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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  
foreign corporation was a CFC.  
Lines a, b, and c. Complete a  
separate Schedule E for each  
Instructions for Separate  
Schedules  
applicable separate category of  
income. Enter the appropriate code  
on line a (above Part I). To determine  
the appropriate code, see Categories  
of Income in the Instructions for Form  
1118, Foreign Tax  
In Part I, Section 2, report taxes  
deemed paid under section 960(b)(2)  
with respect to distributions of PTEP  
from a lower-tier foreign corporation to  
the foreign corporation with respect to  
which this Schedule E (Form 5471) is  
being completed.  
Schedule E  
Use Schedule E, Part I, to report taxes  
paid, accrued, or deemed paid under  
section 960(b)(2) by a foreign  
Credit—Corporations. Taxes with  
respect to all categories of income  
listed in the Instructions for Form  
1118, with the exception of foreign  
branch income, may need to be  
reported. A foreign corporation may  
accrue or pay taxes properly  
corporation for which a foreign tax  
credit is allowed, and use Schedule E,  
Part III, to report taxes for which a  
credit may not be taken.  
Amounts not reported in Part I. Do  
not report taxes that are not  
creditable, including taxes for which a  
credit is disallowed under section  
245A(d) or section 901(j), (k), (l), or  
(m); or suspended under section 909.  
Such taxes are reported in Part III. A  
credit is never allowed for taxes paid  
or accrued to the United States. Do  
not report such taxes in Part I. Report  
them instead in Part III.  
Note. Schedule E must be completed  
even for noncorporate U.S.  
attributable to an income group within  
the general category, passive  
shareholders. Certain noncorporate  
U.S. shareholders may elect under  
section 962 to be taxed at corporate  
rates on section 951(a) amounts and  
the global intangible low-taxed income  
(GILTI) inclusion for the tax year, so as  
to be able to claim a credit for certain  
foreign taxes paid or accrued by the  
CFC. The information reported on  
Schedule E is relevant for U.S.  
category, or section 901(j) category.  
See Regulations section 1.960-1(d)(2)  
(ii). A foreign corporation may accrue  
or pay taxes properly attributable to a  
PTEP group within any of the separate  
categories of income, with the  
exception of foreign branch category  
income. See Regulations section  
1.960-3(c)(1).  
Adjustments to foreign income tax-  
es. Adjustments to foreign income  
taxes paid or accrued in a prior year  
should not be reflected on Schedule E  
in the year of adjustment. Instead,  
they should be reported in the year to  
which such taxes relate. This may  
require an amended return. See  
section 905(c). Adjustments include  
additional payments, refunds, and  
downward adjustments for accrued  
foreign taxes that are not paid within 2  
years after the close of the tax year to  
which such taxes relate.  
If code 901j is entered on line a,  
enter on line b the country code for  
the sanctioned country using the  
two-letter codes (from the list at  
If one of the RBT codes is entered  
on line a, enter on line c the country  
code for the treaty country using the  
two-letter code (from the list at  
shareholders making this election.  
Also, timely information reporting is  
important to the extent the U.S.  
shareholder chooses to amend its  
return in a later year to make the  
election under section 962. Schedules  
E and E-1 are also relevant for  
noncorporate U.S. shareholders who  
do not make a section 962 election.  
Taxes paid or accrued with respect to  
distributions of PTEP by the U.S.  
shareholder, while not reported on  
Form 5471, are subject to different  
rules regarding creditability and  
foreign currency gain or loss. See, for  
example, sections 965(g) and 986(c).  
Therefore, it is important that the U.S.  
shareholder track the PTEP groups to  
follow the different rules for each  
group.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
Comparison to income tax ex-  
pense reported on Form 5471,  
Schedule C. The foreign income  
taxes reported on Schedule E may  
differ from the amount reported as  
income tax expense on line 21a of  
Schedule C. This is due in part to  
differences in the accounting for  
foreign tax redeterminations,  
disallowed taxes, and foreign income  
taxes reported in Other  
Note. Do not complete a separate  
Schedule E for taxes assigned to the  
section 951A category. Taxes paid,  
accrued, or deemed paid with respect  
to section 951A PTEP that is in the  
section 951A category are reported  
on the Schedule E completed for the  
general category.  
Important. In addition to the  
separate category codes referred to  
above, if you have more than one of  
the categories of income referred to  
above, you must complete and file a  
separate Schedule E (including  
Schedule E-1) using code “TOTAL”  
that aggregates all amounts listed for  
each line and column of all other  
Schedules E and E-1.  
Comprehensive Income for U.S.  
GAAP purposes.  
Comparison to income tax ex-  
pense reported on Schedule H  
(Form 5471). The taxes added or  
deducted on line 2g of Schedule H  
include both foreign income taxes  
reported in Part I of Schedule E as  
well as the taxes reported in Part III of  
Instructions for Form 5471 (Rev. 01-2024)  
29  
     
Schedule E that are not creditable  
foreign income taxes.  
or accrued to a different country on  
separate lines.  
