Formulář 5471 Pokyny
Pokyny pro formulář 5471, Informační návrat amerických osob s ohledem na některé zahraniční společnosti
Rev. leden 2024
Související formuláře
- Formulář 5471 - Informační návrat amerických osob s ohledem na některé zahraniční společnosti
- Formulář 5471 Plán E - Příjmy, válečné zisky a nadměrné zisky Daně placené nebo nabyté
- Formulář 5471 Plán G-1 - Uspořádání sdílení nákladů
- Formulář 5471 Plán H - Současné zisky a zisky
- Formulář 5471 Plán I-1 - Informace o globálních nehmotných Nízkonákladech
- Formulář 5471 Plán J - Kumulované zisky a zisky řízené zahraniční společnosti (E&P)
- Formulář 5471 Plán M - Transakce mezi ovládanou zahraniční společností a akcionáři nebo jinými spřízněnými osobami
- Formulář 5471 Plán O - Organizace nebo reorganizace zahraniční společnosti a akvizice a dispozice jejích akcií
- Formulář 5471 Plán P - Dříve Zdaněné zisky a zisky amerických akcionářů některých zahraničních společností
- Formulář 5471 Plán Q - CFC Výnosy ze skupin příjmů CFC
- Formulář 5471 Plán R - Distribuce zahraniční společnosti
Department of the Treasury
Internal Revenue Service
Instructions for Form 5471
(Rev. January 2024)
(Use with the December 2023 revision of Form 5471 and separate Schedules G-1
and Q; 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.)
Information Return of U.S. Persons
With Respect to Certain Foreign Corporations
Section references are to the Internal
Revenue Code unless otherwise noted.
On page 5 of the form, the question entered “XX” on Form 5471,
on Schedule G, line 18, has been
deleted and replaced with new
questions 18a and 18b to better
reflect Regulations section 1.482-2(a)
(2)(iii)(B).
Schedule G, line 14, if the answer to
question 22 of the table in the
instructions was “Yes.”
Contents
Page
Worksheet A, lines 23 and 25, were
revised to add a reference to section
961(c).
On page 5, the question on
Schedule G, line 19a, has been
reworded to better reflect Regulations
section 1.385-3. As a result, the
information requested on line 19b(1)
has also been reworded.
Changes to separate Sched-
ule G-1. Line 6b was reworded to
better reflect Regulations section
1.482-7A.
Changes to separate Schedule Q.
On page 1 of the schedule, line 1f now
requests “Other Foreign Personal
Holding Company Income.” Filers are
directed to see the instructions for an
attachment requirement for line 1f.
Worksheet A, lines 28 and 31, were
amended.
Worksheet A, line 58, was revised
to more accurately reflect Regulations
section 1.951-1(b)(1)(ii)(A).
The instructions for Worksheet A,
line 1a, were clarified by adding a
reference to the limitation on section
954(c)(6) in Regulations section
1.245A-5.
A new instruction for Worksheet A,
lines 13b, 13d, 13e, 14b, 15b, 16b,
18b, and 19b, was added regarding
allocation and apportionment of
Instructions for Separate
expenses to better reflect Regulations
section 1.954-1(c)(1)(i), (ii), and (iv).
On page 4 of the schedule, the
following lines have been shaded
under column (xv), Loss Allocation.
A new Worksheet H-1 has been
added to these instructions. Also, new
Worksheet H-1 Instructions have been
provided.
In the instructions for separate
Schedule Q, line 1, the attachment
requirement for line 1f has been
Lines 3, 3(1), and 3(2), pertaining to
•
the Tested Income Group.
Lines 4, 4(1), and 4(2), pertaining to
•
the Residual Income Group.
Changes to these instructions.
These instructions have been updated clarified.
for the aforementioned changes to
Future Developments
Form 5471 and separate Schedule Q.
General Instructions
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/
No changes were needed to the
instructions for separate
Schedule G-1.
Purpose of Form
Form 5471 is used by certain U.S.
persons who are officers, directors, or
shareholders in certain foreign
In addition, the following changes
have been made.
The table of questions for Form
5471, Schedule G, line 14, has been
amended as follows. If the answer to
question 22 of that table is “Yes,” for
tax year 2023, affected Form 5471
filers will enter code “PRS” on Form
5471, Schedule G, line 14. For tax
year 2022, affected Form 5471 filers
corporations. The form and schedules
are used to satisfy the reporting
requirements of sections 6038 and
6046, and the related regulations.
What’s New
Changes to Form 5471. On page 1
of the form, new line 1b(3) requests
the previous reference ID number(s)
of the foreign corporation, if any.
Who Must File
Generally, all U.S. persons described
Jan 25, 2024
Cat. No. 49959G
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,
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
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).
statements, and/or information apply.
2. Is not related (using principles
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),
of section 954(d)(3)) to the
foreign-controlled section 965 SFC.
U.S. person. For purposes of
Category 1, a U.S. person is:
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.
1. A citizen or resident of the
United States;
inclusion of a single instance of that
schedule for any separate category
will meet the requirement.
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).
If the filer is described in more than
one filing category, do not duplicate
information. However, complete all
items that apply. For example, if you
are the sole owner of a CFC (that is,
you are described in Categories 4 and
5a), complete all six pages of Form
5471 and separate Schedules E, G-1,
H, I-1, J, M, P, Q, and R.
See section 957(c) for exceptions.
Section 965 SFC. For purposes of
Category 1, a section 965 SFC is:
Category 1c Filer
1. A controlled foreign corporation
definition); or
2. Any foreign corporation with
respect to which one or more
domestic corporations are U.S.
shareholders.
A Category 1c filer is a person who is
Note. Complete a separate Form
5471 and all applicable schedules for
each applicable foreign corporation.
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.
When and Where To File
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.
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.
Related constructive U.S. share-
holder. For purposes of Category 1c,
a related constructive U.S.
Categories of Filers
Category 1 Filers
See section 965 and the
shareholder is a U.S. shareholder with
respect to a foreign-controlled section
965 SFC who:
regulations thereunder for exceptions.
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
Category 1a Filer
1. Does not own, within the
meaning of section 958(a), stock of
the foreign-controlled section 965
SFC; and
A Category 1a filer is a Category 1
filer that is not a Category 1b or 1c
filer.
corporation (SFC) at any time during
the foreign corporation’s tax year
ending with or within the U.S.
2. Is related (using principles of
Category 1b Filer
section 954(d)(3)) to the
shareholder’s tax year, and who
owned that stock on the last day in
that year in which the foreign
foreign-controlled section 965 SFC.
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.
Unrelated section 958(a) U.S.
shareholder. For purposes of
Category 1b, an unrelated section
958(a) U.S. shareholder is a U.S.
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.
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
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:
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.
Instructions for Form 5471 (Rev. 01-2024)
2
The section 965 SFC (or
section 5.02 of Notice 2018-13,
See Regulations section
•
foreign-controlled section 965 SFC)
has accumulated earnings and profits
(E&P) related to section 965 that is
reportable on Schedule J (Form
5471), or
Category 1 filers.
U.S. person. For purposes of
Unrelated constructive U.S. share-
holder. A Category 1 filer does not
have to file Form 5471 if all of the
following conditions are met.
Category 2, a U.S. person is:
1. A citizen or resident of the
United States;
The Category 1 filer has previously
•
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).
taxed E&P related to section 965 that
is reportable on Schedule P (Form
5471).
