of its tax 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 tax year to
which such depreciation relates.
Specified tangible property and dual-use property.
Specified tangible property means any tangible property
used in the production of tested income. If such property
was used in the production of tested income and income
that is not tested income (that is, dual-use property), the
property is treated as specified tangible property in the
same proportion that the amount of tested income
determined before allocable deductions (that is, line 4)
produced with respect to the property bears to the total
amount of gross income produced with respect to the
property.
Partnership property. A CFC with tested income that
is a partner of a partnership that has depreciable tangible
property determines its share of the partnership’s average
adjusted basis in the depreciable tangible property of the
partnership based on the amount of the distributive share
of the gross income produced by the property that is
included in the CFC’s gross tested income (defined
below) relative to the total amount of gross income
produced by the property. The partnership’s average
adjusted basis in the depreciable tangible property of the
partnership 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.
40
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 Line 6, earlier, 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.
E&P with respect to all categories of income listed in the
Instructions for Form 1118, except foreign branch
category income, may need to be reported. A foreign
corporation may have E&P in an income group within the
general category, passive category, or section 901(j)
category. See Regulations section 1.960-1(d)(2)(ii). A
foreign corporation may have PTEP in a PTEP group
within any of the separate categories of income, 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 code (from the list at IRS.gov/CountryCodes).
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
Instructions for Form 5471 (Rev. 01-2025)
category should be reported on the general category
Schedule J.
Note. For purposes of this Schedule J, include in each
separate category of 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 J using code
“TOTAL” that aggregates all amounts listed for each line
and column in Part I of all other Schedules J.
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, later, for
additional information pertaining to reporting amounts in
column (d).
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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 PTEP amounts
required to be included in column (e). If the person filing
Form 5471 is unable to determine whether amounts
should be reported as PTEP, those amounts should be
included in column (a), Post-2017 E&P Not Previously
Taxed (post-2017 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, later, for an example.
Enter the amounts in this schedule in the functional
currency of the foreign corporation as reported on Form
5471, page 1, item 1h. If the foreign corporation is the
owner of a qualified business unit(s) (QBU) with a different
functional currency, translate the E&P of the QBU(s) to the
foreign corporation’s functional currency.
Columns (a), (b), and (c)
Report the opening balance, current year additions and
subtractions, and the closing balance in the foreign
corporation's E&P described in section 959(c)(3). In
general, this is E&P of the foreign corporation that has not
been included in gross income of a U.S. person under
section 951(a)(1) and section 951A.
In column (a), report E&P described in section 959(c)
(3) and earned after the repeal of section 902, that is,
post-2017 E&P not previously taxed (post-2017 section
959(c)(3) balance). The repeal of section 902 is effective
for tax years of foreign corporations beginning after
December 31, 2017, and to tax years of U.S. shareholders
in which or with which such tax years of foreign
corporations end.
In column (b), report post-1986 undistributed earnings,
as defined under section 902(c)(1), and as in effect prior
to the repeal of section 902.
Use column (c) to report the aggregate amount of the
foreign corporation's pre-1987 section 964(a) E&P
accumulated since 1962 and not previously distributed or
deemed distributed. These amounts are figured in U.S.
dollars using the rules of Regulations section 1.964-1(a)
through (d), and translated into the foreign corporation's
Instructions for Form 5471 (Rev. 01-2025)
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) amounts).
• Column (e)(iii) is PTEP described in the following three
subgroups (which are aggregated into a single PTEP
group) (section 959(c)(1) amounts).
1. PTEP attributable to investments in U.S. property
and not by reason of reclassification.
2. PTEP attributable to inclusions under section 951(a)
(1)(A) (other than inclusions under section 951(a)(1)(A)
described in the instructions for columns (e)(vi) through
(ix)) and reclassified as investments in U.S. property (for
example, PTEP attributable to subpart F income
inclusions and reclassified as investments in U.S.
property).
3. PTEP attributable to inclusions under former 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) amounts).
• Column (e)(v) is PTEP described in the following three
subgroups (which are aggregated into a single PTEP
group) (section 959(c)(1) amounts).
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).
41
• 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) (section 959(c)(2) amounts).
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 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).
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
numbers on line 2a of column (a), (b), (c), or (e), as
applicable.
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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 section 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.
Column (f)
Use column (f) to report the opening and closing balances
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 on 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.