1. The tax is paid before the  
beginning of the year to which the tax  
relates.  
2. Accrued taxes are not paid  
before the date 2 years after the close  
of the tax year to which such taxes  
relate.  
3. There is an election in effect  
under section 986(a)(1)(D) to  
translate foreign taxes using the  
exchange rate in effect on the date of  
payment.  
Section 1—Taxes Paid or  
Accrued Directly by Foreign  
Corporation  
Column (e)  
The foreign tax year under foreign tax  
law may not be the same tax year as  
the U.S. tax year of the foreign  
Column (a)  
corporation. If the tax is attributable to  
a pass-through entity owned by a  
foreign corporation, the foreign tax  
year of the foreign corporation within  
which such pass-through entity’s year  
ends should be reported on this line.  
Amounts reported on Schedule E may  
include taxes paid or accrued by the  
foreign corporation or a pass-through  
entity (for example, a partnership or  
disregarded entity) owned by the  
foreign corporation. If the tax is paid or  
accrued by the pass-through entity,  
enter the name of such entity instead  
of the name of the foreign corporation.  
If the tax paid or accrued by the  
4. The foreign corporation reports  
on the cash basis. See section 986(a).  
5. The foreign tax is denominated  
in an inflationary currency. See  
section 986(a)(1)(C).  
Column (g)  
Enter the income reported to the  
foreign tax authority under foreign tax  
law. This should be the foreign taxable  
income base for determining the tax  
reported in column (j).  
foreign corporation is attributable to a  
branch or qualified business unit  
Report the exchange rate using the  
“divide-by convention” specified under  
5471, earlier.  
(QBU) of the foreign corporation,  
enter the name of the branch or QBU.  
Column (h)  
Column (b)  
Column (m)  
Check the box if taxes were paid on  
U.S. source income.  
Enter the EIN or reference ID number  
of the payor entity listed in column (a).  
A reference ID number is required  
only in cases in which no EIN was  
entered for the foreign corporation or  
pass-through entity owned by the  
foreign corporation. Filers are  
Enter the tax in functional currency.  
E&P takes into account foreign  
income taxes paid or accrued by the  
foreign corporation. The foreign  
corporation's E&P is determined in the  
foreign corporation's functional  
currency. See section 986(b).  
Column (i)  
Enter the three-letter currency code  
for the local currency in which the tax  
is payable. Currency codes are  
permitted to enter both an EIN and a  
reference ID number. See Item  
1b(2)—Reference ID Number, earlier,  
for more information about reference  
ID numbers.  
Line 5  
Report the total of the amounts listed  
in column (l) on this line 5. This total  
should also be reported on  
codes.  
Schedule E-1, line 4.  
Column (c)  
Line 6  
Column (j)  
Report the total of the amounts listed  
in column (m) on this line 6. This total  
and the amount reported on line 3 of  
Schedule E, Part III, are the  
Check the box if the foreign income  
taxes reported in column (j) were paid  
or accrued by the foreign corporation  
during prior tax years and were  
suspended due to the application of  
the rules of section 909 and that are  
unsuspended in the current year  
because related income is taken into  
account by the foreign corporation,  
certain U.S. corporate owners of the  
foreign corporation, or a member of  
such U.S. corporate owner’s  
Enter the tax paid or accrued in the  
local currency in which tax is payable  
and not the functional currency of the  
payor or foreign corporation. See  
sections 986(a) and 905(c).  
appropriate reduction to current year  
E&P for income taxes. See  
Schedule H, line 2g.  
Columns (k) and (l)  
Example. CFC1, a foreign  
corporation, with reference ID number  
1000123, pays or accrues tax of 10u =  
$10 to Country X on 50u of Country X  
foreign source taxable income with  
respect to CFC1’s foreign tax year  
ending December 31, 2023. CFC1  
has a December 31 tax year end for  
both foreign and U.S. tax purposes.  
Also, CFC1 receives in the tax year  
ending December 31, 2023, a refund  
of 3u from Country X on 15u of foreign  
Enter the exchange rate in column (k)  
and the translated dollar amount in  
column (l).  
consolidated group.  
Translate the taxes entered in  
column (j) into dollars at the average  
exchange rate for the tax year to  
which the tax relates unless one of the  
exceptions below applies. See section  
986(a).  
Column (d)  
Enter the two-letter codes (from the  
list at IRS.gov/CountryCodes) of all  
foreign countries and U.S. territories  
to which taxes were paid or accrued. If  
taxes were paid or accrued to more  
than one country with respect to the  
same income, include each tax paid  
Exceptions. If one of the following source income with respect to CFC1’s  
exceptions applies, use the exchange  
rate in effect on the date the foreign  
corporation paid the tax.  
tax year ending December 31, 2017,  
translated to equal $5, and on which  
the original liability was $7. Therefore,  
Instructions for Form 5471 (Rev. 01-2024)  
30  
the revised tax liability is $2. All taxes  
relate to general category income.  