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.
Category 1 Filers—Exceptions
From Filing
See Regulations section
Certain constructive owners.
1.6046-1(f)(3) for exceptions.
A Category 1 filer does not have to
•
file Form 5471 if all of the following
Additional Information for
Category 2 Filers
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.
Foreign sales corporations (FSCs).
This exception implements the
relief for certain Category 5 filers
announced in section 8.04 of Rev.
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.
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
Category 2 Filer
Form 5471 if:
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
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
A Category 1 filer does not have to
•
file Form 5471 if it:
transactions):
1. Does not own a direct or
indirect interest in the foreign
corporation, and
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.
2. Is required to file Form 5471
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
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
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:
constructive ownership exception.
See Regulations section 1.6038-2(j)
(2) and (3), and Regulations section
1.6038-2(l) for additional information.
ownership is attributed furnishes all of
the information required of the
Category 2 filer.
No section 958(a) U.S. sharehold-
er. 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
Other filing exceptions. Certain
other filing exceptions apply to all
categories of filers. See Additional
Filing Exceptions, later.
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
1. 10% or more of the total value
of the foreign corporation's stock, or
foreign-controlled section 965 SFC.
This exception extends the relief for
Category 5 filers announced in
2. 10% or more of the total
combined voting power of all classes
of stock with voting rights.
Instructions for Form 5471 (Rev. 01-2024)
3
acquisition, meets the 10% stock
ownership requirement (defined
below) with respect to the foreign
corporation;
2. The name, address, identifying
number, and number of shares
6013(h), relating to nonresident aliens
who become residents of the United
subscribed to by each suscriber to the States during the tax year and are
foreign corporation's stock.
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).
2. A U.S. person who acquires
stock which, without regard to stock
already owned on the date of
Foreign sales corporations (FSCs).
Category 3 filers who are
shareholders, officers, and directors
of an FSC (as defined in section 922,
as in effect before its repeal) must file
Form 5471 and a separate
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.
Schedule O to report changes in the
ownership of the FSC.
See Regulations section
Category 3 Filers—Exception
From Filing
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
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.
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:
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.
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.
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).
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.
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).
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.
Additional Information for
Category 4 Filers
See Regulations section
Foreign sales corporations (FSCs).
1.6046-1(f)(3) for exceptions.
Category 4 filers who are
•
U.S. person. For purposes of
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
shareholders of an FSC are not
subject to the subpart F rules with
respect to the FSC for:
Category 4, a U.S. person is:
1. A citizen or resident of the
United States;
1. Exempt foreign trade income;
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;
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
3. An individual for whom an
election is in effect under section
Instructions for Form 5471 (Rev. 01-2024)
4
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.
4. An estate or trust that is not a
foreign estate or trust, as defined in
section 7701(a)(31).
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
See section 957(c) for exceptions.
In general, a CFC is a foreign
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
corporation that has U.S.
Category 4 filers who are
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:
•
shareholders of an FSC are subject to
the subpart F rules for:
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, later.
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
1. The total combined voting
power of all classes of its voting stock,
or
2. The total value of the stock of
the corporation.
Category 5 Filers
For purposes only of taking into
account income described in section
953(a) (relating to insurance income),
a CFC also includes a foreign
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:
3. All other FSC income that is not
foreign trade income or investment
income or carrying charges.
corporation that is described in
section 957(b); and for purposes only
of taking into account related person
insurance income, a CFC includes a
foreign corporation described in
section 953(c)(1)(B).
Category 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.
Category 5a Filer
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.
Category 5a filers, Category 5b filers,
and Category 5c filers.
A Category 5a filer is a Category 5
filer that is not a Category 5b or 5c
filer.
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.
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,
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:
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
1. Owns, within the meaning of
2. Is required to file Form 5471
section 958(a), stock of a
solely because of constructive
foreign-controlled CFC; and
ownership from a nonresident alien.
U.S. person. For purposes of
2. Is not related (using principles
of section 954(d)(3)) to the
foreign-controlled CFC.
No statement is required to be
attached to the tax return of a
Category 5, a U.S. person is:
1. A citizen or resident of the
Category 4 filer claiming either
United States;
constructive ownership exception.
See Regulations section 1.6038-2(j)
(2) and (3), and Regulations section
1.6038-2(l) for additional information.
Foreign-controlled CFC. For
purposes of Category 5b, a
2. A domestic partnership;
3. A domestic corporation; or
foreign-controlled CFC is a foreign
corporation that is a CFC that would
Instructions for Form 5471 (Rev. 01-2024)
5
not be a CFC if the determination
were made without applying
1. All other types of FSC income
(including section 923(a)(2)
5.02 of Notice 2018-13, 2018-6 I.R.B.
341, for additional information.
Unrelated constructive U.S. share-
holder. A Category 5 filer does not
have to file Form 5471 if all of the
following conditions are met.
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.
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.
1. The foreign corporation is a
Category 5c Filer
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.
3. The filer is not related, using
principles of section 954(d)(3), to the
foreign-controlled CFC.
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,
Category 5 Filers—Exceptions
From Filing
Certain constructive owners.
See section 8.04 of Rev. Proc.
additional information.
A Category 5 filer does not have to
•
file Form 5471 if all of the following
Related constructive U.S. share-
holder. For purposes of Category 5c,
a related constructive U.S.
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.
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
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
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
2. Is related (using principles of
section 954(d)(3)) to the
1120-FSC, if the filer has inclusions
with respect to the FSC under section
951(a) (as described above).
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.
Other filing exceptions. Certain
other filing exceptions apply to all
categories of filers. See Additional
Filing Exceptions next.
A Category 5 filer does not have to
•
Additional Information for
Category 5 Filers
Additional Filing
Exceptions
file Form 5471 if it:
1. Does not own a direct or
indirect interest in the foreign
corporation, and
Foreign sales corporations (FSCs).
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
Category 5 filers who are
•
shareholders of an FSC are not
subject to the subpart F rules with
respect to the FSC for:
2. Is required to file Form 5471
solely because of constructive
ownership from a nonresident alien.
1. Exempt foreign trade income;
No statement is required to be
attached to the tax return of a
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 5 filer claiming either
corporation for the same period, a
joint information return that contains
the required information may be filed
with your tax return or with the tax
return of any one of the other persons.
For example, a U.S. person described
in Category 5 may file a joint Form
5471 with a Category 4 filer or another
Category 5 filer; similarly, a U.S.
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. sharehold-
er. 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
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).
Category 5 filers who are
•
shareholders of an FSC are subject to
the subpart F rules for:
which it was a CFC and the CFC is a
foreign-controlled CFC. See section
However, for Category 3 filers, the
required information may only be filed
Instructions for Form 5471 (Rev. 01-2024)
6
by another person having an equal or
greater interest (measured in terms of
value or voting power of the stock of
the foreign corporation).
CFC is considered to have
types of transactions that the IRS has
determined to be a tax avoidance
transaction and identified by notice,
regulation, or other published
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
guidance as a listed transaction.
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
2. Any transaction offered under
conditions of confidentiality for which
the corporation (or a related party)
paid an advisor a fee of at least
$250,000.
3. Certain transactions for which
the corporation (or a related party)
has contractual protection against
disallowance of the tax benefits.
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.
Regulations section 1.6038-2(j)(1)
and (3) for additional information.
Domestic corporations.