42
Line 2b. This line of column (d) accounts for foreign
income taxes that are suspended in the current tax year.
Report such amounts as negative numbers.
Line 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).
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 section 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
Instructions for Form 5471 (Rev. 01-2025)
the foreign taxes imposed on receipt of a distribution of
PTEP from a lower-tier foreign corporation.
Example. Domestic Corporation, a U.S. shareholder,
wholly owns the only class of stock of CFC1, a foreign
corporation. CFC1, in turn, wholly owns the only class of
stock of CFC2, a foreign corporation. CFC2, in turn, wholly
owns the only class of stock of CFC3, a foreign
corporation. The functional currency of Domestic
Corporation, CFC1, CFC2, and CFC3 is the U.S. dollar.
During Year 1, Domestic Corporation reports an inclusion
under section 951(a)(1) of $100 as a result of subpart F
income of CFC3. During Year 2, CFC3 distributes $40 to
CFC2. CFC2 pays withholding tax of $4 on the distribution
from CFC3. Such tax is related to previously taxed subpart
F income. Domestic Corporation reports on CFC2’s Form
5471, Schedule J, line 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 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.
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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.
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 in column (e)(viii) 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.
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, or if
more than one Schedule J (Form 5471) is filed, the
Schedule J (Form 5471) with code “TOTAL” entered on
line a of that Schedule J.
Instructions for Form 5471 (Rev. 01-2025)
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 989(b).
Report the exchange rate in the entry space provided at
the top of Schedule M using the “divide-by convention”
specified under Reporting exchange rates on Form 5471,
earlier.
Name of person filing Form 5471. The name of the
person filing Form 5471 is generally the name of the U.S.
person described in the applicable category or categories
of filers (see Categories of Filers, earlier). However, in the
case of a consolidated return, enter the name of the U.S.
parent in the field for “Name of person filing Form 5471.”
Reference ID number of foreign corporation. Use the
reference ID number shown on Form 5471, page 1, item
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).
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
43
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.
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.
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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).
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 provide
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 provide
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.
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
44
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.
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 are therefore 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, page 1, item
1b(2).
Part I
Column (d). Enter the date the shareholder first acquired
10% or more (in value or voting power) of the outstanding
stock of the foreign corporation.
Column (e). Enter the date the shareholder acquired
(whether in one or more transactions) an additional 10%
or more (in value or voting power) of the outstanding stock
of the foreign corporation.
Part II
Section A—General Shareholder Information
If the shareholder's latest tax return was filed
electronically, enter “e-filed” in column (b)(3) instead of a
service center.
Section C—Acquisition of Stock
Section C is completed by shareholders who are
completing Schedule O because they have acquired
sufficient stock in a foreign corporation. If the shareholder
acquired the stock in more than one transaction, use a
separate line to report each transaction.
Column (d). Enter the method of acquisition (for
example, purchase, gift, bequest, trade).
Instructions for Form 5471 (Rev. 01-2025)
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).
Column (e)(3). Enter the number of shares
constructively owned (within the meaning of section
958(b)) by the shareholder listed in column (a).
• Corporation FJ.
• Corporation FK.
Then Mr. Lyons is required to indicate that he is a
10%-or-more shareholder in corporations F, FI, and FJ.
Schedule P
Use Schedule P to report the PTEP 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).
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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, Alex, 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, 2023, Alex made a gift of 5,000 shares of
foreign corporation X to his child. Because Alex 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, Alex
completes Section D as follows.
• Enters his name in column (a).
• Enters “common” in column (b).
• Enters “July 1, 2023” 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 child 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 in
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 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.
Instructions for Form 5471 (Rev. 01-2025)
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 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).
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
45
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 901j is entered on line a, enter on line b the
country code for the sanctioned country using the
two-letter code (from the list at IRS.gov/CountryCodes).
Columns (a) through (j) of Schedule P correspond to
Schedule J, columns (e)(i) through (e)(x). See Schedule J,
earlier, 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 on 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.
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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 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.
Part I
Enter amounts in the functional currency of the foreign
corporation as reported on Form 5471, page 1, item 1h.
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 section 989(b)
(1) and (3); and Regulations sections 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.
46
Schedule Q
Use Schedule Q to report the CFC’s income, deductions,
taxes, and assets by CFC income groups for purposes of
section 960(a) and (d).
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.
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 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 PFIC.
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 to 4, 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.”