Also assume for both years that the  
local currency in which the tax was  
paid was the same as the foreign  
corporation’s functional currency. The  
country code for Country X is XX.  
The following entries should be  
made on the 2023 Schedule E (Form  
5471), Part I, Section 1, for CFC1 with  
respect to the General Category  
Income separate category.  
The only foreign taxes of the  
in Regulations section 1.960-3(c)(2)).  
Please enter the applicable PTEP  
distributing foreign corporation that  
may be treated as deemed paid under group code from the following list.  
section 960(b) are foreign taxes paid,  
accrued, or deemed paid by the  
distributing foreign corporation with  
respect to the receipt of a PTEP  
distribution from another lower-tier  
foreign corporation below the  
PTEP Group Classification  
Taxes related to  
previously taxed  
E&P  
PTEP Group Code  
distributing foreign corporation.  
Accordingly, there can be no  
Reclassified section  
965(a) PTEP  
R965a  
R965b  
959c1  
deemed-paid foreign taxes with  
respect to a PTEP distribution from a  
lower-tier foreign corporation that is  
the lowest foreign-tier foreign  
Reclassified section  
965(b) PTEP  
Line 1, column (a): CFC1  
Line 1, column (b): 1000123  
Line 1, column (d): XX  
General section  
959(c)(1) PTEP  
corporation in a chain, and therefore  
no such distributions will be reported  
in Section 2. See Regulations section  
1.960-1(d)(3)(ii)(B).  
Line 1, column (e): 2023/12/31  
Line 1, column (f): 2023/12/31  
Line 1, column (g): 50u  
Line 1, column (i): u  
Reclassified section  
951A PTEP  
R951A  
R245Ad  
Reclassified section  
245A(d) PTEP  
Line 1, column (j): 10u  
Any foreign income taxes paid or  
accrued (but not deemed paid) by the  
foreign corporation with respect to a  
PTEP distribution from a lower-tier  
foreign corporation (whether or not  
such PTEP distribution is reported in  
Section 2), such as withholding taxes  
imposed on the PTEP distribution, are  
reported in Section 1.  
Section 965(a) PTEP  
Section 965(b) PTEP  
Section 951A PTEP  
965a  
965b  
Line 1, column (k): 1.0000  
Line 1, column (l): $10  
Line 1, column (m): 10u  
951A  
245Ad  
An amended 2017 tax return  
Section 245A(d)  
PTEP  
should be filed by or for the U.S.  
person(s) with respect to which Form  
5471 was required and that return  
should include an amended Form  
5471. The amended Form 5471  
should include an attachment with a  
schedule that looks like the current  
version of Schedule E, Part I, Section  
1, with the following entries for the  
general category of income.  
Section 951(a)(1)(A)  
PTEP  
951a1A  
Column (a)  
Column (e)  
Enter the name of each lower-tier  
foreign corporation that made a PTEP  
distribution with respect to which a  
deemed-paid tax is determined in the  
current year by the foreign corporation  
with respect to which this Schedule E  
(Form 5471) is being completed.  
Enter the year in which the U.S.  
shareholder included income of the  
lower-tier foreign corporation under  
section 951(a) or section 951A and  
established the PTEP account to  
which the distribution is attributed.  
This is the annual PTEP account. See  
Regulations section 1.960-3(c)(1).  
Line 1, column (a): CFC1  
Line 1, column (b): 1000123  
Line 1, column (d): XX  
Line 1, column (e): 2017/12/31  
Line 1, column (f): 2017/12/31  
Line 1, column (g): 15u  
Line 1, column (i): u  
Column (b)  
Column (f)  
Enter the EIN or reference ID number  
of the lower-tier foreign corporation  
listed in column (a). A reference ID  
number is required only in cases in  
which no EIN was entered for the  
lower-tier foreign corporation. Filers  
are permitted to enter both an EIN and  
a reference ID number. See Item  
for more information about reference  
ID numbers.  
Line 1, column (j): 1.20u  
Line 1, column (k): 1.6667  
Line 1, column (l): $2  
Enter the PTEP distribution with  
respect to the PTEP group within the  
annual PTEP account identified in  
column (d) and column (e) in the  
functional currency of the distributing  
lower-tier foreign corporation. If there  
is a PTEP distribution related to more  
than one PTEP group within an annual  
PTEP account, complete a separate  
line for each PTEP group within an  
annual PTEP account.  
Line 1, column (m): 1.20u  
Section 2—Taxes Deemed Paid  
(Section 960(b))  
The purpose of Section 2 is to track  
deemed-paid foreign income taxes  
with respect to current year PTEP  
distributions from lower-tier foreign  
corporations to the foreign corporation  
with respect to which this Schedule E  
(Form 5471) is being completed (“the  
foreign corporation”).  
