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Form 5471 Instructions

Instructions for Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations

Rev. January 2024

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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  
Future Developments . . . . . . . . . . . . 1  
What’s New . . . . . . . . . . . . . . . . . . 1  
General Instructions . . . . . . . . . . . . . 1  
Purpose of Form . . . . . . . . . . . . . . . 1  
Who Must File . . . . . . . . . . . . . . . . 1  
When and Where To File . . . . . . . . . . 2  
Categories of Filers . . . . . . . . . . . . . 2  
Additional Filing Requirements . . . . . . 7  
Penalties . . . . . . . . . . . . . . . . . . . . 8  
Other Reporting Requirements . . . . . . 8  
Specific Instructions . . . . . . . . . . . . . 9  
Schedule B . . . . . . . . . . . . . . . . . 12  
Schedule C . . . . . . . . . . . . . . . . . 13  
Schedule F . . . . . . . . . . . . . . . . . 13  
Schedule G . . . . . . . . . . . . . . . . . 13  
Schedule I . . . . . . . . . . . . . . . . . . 19  
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  
Schedules . . . . . . . . . . . . . . . 29  
Schedule E . . . . . . . . . . . . . . . . . 29  
Schedule E-1 . . . . . . . . . . . . . . . . 32  
Schedule G-1 . . . . . . . . . . . . . . . . 34  
Schedule H . . . . . . . . . . . . . . . . . 35  
Schedule I-1 . . . . . . . . . . . . . . . . 37  
Schedule J . . . . . . . . . . . . . . . . . 39  
Schedule M . . . . . . . . . . . . . . . . . 42  
Schedule O . . . . . . . . . . . . . . . . . 43  
Schedule P . . . . . . . . . . . . . . . . . 43  
Schedule Q . . . . . . . . . . . . . . . . . 44  
Schedule R . . . . . . . . . . . . . . . . . 48  
Principal Business Activity Codes . . . 50  
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  
in Categories of Filers below must  
Jan 25, 2024  
Cat. No. 49959G  
         
complete the schedules, statements,  
and/or other information requested in  
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  
(CFC) (see Category 5 Filers, later, for  
definition); or  
2. Any foreign corporation with  
respect to which one or more  
domestic corporations are U.S.  
shareholders.  
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  
2018-6 I.R.B. 341, to similarly situated 1.6046-1(i) for additional information.  
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  
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  
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  
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  
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)  
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  
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  
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  
boxes that apply. See Categories of  
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  
Income (OCI), see Lines 23 and 24,  
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  
Use Worksheet A to compute the  
U.S. shareholder's pro rata share of  
subpart F income of the CFC, which is  
reportable on lines 1e through 1h. Do  
not include any income includible on  
Form 5471, Schedule I, lines 1a  
through 1d, or any income includible  
under section 951A (Schedule I-1 is  
used to provide information relating to  
section 951A). Subpart F income  
reportable on lines 1e through 1h  
includes the following.  
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  
income (Worksheet A, lines 1 through  
17).  
Adjusted net insurance income  
1.1275-1(b)(1).  
(Worksheet A, line 18).  
Adjusted net related person  
Schedule I  
insurance income (Worksheet A,  
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  
(Worksheet A, line 20).  
Illegal bribes, kickbacks, and other  
payments (Worksheet A, line 21).  
Income described in section 952(a)  
(5) (Worksheet A, line 22).  
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  
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  
REMIC; however, see Line 1i, later, for  
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  
19  
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  
959(a) and (c)(1), and Schedule J)  
should be reclassified as section  
959(c)(1) PTEP.  
U.S. property is measured on a  
quarterly average basis. For purposes  
of Worksheet B, the amount taken into  
account with respect to U.S. property  
is generally its adjusted basis for E&P  
purposes, reduced by any liability to  
The CFC's U.S. property for the tax  
year will be determined only by taking  
into account quarters ending on or  
before such last day (and investments  
in U.S. property as of the close of  
Instructions for Form 5471 (Rev. 01-2024)  
28  
subsequent quarters should be  
recorded as zero on line 1); and  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. If applicable, use the  
reference ID number shown on Form  
5471, page 1, item 1b(2).  
Part I—Taxes for Which a  
Foreign Tax Credit Is Allowed  
In determining applicable earnings,  
In Part I, Section 1, list income, war  
profits, and excess profits taxes  
(income taxes) paid or accrued to  
each foreign country or U.S. territory  
for the foreign corporation’s foreign tax  
year(s) that ends with or within its U.S.  
tax year.  
current year E&P will include only E&P  
that are allocable (on a pro rata basis)  
to the part of the year during which the