Instructions for Form 5471 (Rev. 01-2025)
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.
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Codes for Categories of Income
Code
PAS
Category of Income
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 (i), the country code for the sanctioned country
using the two-letter code (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
and lines 3 and 4. 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).
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
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
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
Instructions for Form 5471 (Rev. 01-2025)
Line C. If code 901j is entered on line A, enter the country
code for the sanctioned country using the two-letter code
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 line
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 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 section 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
47
general category that consists of all of a CFC’s foreign
base company sales income.
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).
(ii) on line 1a is the sum of the amounts reported in
column (ii) on lines 1a(2) and 1a(3), which is equal to
$175 ($100 + $75). The amounts reported in columns (x)
and (xii) on line 1a are the sum of the amounts reported in
each column on lines 1a(2) and 1a(3), which is equal to
$8 ($5 + $3). The items reported on line 1a(1), gross
income of $50 and $20 of foreign tax, are not included in
the totals reported on line 1a. 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).
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Note. Enter the following passive category foreign
personal holding company income of the CFC on line 1f
(other foreign personal holding company income).
• 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, line 1f, delineating the amount
on line 1f for each of the three groups reporting on line 1f.
For example, if both payments in lieu of dividends and
income from notional principal contracts are included on
line 1f, on the statement, identify the amount related to
each of those income groups for each column of line 1f.
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 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.
Example. For line 1a(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 1a(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 1a(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
48
Line 2. Recaptured Subpart F Income
Enter income that is recaptured as subpart F income in
the current year. See section 952(c)(2).
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) 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) 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).
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
Instructions for Form 5471 (Rev. 01-2025)
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 1j) 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
GILTI high-tax exclusion, in the appropriate column on
line 4.
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.
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Example. For line 1a(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 1a(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 1a(1), 3(1), and 4(1), which
equals $600 ($100 + $200 + $300). The amount reported
in column (x) of line 4 is the sum of the amounts reported
in column (x) on lines 1a(1), 3(1), and 4(1), which equals
$210 ($35 + $70 + $105). On line 4, column (xii) should be
blank because foreign tax on residual amounts is not
creditable. The amounts reported on line 1a(1) would not
be included in the total for line 1a, but the amount reported
on line 1a(2) would be included in the total reported on
line 1a. 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.
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.
territory 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 section 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
Instructions for Form 5471 (Rev. 01-2025)
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 (xii). Foreign taxes for which credit is allowed (U.S. dollars). The 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.
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 U.S. person)
49
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.
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 FMVs.
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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 lines 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.
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
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
50
Column (b). Date of distribution. Enter the month, day,
and year using the following format: MM-DD-YYYY. For
example, June 30, 2023, would be entered as
“06-30-2023.”
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 FMV of any property transferred
to the shareholder. However, this amount is 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.
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 E&P. Report distributions from current and
accumulated E&P. Do not report any part of a distribution
that is not from E&P in column (d).
An actual distribution is first out of PTEP, if any, and
then out of the section 959(c)(3) balance. See section
959(c).
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 Schedule I, Line 6, earlier, for details.
With respect to foreign currency gain or loss on a
distribution of PTEP, 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.
Note. E&P described in section 959(c)(3) is generally
E&P of the foreign corporation that has not been included
in gross 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
Instructions for Form 5471 (Rev. 01-2025)
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.
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.
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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. 01-2025)
51
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
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).
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, painting,
wallcovering, flooring, tile, &
finish carpentry)
238900 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.
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
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
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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
Crude Petroleum Extraction
Natural Gas Extraction
Coal Mining
Metal Ore Mining
Stone Mining & Quarrying
Sand, Gravel, Clay, &
Ceramic & Refractory
Minerals Mining & Quarrying
212390 Other Nonmetallic Mineral
Mining & Quarrying
213110 Support Activities for Mining
Utilities
221100 Electric Power Generation,
Transmission & Distribution
221210 Natural Gas Distribution
221300 Water, Sewage & Other
Systems
221500 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
52
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
Wholesale Trade
Merchant Wholesalers, Durable
Goods
423100 Motor Vehicle & Motor Vehicle
Parts & Supplies
423200 Furniture & Home Furnishings
423300 Lumber & Other Construction
Materials
423400 Professional & Commercial
Equipment & Supplies
423500 Metal & Mineral (except
Petroleum)
423600 Household Appliances &
Electrical & Electronic Goods
423700 Hardware & Plumbing &
Heating Equipment &
Supplies
423800 Machinery, Equipment, &
Supplies
423910 Sporting & Recreational
Goods & Supplies
423920 Toy & Hobby Goods &
Supplies
423930 Recyclable Materials
423940 Jewelry, Watch, Precious
Stone, & Precious Metals
Principal Business Activity Codes (Continued)
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
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.