Column (c)  
Column (g)  
Enter the applicable two-letter code  
(from the list at IRS.gov/  
Enter the total amount of the lower-tier  
foreign corporation’s PTEP in the  
PTEP group within the annual PTEP  
account identified in column (d) and  
column (e). Enter such amount in the  
Report a PTEP distribution by a  
lower-tier foreign corporation in  
Section 2 only if foreign income taxes  
are deemed paid under section  
960(b) by the foreign corporation with  
respect to such PTEP distribution.  
Column (d)  
Enter the code which describes the  
PTEP group classification (as set forth  
Instructions for Form 5471 (Rev. 01-2024)  
31  
functional currency of the distributing  
lower-tier foreign corporation.  
which generally applies to certain  
taxes paid on dividends if the  
(section 901(f)), certain taxes used to  
provide subsidies (section 901(i)), and  
taxes for which no credit is allowed  
because of the boycott provisions of  
section 908.  
minimum holding period is not met  
with respect to the underlying stock,  
or if the corporation is obligated to  
make related payments with respect  
to positions in similar or related  
property. Also enter foreign income  
taxes disallowed under section 901(l),  
which generally applies to certain  
taxes paid on gain and income other  
than dividends if the minimum holding  
period is not met with respect to the  
underlying property, or if the  
Column (h)  
Enter the total amount of the lower-tier  
foreign corporation’s PTEP group  
taxes with respect to the PTEP group  
within the annual PTEP account  
identified in column (d) and column  
(e). Enter this amount in U.S. dollars.  
To determine the appropriate  
Column (i)  
For each line in this column, enter the  
total amount for each payor in  
columns (c) through (h).  
Line 3  
translation rate, see section 986(a).  
Total each amount in column (i) and  
enter on line 3. All amounts should be  
in functional currency.  
corporation is obligated to make  
related payments with respect to  
positions in similar or related property.  
Column (i)  
Enter the U.S. dollar amount of the  
recipient foreign corporation's income  
taxes deemed paid that are properly  
attributable to the PTEP distribution  
reported in column (f) and not  
deemed to have been paid by the  
domestic corporation for any prior tax  
year.  
Line 4  
Translate the line 3 amount from  
functional currency to U.S. dollars  
using, in general, the average  
exchange rate as defined by section  
989(b)(3).  
Column (e)  
In the case of a covered asset  
acquisition (as defined in section  
901(m)(2)), enter the disqualified  
portion of any tax determined with  
respect to the income or gain  
attributable to the relevant foreign  
assets (section 901(m)).  
Schedule E-1  
Note. With respect to distributions of  
PTEP resulting from inclusions under  
section 965, report the taxes properly  
attributable to such PTEP without  
reduction for the foreign tax credit  
disallowance.  
Use Schedule E-1 (on pages 2 and 3  
of separate Schedule E) to report the  
cumulative balance of foreign income  
taxes paid or accrued by a CFC by  
separate category of income.  
Note. This rule generally applies to  
covered asset acquisitions after  
December 31, 2010. See Regulations  
sections 1.901(m)-1 through  
Enter amounts in U.S. dollars  
unless otherwise noted.  
Part III—Taxes for Which  
Foreign Tax Credit Is  
Disallowed  
Use Part III to report taxes for which  
foreign tax credits are not allowed.  
While not allowed as a credit, such  
taxes are taken into account in  
determining the foreign corporation’s  
E&P.  
1.901(m)-8 for additional information.  
Note that the rules contained in these  
regulations have later effective dates.  
Columns (a), (b), and (c)  
In columns (a), (b), and (c), report  
only the foreign income taxes the  
foreign corporation pays or accrues  
attributable to the subpart F income  
group, the tested income group, and  
the residual income group,  
Column (f)  
Enter the amount of taxes paid or  
accrued by the foreign corporation to  
the United States. No credit is allowed  
for these taxes because only foreign  
income taxes paid or accrued to a  
foreign country or territory of the  
United States are allowed as a credit.  
See section 901(b).  
respectively. Use Schedule Q to  
determine the taxes attributable to  
each income group. Do not include  
foreign income taxes paid or accrued  
by the foreign corporation in its other  
tax years beginning after December  
31, 2017, or that do not relate to the  
current tax year. Do not include  
foreign income taxes that are  
Do not enter taxes that do not meet  
the criteria under Regulations section  
1.901-2.  
Columns (a) and (b)  
Column (g)  
Tax Credit Is Allowed, earlier, for  
Report foreign income taxes related to  
the current tax year that have been  
suspended due to the rules of section  
909.  
instructions regarding these columns.  
disallowed and are reported on  
Schedule E, Part III. Do not include  
taxes paid or accrued by the foreign  
corporation with respect to its receipt  
of a PTEP distribution, even if those  
amounts were included in the total  
entered on line 5, column (l), of  
Schedule E, Part I, Section 1. These  
are reported in column (e). Do not  
include taxes deemed paid by the  
foreign corporation with respect to its  
receipt of a PTEP distribution. These  
are also reported in column (e).  