1. Any listed transaction, which is
a transaction that is the same as or
substantially similar to one of the
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/
Filing Requirements for Categories of Filers
Table of Required Information
Category of Filer
Required Information*
1a
1b
1c
2
3
4
5a
5b
5c
The identifying information on page
1 of Form 5471 above Schedule A;
see Specific Instructions
procedural rules regarding the
election under section 953(d).
Schedule A
Schedule B, Part I
Schedule B, Part II
Schedules C and F
Separate Schedule E
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:
1
2
1
2
Schedule E-1 (included with
separate Schedule E)
1
1
Schedule G
A purchaser (or its U.S.
•
shareholder) must attach a copy of
Form 8883, Asset Allocation
Separate Schedule G-1
Separate Schedule H
Schedule I
Statement Under Section 338, to the
first Form 5471 for the new foreign
target corporation (see the
Instructions for Form 8883 for details);
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
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).
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.
Reportable transaction disclosure
statement. If a U.S. shareholder of a
Instructions for Form 5471 (Rev. 01-2024)
7
4. Certain transactions resulting in section 6038(a) within the time
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
a loss of at least $10 million in any
single year or $20 million in any
combination of years.
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.
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
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.
For more information, see
Any person who fails to file or report
•
Regulations section 1.6011-4. Also,
see the Instructions for Form 8886.
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.
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.
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
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”
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
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.
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.
Reportable transactions by materi-
al advisors. Material advisors to any
reportable transaction must disclose
certain information about the
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
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.
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.
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. 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.
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.
Penalties
Example. During its annual
accounting period, the foreign
Failure to file information required
by section 6038(a) (Form 5471 and
Schedule M).
corporation paid income taxes of
30,255,400 Yen to Japan. The
Schedule E instructions specify that
the foreign corporation must translate
these amounts into U.S. dollars at the
average exchange rate for the tax year
A $10,000 penalty is imposed for
•
each annual accounting period of
each foreign corporation for failure to
furnish the information required by
Instructions for Form 5471 (Rev. 01-2024)
8
to which the tax relates in accordance Specifications for Substitute Forms
362(e)(2)(C) to limit the transferor's
basis in the stock received instead of
the transferee's basis in the
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
and Schedules, which reprints the
most recent applicable revenue
procedure. Pub. 1167 is available at
transferred property. The election is
made by a statement as provided in
Regulations section 1.362-4(d)(3).
Dormant Foreign Corporations
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.
Do not attach the statement
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.
described above to Form
!
CAUTION
5471.
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
Enter the name of the payor entity in
•
column (a).
Enter the payor entity’s employer
•
If you elect the summary
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.
identification number (EIN) or
procedure, complete only page 1 of
Form 5471 for each dormant foreign
corporation as follows.
reference ID number in column (b).
Enter “JA” in column (d).
•
•
•
Enter “JPY” in column (i).
The top margin of the summary
•
Enter “30,255,400 Yen” in column
return must be labeled “Filed Pursuant
to Rev. Proc. 92-70 for Dormant
Foreign Corporation.”
(j).
Foreign Disregarded Entities
and Branches
Enter “108.8593” in column (k).
•
Enter “277,931” in column (l).
•
Include filer information such as
•
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
name and address, items A through
C, and tax year.
Computer-Generated Form
5471 and Schedules
Include corporate information such
•
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
as the dormant corporation's annual
accounting period (below the title of
the form) and items 1a, 1b, 1c, and
1d.
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.
For more information, see Rev. Proc.
92-70.
substituteforms@irs.gov, or requests
may be mailed to:
File this summary return in the
manner described under When and
Where To File, earlier.
Internal Revenue Service
Attention: Substitute Forms
Program
Treaty-Based Return Positions
SE:W:CAR:MP:P:TP
1111 Constitution Ave. NW
Room 6554
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):
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,
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.
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.
Overrides or modifies any provision
•
of the Internal Revenue Code; and
Causes, or potentially causes, a
•
Important. Be sure to attach the
approval letter to Form 5471.
reduction of any tax incurred at any
time.
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
Identifying Information
See Form 8833 for exceptions.
Annual Accounting Period
Failure to make a required
disclosure may result in a $1,000
penalty ($10,000 for a C corporation).
See section 6712.
Enter, in the space provided below the
title of Form 5471, the annual
attachment is not necessary.
Every year, the IRS issues a
revenue procedure to provide
guidance for filers of
accounting period of the foreign
corporation for which you are
Section 362(e)(2)(C) Elections
furnishing information. Except for
information contained on Schedule O,
report information for the tax year of
the foreign corporation that ends with
computer-generated forms. In
addition, every year, the IRS issues
Pub. 1167, General Rules and
The transferor and transferee in
certain section 351 transactions may
make a joint election under section
Instructions for Form 5471 (Rev. 01-2024)
9
or within your tax year. When filing
Schedule O, report acquisitions,
dispositions, and organizations or
reorganizations that occurred during
your tax year.
has a P.O. box, show the box number
instead.
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.
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.
Section 898 specified foreign cor-
poration (SFC). The annual
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).
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.
Item A—Identifying Number
The identifying number of an
individual is his or her social security
number (SSN). The identifying
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.
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.
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
For these purposes, section 898(b)
defines an SFC as any foreign
corporation:
foreign-controlled CFC with respect to
which there is no related section
958(a) U.S. shareholder, if information
satisfying the requirements of
Item B—Category of Filer
1. That is treated as a CFC for any
Complete item B to indicate the
category or categories that describe
the person filing this return. If more
than one category applies, check all
Filers, earlier.
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.
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
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.
unrelated constructive U.S.
For more information, see section
898 and Rev. Proc. 2006-45, 2006-45
I.R.B. 851, available at IRS.gov/irb/
modified by Rev. Proc. 2007-64,
2007-42 I.R.B. 818, available at
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.
Item C—Percentage of Voting
Stock Owned
Enter the total percentage of the
foreign corporation's voting power you
owned directly, indirectly, or
constructively at the end of the
corporation's annual accounting
period.
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.
Name of Person Filing This
Return
The name of the person filing Form
5471 is generally the name of the U.S.
person described in the applicable
category or categories of filers (see
Categories of Filers, earlier). However,
in the case of a consolidated return,
enter the name of the U.S. parent in
the field for “Name of person filing this
return.” Be sure to list each U.S.
shareholder of the foreign corporation
in Schedule B, Part I.
Item D—Final Year
Check the item D checkbox only if this
is the final year of the foreign
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.
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.
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.
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
Address
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.
Include the suite, room, or other unit
number after the street address. If the
post office does not deliver mail to the
street address and the U.S. person
shareholder, as applicable, on the
Instructions for Form 5471 (Rev. 01-2024)
10
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 H—Person(s) on Whose
Behalf This Information Return
Is Filed
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.
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
Item G—Alternative Information
Code
If the item F checkbox is checked,
enter the applicable code from the list
provided below.
All persons identified in item H
must complete a separate
!
CAUTION
Schedule P (Form 5471) if the
complete a joint Form 5471 according
to the applicable column(s) of the
Filers, earlier. This includes
person is a U.S. shareholder
described in Category 1a, 1b, 4, 5a, or
5b. In such a case, the Schedule P
must be attached to the statement
described above.
Audited separate-entity financial
statements of the foreign corporation that
01 are prepared in accordance with U.S.
generally accepted accounting principles
(U.S. GAAP).
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).