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)
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)
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.
TREASURY/IRS
AND OMB USE
ONLY DRAFT
October 8, 2024
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
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
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
Pipeline Transportation
486000 Pipeline Transportation
Scenic & Sightseeing
Transportation
487000 Scenic & Sightseeing
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)
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
53
Principal Business Activity Codes (Continued)
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
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
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
Home Health Care Services
621610 Home Health Care Services
Other Ambulatory Health Care
Services
621900 Other Ambulatory Health
Care Services (including
ambulance services & blood
& organ banks)
Hospitals
622000 Hospitals
Nursing and Residential Care
Facilities
623000 Nursing & Residential Care
Facilities
Social Assistance
624100 Individual & Family Services
624200 Community Food & Housing,
& Emergency & Other Relief
Services
624310 Vocational Rehabilitation
Services
624410 Childcare Services
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
811420 Reupholstery & Furniture
Repair
811430 Footwear & Leather Goods
Repair
811490 Other Personal & Household
Goods Repair & Maintenance
Personal and Laundry Services
812111 Barber Shops
812112 Beauty Salons
812113 Nail Salons
812190 Other Personal Care Services
(including diet & weight
reducing centers)
812210 Funeral Homes & Funeral
Services
812220 Cemeteries & Crematories
812310 Coin-Operated Laundries &
Drycleaners
812320 Drycleaning & Laundry
Services (except
Coin-Operated)
812330 Linen & Uniform Supply
812910 Pet Care (except Veterinary)
Services
812920 Photofinishing
812930 Parking Lots & Garages
812990 All Other Personal Services
Religious, Grantmaking, Civic,
Professional, and Similar
Organizations
813000 Religious, Grantmaking,
Civic, Professional, & Similar
Organizations (including
condominium and
homeowners associations)
TREASURY/IRS
AND OMB USE
ONLY DRAFT
October 8, 2024
Management of Companies
(Holding Companies)
551111 Offices of Bank Holding
Companies
551112 Offices of Other Holding
Companies
Administrative and Support and
Waste Management and
Remediation Services
Administrative and Support
Services
561110 Office Administrative
Services
54
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)
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
Arts, Entertainment, and
Recreation
Performing Arts, Spectator Sports,
and Related Industries
711100 Performing Arts Companies
711210 Spectator Sports (including
sports clubs & racetracks)
711300 Promoters of Performing Arts,
Sports, & Similar Events
711410 Agents & Managers for
Artists, Athletes, Entertainers,
& Other Public Figures
711510 Independent Artists, Writers,
& Performers
Museums, Historical Sites, and
Similar Institutions
712100 Museums, Historical Sites, &
Similar Institutions
Amusement, Gambling, and
Recreation Industries
713100 Amusement Parks & Arcades
713200 Gambling Industries
713900 Other Amusement &
Recreation Industries
(including golf courses, skiing
facilities, marinas, fitness
centers, & bowling centers)
Accommodation and Food
Services
Accommodation
721110 Hotels (except Casino Hotels)
& Motels
721120 Casino Hotels
721191 Bed & Breakfast Inns
721199 All Other Traveler
Accommodation
721210 RV (Recreational Vehicle)
Parks & Recreational Camps
721310 Rooming & Boarding Houses,
Dormitories & Workers’
Camps
Food Services and Drinking Places
722300 Special Food Services
(including food service
contractors & caterers)
722410 Drinking Places (Alcoholic
Beverages)
722511 Full Service Restaurants
722513 Limited Service Restaurants
722514 Cafeterias, Grill buffets, &
Buffets
722515 Snack & Nonalcoholic
Beverage Bars
Other
999000 Unclassified Establishments
(unable to classify)
| File Type | application/pdf |
| File Title | Instructions for Form 5471 (Rev. January 2025) |
| Subject | Instructions for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations |
| Author | W:CAR:MP:FP |
| File Modified | 2024-10-08 |
| File Created | 2024-10-07 |