Column (c)  
Enter foreign income taxes that are  
disallowed under section 901(j),  
generally foreign income taxes paid or  
accrued to certain sanctioned  
countries.  
Column (h)  
Enter taxes for which a foreign tax  
credit is disallowed other than those  
detailed in columns (c) through (g).  
Such taxes may include, but are not  
limited to, taxes attributable to section  
245A(d) income, certain taxes on the  
purchase or sale of oil and gas  
Column (d)  
Enter foreign income taxes that are  
disallowed under section 901(k),  
Instructions for Form 5471 (Rev. 01-2024)  
32  
 
On line 9, report reductions for the  
portion of such taxes that are deemed  
paid by a U.S. shareholder with  
respect to an inclusion under section  
951(a) or 951A. On line 15, report  
reductions for foreign income taxes  
attributable to the column (b) tested  
income group that are not deemed  
paid as a result of the inclusion  
income, after foreign income tax, of  
$100 with respect to which it pays $20  
of foreign income tax. Such tax is  
properly attributable to subpart F  
income of CFC3 and is reported on  
line 4, column (a), of Schedule E-1 of  
CFC3’s Form 5471. During Year 1,  
Domestic Corporation reports an  
inclusion under section 951(a)(1) of  
$100 and deemed paid taxes of $20  
under section 960(a) as a result of  
subpart F income of CFC3. During  
Year 2, CFC3 distributes $40 to CFC2.  
CFC2 pays withholding tax of $4 on  
the distribution from CFC3. Such tax  
is a tax related to previously taxed  
earnings and profits that were  
Line 2. Use line 2 to reflect  
adjustments to a U.S. person’s foreign  
tax credit as a result of redetermined  
foreign income taxes. If a U.S. person  
has appropriately amended the  
immediately prior year return,  
including its Schedule E-1, to  
redetermine its U.S. tax liability, no  
adjustment should be included on this  
line. This line is only applicable if a  
U.S. person appropriately amended a  
prior year return and there were  
intervening years between the  
percentage or the 80% limitation.  
Also, on line 15, report any other  
reductions to the three income groups  
in columns (a), (b), and (c) necessary  
to achieve a zero balance on line 16.  
Attach a statement explaining why  
such taxes were not deemed paid  
under section 960. The balance of  
foreign income taxes paid or accrued  
with respect to the three income  
groups that is entered on line 16  
should equal zero after taking into  
account the reductions.  
amended year return and the current  
year return for which an amended  
return was not filed. If so, an  
adjustment for the prior year amended  
return (and its impact on intervening  
years) should be reflected on line 2.  
included as subpart F income and is  
reported on line 4, column (e)(x), of  
Schedule E-1 of CFC2’s Form 5471.  
Line 3a. A tax reported on  
Line 5. Report taxes carried over to a  
foreign surviving corporation after an  
acquisition by a foreign corporation of  
the assets of another foreign  
Schedule E, Part I, Section 1, line 5,  
column (l), for which column (c) was  
checked because such tax was  
unsuspended in the current year,  
should be included as a positive  
amount in column (a), (b), (c), or (e),  
as appropriate. Such tax should also  
be reflected as a negative amount in  
column (d).  
Column (d)  
Use column (d) to report taxes  
suspended under section 909.  
corporation in a transaction described  
in section 381. See Regulations  
Columns (e)(i) through (e)(x)  
section 1.367(b)-7(b)(1) and (d)(1).  
Report foreign income taxes paid or  
accrued with respect to E&P  
Line 6. Enter foreign income taxes  
properly attributable to PTEP and not  
previously deemed paid (from  
described in section 959(c)(1) and (c)  
(2). See the instructions for  
Line 3b. Include as a positive amount  
in column (d) foreign income taxes  
related to the current tax year that  
have been suspended due to the rules  
of section 909. Such taxes are also  
reported on Schedule E, Part III,  
column (g).  
Schedule E, Part I, Section 2, line 5,  
column (i)). The total reported on  
Schedule E, Part I, Section 2, line 5,  
column (i), should be broken out on  
Schedule E-1, line 6, columns (e)(i)  
through (e)(x), based on the type of  
PTEP to which such taxes relate.  
Schedule J, Column (e), later, for  
specific information about the ten  
PTEP group columns. Also see  
Regulations section 1.960-3(c)(2) for  
additional information regarding the  
ten PTEP groups.  
Line 4. The total reported on  
Example 2. The facts are the  
same as in Example 1, except that, in  
addition, CFC2 distributes $36 to  
CFC1 in Year 3. CFC1 is deemed to  
pay the $4 of withholding tax paid by  
CFC2 in Year 2. See section 960(b).  