Item 1b(2)—Reference ID
Number
Audited separate-entity financial
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
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.
statements of the foreign corporation that
02
are prepared on the basis of international
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
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
separate Schedule I to them to assist
them in completing their tax return.
corporation is organized (“local-country
GAAP”).
A separate Worksheet 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 Worksheet H-1, send a
copy of their separate Worksheet H-1
to them to assist them in completing
their tax return.
Unaudited separate-entity financial
statements of the foreign corporation that
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
04
are prepared in accordance with U.S.
GAAP.
Unaudited separate-entity financial
05 statements of the foreign corporation that
are prepared on the basis of IFRS.
Unaudited separate-entity financial
Note. New Worksheet H-1 may be
found later in these instructions. See
Instructions, later.
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.
statements of the foreign corporation that
06
are prepared on the basis of local-country
corporation in order to keep track of
the corporation from tax year to tax
year.
GAAP.
Separate-entity records used by the
07
foreign corporation for tax reporting.
The reference ID number must
Separate-entity records used by the
meet the requirements set forth below.
foreign corporation for internal
08
management controls or regulatory or
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
other similar purposes.
The name, address, and EIN (or
•
Information described in a code
listed above qualifies as alternative
information only if information
reference ID number) of the foreign
corporation(s).
permission to use these numbers.
A statement that their filing
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
•
described in any preceding code is
not “readily available” (as defined in
section 3.04 of Rev. Proc. 2019-40).
For example, information described in
code 03 above qualifies as alternative
information only if information
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.
described in codes 01 and 02 is not
readily available.
The IRS Service Center where the
•
For more information, see Rev.
return was or will be filed. If the return
was or will be filed electronically, enter number should also be entered on
“e-file.”
Form 8858 if the foreign corporation is
Instructions for Form 5471 (Rev. 01-2024)
11
listed as a tax owner of an FDE or FB
on Form 8858. See the instructions for this election. For the first year that
Form 8858, line 3c(2), for more Form 5471 is filed after an entity
information. Also, if a U.S. shareholder classification election is made on
is required to file Schedule A (Form behalf of the foreign corporation on
foreign corporation to have an EIN for
standard. These codes are available
codes. Click on List One (XLS).
8992) or Schedule B (Form 8992) with Form 8832, the new EIN must be
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.
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.
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).
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 H, later.
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
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
characters are permitted.
Schedule B, Part I and Part II.
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.
Part I
Category 3 and 4 filers must complete
Schedule B, Part I, for U.S. persons
that owned (at any time during the
annual accounting period), directly or
indirectly through foreign entities, 10%
or more of the total combined voting
power of all classes of stock entitled
to vote of the foreign corporation, or
10% or more of the total value of
shares of all classes of stock of the
foreign corporation.
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.
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.
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.
Correlation issues. There are some
situations that warrant correlation of a
new reference ID number with a
Effective beginning with tax
year 2022, several changes
previous reference ID number when
assigning a new reference ID number
to a foreign corporation. For example:
!
CAUTION
were made to the principal
business activities and codes listed at
the end of these instructions. See the
revised list before entering a six-digit
code and the description of the
In the case of a merger or
•
acquisition, a Form 5471 filer must
use a reference ID number that
correlates the previous reference ID
number with the new reference ID
number assigned to the foreign
corporation; or
Column (e). Enter each
shareholder's allocable percentage of
the foreign corporation's subpart F
income.
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
Part II
In the case of an entity
•
Category 1a, 1c, 3, 4, 5a, and 5c filers
must complete Part II.
classification election that is made on
behalf of a foreign corporation on
Form 8832, Regulations section
301.6109-1(b)(2)(v) requires the
three-character alphabet code for the
foreign corporation's functional
currency using the ISO 4217
Report the direct shareholders of
the foreign corporation. In the case of
Instructions for Form 5471 (Rev. 01-2024)
12
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
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.
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
Schedule F
Report all information in U.S. dollars.
Generally, the foreign corporation's
balance sheet is prepared in
information requested in columns (b),
(c), and (d) for each such regarded
entity owner.
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).
functional currency and translated to
U.S. dollars using U.S. GAAP
translation rules. If the foreign
corporation uses DASTM, the tax
balance sheet on Schedule F should
be prepared and translated into U.S.
dollars according to Regulations
section 1.985-3(d), rather than U.S.
GAAP.
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
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.
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.
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.
Include all derivatives, both
Schedule C
short-term and long-term.
Report all information in the foreign
corporation's functional currency in
accordance with U.S. GAAP and
translate using U.S. GAAP translation
principles.
Note. If there is an income tax
Schedule G
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.
Note. Category 1b and 5b filers are
not required to file Schedule G for
foreign-controlled section 965 SFCs
and foreign-controlled CFCs,
respectively.
If the foreign corporation uses the
DASTM under Regulations section
1.985-3, the functional currency
column should reflect local
Question 1
hyperinflationary currency amounts
computed in accordance with U.S.
GAAP. The U.S. dollar column should
reflect such amounts translated into
dollars under U.S. GAAP translation
rules. Differences between this U.S.
dollar GAAP column and the U.S.
dollar income or loss figured for tax
purposes under Regulations section
1.985-3(c) should be accounted for on
Schedule H. See Schedule H, Special
rules for DASTM, later.
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.
Lines 23 and 24. Enter amounts
defined in ASC 220 (Income
Statement—Reporting
Comprehensive Income).
1. Name and EIN (if any) of the
foreign partnership.
Line 23a. Enter foreign currency
translation adjustments before the
income tax expense (benefit) is
allocated.
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.
Line 23b. Enter other
Line 8. Enter foreign currency
transaction gain or loss reported on
the income statement. For amounts
included in Other Comprehensive
later. Enter unrealized gain or loss on
line 8a and realized gain or loss on
line 8b.
Line 16. Enter transactional taxes
excluding items reportable in income
tax expense (benefit). Report income
taxes on line 21.
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.
3. Name of the partnership
representative (if any).
4. Beginning and ending dates of
the foreign partnership's tax year.
Question 3
Line 23c. Enter the income tax
expense (benefit) allocated to OCI
items in the intraperiod allocation.
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
Important. Differences between the
functional currency amount of income
Instructions for Form 5471 (Rev. 01-2024)
13
the assets and liabilities of the FDE for payments also include amounts
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
purposes of U.S. income tax law.
received or accrued by the foreign
corporation in connection with the
acquisition of depreciable or
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
amortizable property (section 59A(d)
(2)), reinsurance payments (section
59A(d)(3)), and certain payments
relating to expatriated entities (section
59A(d)(4)).
deduction is being claimed, check the
“No” box on line 6a and go to line 7.
Question 9a
Under section 367(d), a U.S.
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.
schedules on Form 8858 must be
included in determining the amounts
reported on the equivalent schedules
as follows.
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.
IF amounts were reported
on...
THEN take those
amounts into account
(converting from
GAAP to tax as
necessary) when
determining the
amounts to be
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
reported on...
Form 8858, Schedule C
Form 8858, Schedule F
Form 8858, Schedule H
Form 8858, Schedule J
Schedule M (Form 8858)
Form 5471,
Schedule C.
Question 9b
Form 5471,
Schedule F.
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.
Schedule H (Form
5471).
Schedules E and E-1
(Form 5471).
Schedule M (Form
5471).
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.
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.
Question 10
A foreign corporation may qualify as
an expatriated foreign subsidiary
under Regulations section
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
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
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
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.
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,
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.