Such tax is attributable to previously  
taxed subpart F income and is  
reported on line 6, column (e)(x), of  
Schedule E-1 of CFC1’s Form 5471.  
Such tax is also reported as a  
Schedule E, Part I, Section 1, line 5,  
column (l), should be separated into  
columns (a) through (e) according to  
the type of income or E&P to which  
such taxes relate. Therefore, for  
example, taxes paid or accrued with  
respect to the receipt of a PTEP  
distribution are reported in column (e),  
and taxes paid or accrued with  
respect to current year subpart F  
income of the foreign corporation are  
reported in column (a).  
Specific Instructions Related to  
Lines 1 Through 16  
Line 1a. This amount should equal  
the amount that was reported as the  
balance on line 16 of the prior year  
Schedule E-1.  
Line 1b. If the balance on line 16 of  
prior year Schedule E-1 was adjusted  
after the filing of the original prior year  
Form 5471, such adjustments should  
be reflected on line 1b. For example, if  
there were errors in the original  
negative number on line 10, column  
(e)(x), of Schedule E-1 of CFC2’s  
Form 5471.  
Line 7. Attach a statement with a  
description and the amount of any  
adjustments required before taking  
into account taxes deemed paid by  
the foreign corporation. Do not include  
any adjustments required to be  
reported on line 1b or 12.  
Example 1. Domestic  
computation of foreign income taxes,  
an adjustment would be included on  
this line. See Corrections to Form  
5471, earlier. Do not include any  
adjustments required to be reported  
on line 7 or 12. Attach a statement  
that includes an explanation and the  
dollar amount of each such  
Corporation, a U.S. shareholder,  
wholly owns the only class of stock of  
CFC1, a foreign corporation. CFC1, in  
turn, wholly owns the only class of  
stock of CFC2, a foreign corporation.  
CFC2, in turn, wholly owns the only  
class of stock of CFC3, a foreign  
corporation. The functional currency  
of Domestic Corporation, CFC1,  
CFC2, and CFC3 is the U.S. dollar.  
During Year 1, CFC3 has subpart F  
adjustment, along with a total that  
equals the amount entered on line 1b.  
Line 9. A domestic corporation is  
deemed to pay foreign income taxes  
attributable to inclusions under  
Instructions for Form 5471 (Rev. 01-2024)  
33  
section 951(a)(1). See section 960(a).  
Amounts reported on line 9 should be  
negative numbers.  
If a domestic corporation includes  
an amount in income under section  
951A, such domestic corporation is  
deemed to pay foreign income taxes  
equal to 80% of the product of (a)  
such domestic corporation’s inclusion  
percentage, multiplied by (b) the  
Example 4. The facts are the  
same as in Example 1, except that  
during Year 2, CFC2 invests $40 in  
U.S. property. At the time of  
which the foreign corporation was a  
controlled participant (as defined in  
Regulations section 1.482-7(j)) during  
the tax year. All amounts should be  
reported in U.S. dollars.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. If applicable, use the  
reference ID number shown on Form  
5471, page 1, item 1b(2).  
Question 4. Enter the foreign  
corporation’s share of reasonably  
anticipated benefits (RAB) for the  
CSA during the tax year. See  
investment in such property, CFC2  
continues to maintain a $36 balance  
in its section 959(c)(2) PTEP account.  
CFC2 reclassifies such amount as  
section 959(c)(1) PTEP on  
Schedule J. Accordingly, $4 of foreign  
income taxes related to section 959(c)  
(2) PTEP is reclassified to section  
959(c)(1) PTEP on line 11, column (e)  
(iii). A negative $4 will be recorded on  
line 11, column (e)(x), and a positive  
$4 will be recorded on line 11, column  
(e)(iii).  
Line 12. Attach a statement with a  
description and the amount of any  
required adjustments to taxes of the  
foreign corporation not already taken  
into account on this schedule. An  
example of amounts reported on  
line 12 is taxes attributable to PTEP  
distributions to shareholders ineligible  
to claim a foreign tax credit under  
section 960(b)(1) (such as foreign  
corporations).  
aggregate tested foreign income taxes  
paid or accrued by the CFC. For the  
computation of such amount, see  
Form 1118, Schedule D. Amounts  
reported on line 9 should be negative  
numbers. See line 15 with respect to  
reporting taxes not deemed paid as a  
result of the inclusion percentage or  
the application of the 80% limitation.  
Line 10. A domestic corporation is  
deemed to pay foreign income taxes  
with respect to distributions of PTEP.  
See Section 960(b)(1). Amounts  
reported on line 10 should be negative  
numbers.  
Regulations section 1.482-7(e) for  
rules on a determining and updating  
controlled participant’s RAB share. If  
the foreign corporation applied more  
than one RAB share during the tax  
year in determining its share of  
intangible development costs (IDCs),  
enter the RAB share that was applied  
to IDCs incurred at the end of the  
year. See Regulations section  
1.482-7(d) for more information on  
IDCs.  
Taxes are deemed paid by a  
domestic corporation that is a U.S.  
shareholder or a foreign corporation  
that is a CFC with respect to  
Line 15. Enter the reduction to the  
column (b) tested income group for  
tested income taxes not deemed paid.  
See Regulations section 1.960-1. This  
includes taxes attributable to the  
column (b) tested income group that  
were not deemed paid as a result of  
the domestic corporation’s inclusion  
percentage or as a result of the  
distributions of PTEP that it receives.  
Report on line 10, column (e), the  
taxes that relate to PTEP of the  
foreign corporation that are deemed  
paid by a shareholder of the foreign  
corporation, either an upper-tier  
foreign corporation or a U.S.  
Question 5a. Check the “Yes” box if  
the U.S. taxpayer made any platform  
contributions as defined in  
shareholder, with respect to a  
distribution of PTEP made by the  
foreign corporation.  
application of the 80% limit. See  
section 960(d). Enter the reduction to  
the three income groups in columns  
(a), (b), and (c) for other taxes not  
deemed paid. See Regulations  
Regulations section 1.482-7(c) to the  
CSA during the tax year. If “Yes,”  
complete lines 5b and 5c.  
Example 3. The facts are the  
same as in Example 2, except that  
during Year 4, CFC1 distributes $36 to  
Domestic Corporation. Domestic  
Corporation is deemed to pay the $4  
of withholding taxes deemed paid by  
CFC1 in Year 3 and paid by CFC2 in  
Year 2. A negative $4 will be recorded  
on line 10, column (e)(x), of CFC1’s  
Form 5471, Schedule E-1.  
See Example 2, earlier, for  
reporting on line 10, column (e)(x), of  
Schedule E-1 of CFC2's Form 5471  
with respect to taxes on distributions  
from CFC3 to CFC2.  
Line 11. Foreign income taxes  
reclassified from section 959(c)(2)  
PTEP to section 959(c)(1) PTEP  
should be reported as negative  
numbers in columns (e)(vi) through (e)  
(x) and as positive numbers in  
columns (e)(i) through (e)(v).  
section 1.960-1. This includes taxes  
that are properly attributable to a  
subpart F income group but were not  
deemed paid because there was no  
subpart F income with respect to that  
income group in the current year.  
Questions 5b and 5c. Enter the  
foreign corporation's RAB share of the  
total present value of all platform  
contributions made by the U.S.  
taxpayer during the tax year with  
respect to the foreign corporation on  
line 5b. The total present value of all  
platform contributions made by the  
U.S. taxpayer during the tax year  
should be entered even if only a  
portion (or none) of the value of those  
platform contributions was included in  
the U.S. taxpayer's taxable income as  
platform contribution transaction  
(PCT) payments during the tax year. If  
possible, include a reasonable  
Note. If necessary, enter negative  
amounts on line 15 of columns (a),  
(b), and (c) in amounts sufficient to  
reduce line 16, columns (a), (b), and  
(c), to zero. Attach a statement  
explaining why such taxes were not  
deemed paid under section 960.  
Schedule G-1  
present value estimate for any PCTs  
that are priced using a method that  
does not involve the calculation of a  
present value. Otherwise, attach a  
Note. A separate Schedule G-1 must  
be filed for each cost sharing  
arrangement (CSA) as defined in  
Regulations section 1.482-7(b) in  
Instructions for Form 5471 (Rev. 01-2024)  
34  
 
brief statement of the reason(s) it is  
reasonably allocable to, the IDA as  
enter on line 1 the dollar GAAP  
income or (loss) from line 22 of  
Schedule C. Enter on lines 2a through  
not possible to include a present value defined in Regulations section  
estimate for one or more PCTs (for  
example, no revenue projections for a  
PCT that is priced based on a  
sales-based royalty from a  
1.482-7(d)(1)(i). This would include  
stock-based compensation granted in 4 the adjustments made in figuring  
earlier years (which could give rise to  
current E&P for U.S. tax purposes.  
deductions in the current tax year) that Report these amounts in U.S. dollars.  
comparable uncontrolled transaction). were not treated as identified with or  
Enter on line 5b the DASTM gain or  
loss figured under Regulations section  
1.985-3(d).  
reasonably allocable to the IDA.  
If the U.S. taxpayer engaged in  
multiple PCTs during the tax year with  
the foreign corporation and used  
different methods to price the PCTs,  
check the appropriate boxes on  
line 5c to indicate which methods  
were selected as the best method for  
one or more of the PCTs reported in  
the tax year. See Regulations section  
1.482-7(g) for more information on the  
methods applicable to PCTs.  