Schedule K, Question 21.
Question 6
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
Check the “Yes” box on line 6a if the
filer is claiming a deduction under
section 250 with respect to
Question 14
Check the “Yes” box on line 14 if you
answer “Yes” to any of the 22
foreign-derived intangible income
(FDII), and enter the amounts
questions in the Schedule G, Line 14
table below. If “Yes,” enter the
requested on lines 6b, 6c, and 6d.
Enter U.S. dollar amounts on lines 6b,
6c, and 6d, translated from functional
corresponding code(s) from the table
Instructions for Form 5471 (Rev. 01-2024)
14
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.
Form 5471, Schedule G, Line 14
Question
See Worksheet A in If “Yes,”
Code
If “Yes,” content of
the Schedule I
instructions
corresponding description statement to be
code to enter
on Schedule G,
line 14
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
High tax
Amount excluded by
reason of the de
minimis rule (but
only to the extent not
already included in
amounts below)
2
3
4
During the tax year, did the CFC receive any item of income
In other words, is
HT
Sum of the amounts
from lines 13g, 14d,
15d, 16d, 18d, and
19d
that was subject to an effective rate of income tax imposed by a line 13g, 14d, 15d,
foreign country greater than 90% of the maximum rate of tax
specified in section 11?
16d, 18d, or 19d of
Worksheet A greater
than zero?
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
AHC
Deductions
taken into
account
Sum of the amounts
from lines 13b, 13d,
13e, 14b, 15b, and
16b
During the tax year, did the CFC have any gains or losses that In other words, are
(a) arise out of commodity hedging transactions; (b) are active any amounts
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?
Active/
hedging
Sum of the excluded
amounts described
described in section
954(c)(1)(C)(i), (ii), or
(iii) excluded from
line 1c of Worksheet
A?
commodities in section 954(c)(1)
(C)(i), (ii), and (iii)
5
During the tax year, did the CFC have excess foreign currency In other words, are
BN
Business
needs
Amount excluded
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?
any amounts
excluded from line 1d
of Worksheet A by
reason of being
attributable to a
transaction(s) directly
related to the
business needs of
the foreign
corporation?
6
7
8
During the tax year, did the CFC receive, from a person other
In other words, are
ARR
EF
Active rents/ Amount excluded
royalties
than a related person within the meaning of section 954(d)(3), any amounts
rents or royalties that were derived in the active conduct of a
trade or business?
described in section
954(c)(2)(A)
excluded from line 1a
of Worksheet A?
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
Certain
export
Amount excluded
Amount excluded
described in section
954(c)(2)(B)
financing
excluded from line 1a
of Worksheet A?
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
RD
Regular
dealers
described in section
954(c)(2)(C)(i)
excluded from line 1a
of Worksheet A?
Instructions for Form 5471 (Rev. 01-2024)
15
Form 5471, Schedule G, Line 14 (continued)
Question
See Worksheet A in If “Yes,”
Code
If “Yes,” content
of statement to be
attached to Form
5471
the Schedule I
instructions
corresponding description
code to enter
on Schedule G,
line 14
9
During the tax year, was the CFC a securities dealer within the In other words, are
SD
Securities
dealers
Amount excluded
meaning of section 475? If so, did the foreign corporation
any amounts
derive any interest or dividend or equivalent amount described described in section
in section 954(c)(1)(E) or (G) from any transaction entered into 954(c)(2)(C)(ii)
in the ordinary course of its trade or business as a securities
dealer?
excluded from line 1a
of Worksheet A?
10 During the tax year, did the CFC receive dividends* or
In other words, are
SCDI
Same country Amount excluded
dividends/
interest
interest** from a related person that (a) is a corporation created any amounts
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?
described in section
954(c)(3)(A)(i)
excluded from line 1a
of Worksheet A?
*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).
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
In other words, are
any amounts
SCRR
Same country Amount excluded
rents/royalties
privilege of using, property within the country under the laws of described in section
which the CFC is created or organized?
954(c)(3)(A)(ii)
*Rents or royalties (other than rents or royalties that reduce the excluded from line 1a
payor's subpart F income or create or increase a deficit that
may reduce the subpart F income of the payor or another CFC).
of Worksheet A?
12 During the tax year, did the CFC receive or accrue from a
related CFC dividends, interest (including factoring income
In other words, are
any amounts
LT
Look through Amount excluded
treated as income equivalent to interest for purposes of section excluded from line 1a
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 look-through rule
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).
of Worksheet A by
reason of the
described in section
954(c)(6)?
13 During the tax year, did the CFC derive income (either directly In other words, are
AC
Agricultural
commodities
Amount excluded
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?
any amounts
excluded from line 3
of Worksheet A by
reason of the special
rule in Regulations
section 1.954-3(a)(1)
(ii)?
14 During the tax year, did the CFC derive income (either directly In other words, are
SCM
Same country Amount excluded
manufacturing
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
any amounts that are
derived in connection
with property that
manufactured in the same country under the laws of which the does not satisfy
CFC is created or organized?
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))?
Instructions for Form 5471 (Rev. 01-2024)
16
Form 5471, Schedule G, Line 14 (continued)
Question
See Worksheet A in If “Yes,”
Code
If “Yes,” content
of statement to be
attached to Form
5471
the Schedule I
instructions
corresponding description
code to enter
on Schedule G,
line 14
15 During the tax year, did the CFC derive income (either directly In other words, are
SCSU
Same country Amount excluded
sales/use
or through a branch or similar establishment, for example, a
disregarded entity) in connection with the purchase or sale
any amounts that are
derived in connection
from, to, or on behalf of a related person, of personal property with property that
purchased or sold for use or consumption in the same country does not satisfy
under the laws of which the CFC is created or organized?
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))?
16 During the tax year, did the CFC derive income (either directly In other words, are
PM
Physical
manufacturing
Amount excluded
or through a branch or similar establishment, for example, a
disregarded entity) in connection with the purchase or sale
any amounts
excluded from line 3
from, to, or on behalf of a related person, of personal property of Worksheet A by
manufactured by the CFC within the meaning of Regulations
section 1.954-3(a)(4)(ii) or (iii)?
reason of
Regulations section
1.954-3(a)(4)(ii) or
(iii)?
17 During the tax year, did the CFC derive income (either directly In other words, are
SC
BR
Substantial
contribution
Amount excluded
Amount excluded
or through a branch or similar establishment, for example, a
disregarded entity) in connection with the purchase or sale
any amounts
excluded from line 3
from, to, or on behalf of a related person, of personal property of Worksheet A by
manufactured by the CFC within the meaning of Regulations
section 1.954-3(a)(4)(iv)?
reason of
Regulations section
1.954-3(a)(4)(iv)?
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
In other words, are
any amounts
Branch
excluded from line 3
of Worksheet A by
reason of
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
disregarding a
branch or similar
owned subsidiary separate from the CFC under section 954(d) establishment
(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)?
(including a
disregarded entity) of
the CFC as separate
from the CFC?
19 During the tax year, was the CFC an eligible CFC (as defined In other words, are
AF
AI
Active
Amount excluded
Amount excluded
in section 954(h)(2)) that derived qualified banking or
financing income (as defined in section 954(h)(3))?
any amounts
financing
excluded from lines
1a–1i of Worksheet A
by reason of the
special rule
described in section
954(h)?
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
Active
insurance
excluded from lines
1a–1i of Worksheet A
by reason of the
special rule
described in section
954(i)?
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
Instructions for Form 5471 (Rev. 01-2024)
17
Form 5471, Schedule G, Line 14 (continued)
Question
See Worksheet A in If “Yes,”
Code
If “Yes,” content
of statement to be
attached to Form
5471
the Schedule I
instructions
corresponding description
code to enter
on Schedule G,
line 14
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?
In other words, is
line 58 of Worksheet
A greater than zero?
PRS
Pro Rata
Share
The amounts from
lines 58 and 59 of
Worksheet A
23 Is the U.S. person filing this return relying on any exception(s),
exclusion(s), or other provision(s) not listed above to reduce
or exclude any amounts reported or reportable as subpart F
income (of or with respect to the CFC)?
XX
Other
Amount excluded,
reduction amount,
or other amount not
reported or
reportable
of the foreign corporation such that no
amount is treated as an extraordinary
reduction amount or tiered
Question 15
Questions 19a and 19b
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.
Complete lines 19a and 19b only if the
filer is a domestic corporation. In
completing these lines, do not
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.
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
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
Check the “Yes” box if the filer issued
a covered debt instrument in any of
the transactions described in
Question 16
For the foreign corporation’s annual
accounting period with respect to
which reporting is being made on this
Form 5471, if the foreign corporation
is required to file a U.S. income tax
return (for example, Form 1120-F),
check the “Yes” box if the foreign
corporation has previously disallowed
interest expense under section 163(j)
carried forward to the current tax year.
If “Yes,” enter the amount from the
prior year Form 8990, line 31.
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
required under Regulations section
1.245A-5(e)(3)(i)(D).
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
Question 18a
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
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
Question 17a
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 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.
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).
Question 18b
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
Debt that the filer treats as stock
pursuant to Regulations section
1.385-3 should still be included when
completing line 19a.
Question 17b
If the answer to the question on
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).
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
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
Instructions for Form 5471 (Rev. 01-2024)
18
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).
Line 1a
Lines 1e Through 1h
Corporate U.S. shareholders should
Enter on lines 1e through 1h the
enter the foreign-source portion of any amounts from Worksheet A, lines 63,
subpart F income inclusions
65, 67, and 69, respectively. However,
attributable to the sale or exchange by corporate U.S. shareholders should
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.
report on line 1e the amount from
Worksheet A, line 63, less the
amount, if any, reported on line 1a.
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
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.
shareholders should leave line 1a
blank.
Line 1b
Enter the amount of the U.S.
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
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
Adjusted net foreign base company
•
17).
Adjusted net insurance income
•
1.1275-1(b)(1).
Adjusted net related person
•
Schedule I
line 19).
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.
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
International boycott income
•
Illegal bribes, kickbacks, and other
•
Income described in section 952(a)
•
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
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
information about tiered hybrid
dividends.
Line 1c
2019-40, earlier, for more details.
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
Note. A separate Schedule I must be
filed by or for each Category 4, 5a, or
5b U.S. shareholder of the foreign
corporation with respect to which
reporting is furnished on this Form
5471.
corporation. See Regulations section
1.245A-5(d) for further guidance on
tiered extraordinary disposition
amounts.
Line 1
Subpart F income. U.S.
shareholders of CFCs with subpart F
income must report that income on
their tax returns. For more information,
see sections 245A, 951, 952, and
964(e).
Line 1d
Enter the U.S. shareholder's subpart F
income inclusion attributable to tiered
extraordinary reduction amounts
resulting from extraordinary
section 1.952-1(f) for further guidance
on recharacterization of E&P as
subpart F income.
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).
reductions. See Regulations section
1.245A-5(f) for further guidance on
tiered extraordinary reduction
amounts.
Line 2
Report on line 2 the section 956
amount with respect to the U.S.
Instructions for Form 5471 (Rev. 01-2024)
19
shareholder. See Worksheet B,
line 19.
line of other corporate income tax
returns.
Line 5b
Enter the amount of the dividends
received by the shareholder from the
foreign corporation that is an
Line 3
Reserved for future use.
Line 6
If previously taxed E&P (PTEP) were
distributed, enter the amount of
foreign currency gain or (loss)
extraordinary disposition amount. See
Regulations section 1.245A-5(c) for
rules for calculating an extraordinary
disposition amount.
Line 4
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
later).
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).
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
Reporting Amounts on Lines 1
Through 4 on Your Income Tax
Return
extraordinary reduction amount. See
Regulations section 1.245A-5(e) for
For a corporate shareholder, enter the rules for calculating an extraordinary
result from line 1a on Form 1120,
Schedule C, line 16a; enter the result
from line 1b on Form 1120,
reduction amount.
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
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.
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
Line 5d
Enter the amount of hybrid dividends
received by the U.S. shareholder from
the foreign corporation. In general, in
the case of a domestic corporation
that is a U.S. shareholder with respect
to a CFC, a dividend received by the
domestic corporation from the CFC is
a hybrid dividend to the extent of the
sum of the U.S. shareholder’s hybrid
deduction accounts with respect to
shares of stock of the CFC. See
noncorporate tax returns.
comparable line of other noncorporate
tax returns.
Line 8a
Check the “Yes” box on line 8a if the
U.S. shareholder completing this form
had an extraordinary disposition
account with respect to the foreign
corporation having a balance greater
than zero at any time during the tax
year of the foreign corporation. See
Regulations section 1.245A-5(c) for
rules regarding an extraordinary
disposition account.
Line 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.
section 245A(e) and Regulations
section 1.245A(e)-1(b) for additional
information about hybrid dividends.
Line 8b
Note. The corporate U.S.
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.
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.
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 5e
Enter on line 5e dividends not
reported on line 5a, 5b, 5c, or 5d.
Note. The corporate U.S.
Line 8c
shareholder should include the line 5e
amount on Form 1120, Schedule C,
line 14, column (a), or the comparable
Enter on line 8c the CFC’s total
extraordinary disposition account
balance with respect to all U.S
shareholders of the CFC at the
Instructions for Form 5471 (Rev. 01-2024)
20
beginning of the CFC year and at the
end of the CFC tax year. Attach a
statement detailing any differences
between the starting and ending
balances reported on line 8c.
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.
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.
Line 9
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
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
A hybrid deduction account with
respect to a share of stock of a CFC
reflects the amount of hybrid
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 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
maintenance of hybrid deduction
accounts.
deductions of the CFC, or hybrid
dividends paid by the CFC). For
example, if the CFC is an upper-tier
instrument of the CFC that is stock for
U.S. tax purposes. A hybrid deduction
includes a deduction allowed to the
Instructions for Form 5471 (Rev. 01-2024)
21
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)
(excluding amounts described in sections 954(c)(2), (3), and (6))
1a
b Excess of gains over losses from certain property transactions
(section 954(c)(1)(B))
1b
1c
1d
1e
1f
c
d
Excess of gains over losses from commodity transactions (section 954(c)(1)(C))
Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D))
e Income equivalent to interest (section 954(c)(1)(E))
Net income from a notional principal contract (section 954(c)(1)(F))
f
1g
g Payments in lieu of dividends (section 954(c)(1)(G))
h Certain amounts received for services under personal service
contracts (see section 954(c)(1)(H))
1h
i
Certain amounts from sales of partnership interests to which the
look-through rule of section 954(c)(4) applies
1i
2
3
4
5
2
3
4
5
6
Gross foreign personal holding company income. Add lines 1a through 1i
Gross foreign base company sales income (see section 954(d))
Gross foreign base company services income (see section 954(e))
Gross foreign base company income. Add lines 2 through 4
Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 18 and
19)
Gross foreign base company income and gross insurance income. Add lines 5 and 6
Enter 5% of total gross income (as computed for income tax purposes)
Enter 70% of total gross income (as computed for income tax purposes)
6
7
8
7
8
9
9
10
11
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)
12
13 Adjusted net foreign personal holding company income:
a Enter amount from line 2
b Expenses directly related to amount on line 2
c Subtract line 13b from line 13a
d Related person interest expense (see section 954(b)(5))
13a
13b
13c
13d
e Other expenses allocated and apportioned to the amount on line 2
under section 954(b)(5)
13e
13f
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
13g
13h
14 Adjusted net foreign base company sales income:
a Enter amount from line 3
14a
b Expenses allocated and apportioned to the amount on line 3 under
section 954(b)(5)
14b
14c
14d
c
d
Net foreign base company sales income. Subtract line 14b from line 14a
Net foreign base company sales income excluded under high-tax exception
14e
15e
16e
e Subtract line 14d from line 14c
15 Adjusted net foreign base company services income:
a Enter amount from line 4
15a
15b
15c
15d
b Expenses allocated and apportioned to line 4 under section 954(b)(5)
c
d
Net foreign base company services income. Subtract line 15b from line 15a
Net foreign base company services income excluded under high-tax exception
e Subtract line 15d from line 15c
16 Adjusted net full inclusion foreign base company income:
a Enter the excess, if any, of line 11 over line 7
b Expenses allocated and apportioned under section 954(b)(5)
16a
16b
16c
16d
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
c
d
e Subtract line 16d from line 16c
Instructions for Form 5471
22
Worksheet A
Worksheet A (continued) (See instructions.)
17
18
Adjusted net foreign base company income. Add lines 13h, 14e, 15e, and 16e
Adjusted net insurance income (other than related person insurance income):
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17
a
b
Enter amount from line 6 (other than related person insurance income)
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18a
Expenses allocated and apportioned to the amount on line 18a under section
953 .
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18b
18c
18d
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c
d
e
Net insurance income. Subtract line 18b from line 18a .
Net insurance income excluded under high-tax exception .
Subtract line 18d from line 18c .
Adjusted net related person insurance income:
Enter amount from line 6 that is related person insurance income
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18e
19
a
b
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19a
Expenses allocated and apportioned to the amount on line 19a under section
953 .
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19b
19c
19d
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c
d
e
Net related person insurance income. Subtract line 19b from line 19a .
Net related person insurance income excluded under high-tax exception .
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)
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19e
20
21
20
21
22
23
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22
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)) .
Exclusions under section 959(b) and section 961(c) basis that apply to line 13h
amount
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23
24
25
26
27
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24
25
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Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract the sum of lines
24 and 25 from line 13h
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26
29
32
Enter the portion of line 14e that is U.S. source income effectively connected
with a U.S. trade or business (section 952(b)) .
Exclusions under section 959(b) that apply to line 14e amount
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27
28
-0-
28
29
Section 954(d) subpart F Foreign Base Company Sales Income. Subtract the sum of lines 27 and
28 from line 14e .
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30
Enter the portion of line 15e that is U.S. source income effectively connected
with a U.S. trade or business (section 952(b)) .
Exclusions under section 959(b) that apply to line 15e amount
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30
31
-0-
31
32
Section 954(e) subpart F Foreign Base Company Services Income. Subtract the sum of lines 30
and 31 from line 15e
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33
Enter the sum of the portion of lines 16e, 18e, 19e, 20, 21, and 22 that is U.S.
source income effectively connected with a U.S. trade or business (section
952(b)) .
Exclusions under section 959(b) that apply to line 16e, 18e, 19e, 20, 21, and
22 amounts
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33
34
34
35
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Other subpart F income. Subtract the sum of lines 33 and 34 from the sum of lines 16e, 18e, 19e,
20, 21, and 22
Total subpart F income. Add lines 26, 29, 32, and 35 .
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35
36
36
37
Current E&P limitation computation:
a
b
c
Current E&P .
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37a
37b
37c
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Tested loss (enter as a positive number—see instructions) .
Total of line 37a and line 37b
Enter the smaller of line 36 or line 37c
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38
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38
Instructions for Form 5471 (Rev. 01-2024)
23
Worksheet A
Worksheet A (continued) (See instructions.)
39
If the amount on line 37c is less than the amount on line 36, allocate the subpart F income remaining (after having been limited)
to lines 40, 41, 42, and 43 below in the manner prescribed by Regulations section 1.952-1(e). If the amount on line 37c is
greater than or equal to the amount on line 36, enter the amount from line 26 onto line 40, enter the amount from line 29 onto
line 41, enter the amount from line 32 onto line 42, and enter the amount from line 35 onto line 43.
40
41
42
43
44
45
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal
Section 954(d) subpart F Foreign Base Company Sales Income subtotal .
Section 954(e) subpart F Foreign Base Company Services Income subtotal .
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40
41
42
43
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Other subpart F income subtotal
Shareholder’s pro rata share of line 40
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44
Shareholder’s pro rata share of export trade income that applies to line 44
amount (see section 970(a)) .
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45
46
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 45 from
line 44 .
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46
49
47
48
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)) .
Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 48 from line 47
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48
49
50
51
Shareholder’s pro rata share of line 42
Shareholder’s pro rata share of export trade income that applies to line 50
amount (see section 970(a)) .
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50
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51
52
Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from line
50
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52
53
54
Shareholder’s pro rata share of line 43
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53
Shareholder’s pro rata share of export trade income that applies to line 53
amount (see section 970(a)) .
Other subpart F income subtotal. Subtract line 54 from line 53
Add lines 46, 49, 52, and 55 .
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54
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55
56
57
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55
56
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Divide the number of days in the tax year that the corporation was a CFC by
the number of days in the tax year and multiply the result by line 56.
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57
58
58
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
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59
Divide the number of days in the tax year you did not own such stock by the
number of days in the tax year and multiply the result by line 56 .
Enter the smaller of line 58 or line 59 .
Shareholder’s pro rata share of subpart F income. Subtract line 60 from line 57
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59
60
60
61
62
63
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61
62
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 .
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63
64
64
65
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 .
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65
66
66
67
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
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67
68
68
69
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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 .
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69
Instructions for Form 5471 (Rev. 01-2024)
24
applies to tax years of foreign
Worksheet A Instructions
Line 1g. Include payments in lieu of
dividends that are made as required
under section 1058.
corporations beginning after
Foreign base company income.
Foreign base company income
generally does not include the
following.
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
Line 1h. Enter amounts received:
Under a contract under which the
•
Foreign base company shipping
corporation is to furnish personal
services if (a) some person other than
the corporation has a right to
•
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.
income as defined in former section
954(f).
Foreign personal holding company
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
•
income derived in the active conduct
of a banking, finance, or similar
business (section 954(h)).
Line 1b. Enter the excess of gains
over losses from the sale or exchange
of:
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)).
Property that produces the type of
•
From the sale or other disposition of
•
income reportable on line 1a;
such a contract.
An interest in a trust, partnership, or
•
an exception that provides for
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.
Certain income derived in the
•
look-through treatment for certain
sales of partnership interests; or
ordinary course of business of a
securities dealer (section 954(c)(2)(C)
(i)).
Property that does not produce any
•
income.
Do not include the following.
Income, gain, deduction, or loss
Line 1a. Do not include:
Interest from conducting a banking
•
•
business that is “export financing
interest” (section 904(d)(2)(G));
from any transaction (including a
hedging transaction) and transactions
involving physical settlement of a
regular dealer in property, forward
contracts, option contracts, and
similar financial instruments (section
954(c)(2)(C)).
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
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
Dividends, interest, rent, or royalty
•
Gains and losses from the sale or
•
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.
exchange of any property that, in the
hands of the CFC, is property
described in section 1221(a)(1).
proportionate share of the assets of
the partnership attributable to such
interest. Thus, the sale of a
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
partnership interest by a CFC that
meets the ownership threshold
Interest income includes factoring
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
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
commodity transactions.
Line 1d. Enter the excess of foreign
currency gains over foreign currency
losses from section 988 transactions.
An exception applies to transactions
directly related to the business needs
of a CFC.
Line 1e. Enter any income equivalent
to interest, including income from
commitment fees (or similar amounts)
for loans actually made.
line 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
exceptions to the inclusion of subpart
F income. Also, a trade or service
receivable acquired or treated as
acquired by a CFC from a related U.S.
person is considered an investment in
U.S. property for purposes of section
956 (Worksheet B) if the obligor is a
U.S. person.
Line 1f. Include net income from
notional principal contracts (except a
contract entered into to hedge
inventory property).
corporation or partnership, the CFC is
treated as owning directly its
proportionate share of any such
capital or profits interest held directly
or indirectly by such corporation or
partnership. If a CFC is treated as
owning a capital or profits interest in a
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
Instructions for Form 5471 (Rev. 01-2024)
25
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.
deductions attributable to disqualified
payments (Regulations section
1.951A-2(c)(5) or (6)) are not
determined under the rules of section
953(c)(5).
Exceptions. The above definition
does not apply to any foreign
corporation if:
allocated and apportioned to gross
foreign base company income.
Lines 13g, 14d, 15d, 16d, 18d, and
At all times during the foreign
•
Line 10. De minimis rule. If the sum 19d. Exception for certain income
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
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.
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).
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
Line 18. Adjusted net insurance in-
come. 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,
Line 11. Full inclusion rule. If the
sum of foreign base company income
(determined without regard to section
954(b)(5)) and gross insurance
The corporation:
•
1. Elects to treat its related person
income for the tax year exceeds 70%
of gross income for income tax
insurance income for the tax year as
income effectively connected with the
conduct of a trade or business in the
United States,
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
insurance income does not include
exempt insurance income (as defined
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.
under section 954(b)(5)) be treated as in section 953(e)).
foreign base company income or
Line 18b. Expenses. Do not enter
insurance income, whichever is
appropriate. In this case, enter total
gross income (for income tax
purposes) on line 11. Otherwise, enter
zero.
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.
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.
Mutual life insurance companies.
The related person insurance income
rules also apply to mutual life
Line 19. Adjusted net related per-
son insurance income. Related
person insurance income is any
insurance companies under
regulations prescribed by the
insurance income (within the meaning Secretary. For these purposes,
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
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
Note. In determining the amount of
a net item of foreign base company
income, deductions or loss
shareholder. If a CFC has related
person insurance income, the U.S.
shareholder’s pro rata share is to be
attributable to disqualified basis and
Instructions for Form 5471 (Rev. 01-2024)
26
attributable to disqualified payments
(Regulations section 1.951A-2(c)(5)
or (6)) are not allocated and
apportioned to gross insurance
income.
participation in or cooperation with an
international boycott. See Schedule B
(Form 5713).
obligation of the United States or the
Code.
Line 37. Current E&P limitation. A
CFC's subpart F income is limited to
the sum of the following.
Line 21. Illegal bribes, kickbacks,
and other payments. Enter the total
of any illegal bribes, kickbacks, or
Line 20. International boycott in-
come. If a CFC or a member of a
controlled group (within the meaning
of section 993(a)(3)) that includes the
Its current year E&P, computed
•
other payments (within the meaning of under the special rule of section
section 162(c)) paid by or on behalf of 952(c)(1). Enter this amount on
the corporation, directly or indirectly,
line 37a.
CFC has operations in, or related to, a to an official, employee, or agent of a
Any tested loss under section
•
country (or with the government, a
company, or a national of a country)
that requires participation in or
government.
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.
Line 22. Income described in sec-
tion 952(a)(5). The income of a CFC
derived from any foreign country
cooperation with an international
boycott as a condition of doing
during any period during which
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).
section 901(j) applies to such foreign
country will be deemed to be income
to the U.S. shareholders of such CFC.
As of the date these instructions were
revised, section 901(j) applied to Iran,
North Korea, Sudan, and Syria.
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 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
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
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
Worksheet A, lines 40 through 43,
using the rules of Regulations section
1.952-1(e).
taxation (or is subject to a reduced
rate of tax) pursuant to a treaty
income is the amount specifically from
the operations in which there was
Instructions for Form 5471 (Rev. 01-2024)
27
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 deꢀned in section 956(c) and (d)) held (directly or
indirectly) by the CFC as of the close of:
a
b
c
d
The ꢀrst quarter of the tax year .
The second quarter of the tax year
The third quarter of the tax year
The fourth quarter of the tax year .
Number of quarter-ends the foreign corporation was a CFC during the tax year .
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1a
1b
1c
1d
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2
3
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2
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.) .
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3
4
4
5
U.S. shareholder’s pro rata share of the amount on line 3 .
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Earnings and proꢀts described in section 959(c)(1)(A) with respect to the U.S. shareholder after
reductions (if any) for current year distributions
Section 956(a)(1) amount. Subtract line 5 from line 4
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5
6
6
7
Applicable earnings:
a
b
Current year earnings and proꢀts
Line 7a plus accumulated earnings and proꢀts
Enter the greater of line 7a or line 7b .
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7a
7b
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8
9
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8
9
Distributions made by the CFC during the tax year
Subtract line 9 from line 8
10
11
12
13
14
15
16
17
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10
11
12
13
14
15
16
Earnings and proꢀts described in section 959(c)(1) after reductions (if any) for current year distributions
Applicable earnings. Subtract line 11 from line 10
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Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12
Section 956(a) amount. Enter the smaller of line 6 or line 13 .
Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder
Tentative section 956 amount. Subtract line 15 from line 14 .
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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
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17
18
18
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Section 956 amount. Subtract line 17 from line 16
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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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19
Distributions are also taken into
account before the section 956
which the property is subject. See
section 956(c) and (d) and the
Worksheet B Instructions
Use Worksheet B to determine a U.S.
shareholder's pro rata share of
inclusion is determined. Distributions
are generally treated as coming first
from (and thus reducing the balances
regulations under section 956 to
determine whether the CFC is treated
as holding U.S. property. The amount
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
of) the PTEP accounts. Thus, the U.S. of U.S. property held (directly or
shareholders must:
indirectly) by the CFC that was
acquired by the foreign corporation
before it became a CFC is
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).
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.
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
If the foreign corporation ceases to
be a CFC during the tax year:
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.
The determination of the U.S.
•
shareholder's pro rata share will be
made based upon the stock owned
(within the meaning of section 958(a))
by the U.S. shareholder on the last
day during the tax year in which the
foreign corporation was a CFC;
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