Questions 7a and 7b. For the tax  
year, enter the total amount of IDCs  
for the CSA on line 7a. See  
Lines 2a through 2i. Certain  
adjustments (required by Regulations  
section 1.964-1(b) and (c)) must be  
made to the foreign corporation's  
line 1 net book income or (loss) to  
determine its current year E&P. These  
adjustments may include both positive  
and negative adjustments to conform  
the foreign book income to U.S. GAAP  
and to U.S. tax accounting principles.  
If the foreign corporation's books are  
maintained in functional currency in  
accordance with U.S. GAAP, enter on  
line 1 the functional currency GAAP  
income or (loss) from line 22 of  
Regulations section 1.482-7(d) for  
more information on IDCs.  
On line 7b, enter the amount of  
IDCs allocated to the foreign  
corporation for the tax year based on  
the foreign corporation’s RAB share.  
Questions 6b and 6c. See,  
Schedule H  
generally, Regulations section 1.482-7  
for more information on determining  
whether stock-based compensation is  
directly identified with, or reasonably  
allocable to, the intangible  
Use Schedule H to report the foreign  
corporation's current year E&P for  
U.S. tax purposes. Enter the amounts  
on lines 1 through 5c in the CFC's  
functional currency.  
Schedule C, rather than starting with  
foreign book income, and show  
GAAP-to-tax adjustments on lines 2a  
through 2i.  
Lines 2b and 2c. Generally,  
depreciation, depletion, and  
development activity (IDA) under the  
CSA. See Regulations section  
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  
1.482-7(d)(3) and Notice 2005-99 for  
more information on determining the  
measurement and timing of  
stock-based compensation IDCs,  
including an election available with  
respect to options on publicly traded  
stock and certain other stock-based  
compensation. If the taxpayer made  
the election described in Regulations  
section 1.482-7(d)(3)(iii)(B) or Notice  
2005-99, the taxpayer should attach a  
statement to Form 5471 explaining  
that the taxpayer made such election  
and include in such statement the  
total amount of stock-based  
amortization allowances must be  
based on the historical cost of the  
underlying asset, and depreciation  
must be figured according to section  
167. However, if 20% or more of the  
foreign corporation's gross income is  
from U.S. sources, depreciation must  
be figured on a straight line basis  
according to Regulations section  
1.312-15.  
Line 2f. Inventories must be taken  
into account according to the rules of  
sections 471 (incorporating the  
provisions of section 263A) and 472  
and the related regulations.  
Line 2g. See the instructions for  
Schedule C, Line 21, earlier. Reflect  
differences between the income tax  
expense (benefit) reported for book  
purposes and the income taxes  
deducted or added to E&P. Such  
differences include, for example,  
deferred income tax expenses,  
uncertain tax positions, intraperiod  
allocations, adjustments made after  
closing the financial statements  
(post-closing adjustments) and not  
reflected in income tax expense  
(benefit), and the adjustment for a  
foreign tax redetermination that  
required a redetermination of the U.S.  
tax liability.  
2019-40, earlier, for more details.  
Note. A separate Worksheet H-1  
must be attached for each person  
described in Categories 4, 5a, 5b, and  
5c with respect to which reporting is  
furnished on this Form 5471 that is an  
applicable corporation within the  
meaning of section 59(k). Worksheet  
H-1 and instructions are provided later  
in these instructions.  
compensation taken into account as  
an IDC for the tax year pursuant to  
such election. If the taxpayer attaches  
the statement described in the  
Note. Category 5b and 5c filers are  
not required to file Schedule H for  
foreign-controlled CFCs.  
previous sentence, then in the entry  
space provided for line 6b the  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. If applicable, use the  
reference ID number shown on Form  
5471, page 1, item 1b(2).  
taxpayer should include the total  
amount of stock-based compensation  
taken into account as an IDC,  
including stock-based compensation  
pursuant to the election described  
above and any not subject to such  
election.  
Check the appropriate box on  
line 6c to indicate whether any  
stock-based compensation was  
granted during the term of the CSA to  
individuals who performed functions  
in business activities that generate  
cost-shared intangibles that were not  
treated as directly identified with, or  
Special rules for DASTM. If the  
foreign corporation uses DASTM,  
Instructions for Form 5471 (Rev. 01-2024)  
35  
   
corporation. CFC1, in turn, wholly  
owns the only class of stock of CFC2,  
a foreign corporation. During Year 1,  
Domestic Corporation reports an  
inclusion under section 951(a)(1) of  
$100 as a result of subpart F income  
of CFC2. During Year 2, CFC2  
country code for the sanctioned  
country using the two-letter code  
(from the list at IRS.gov/  
Line 2h. Enter the adjustment to  
foreign currency gains or losses.  
Attach a statement with a description  
of the gain or losses.  
In the case of section 988 losses,  
determine whether Form 8886 needs  
to be completed, as described under  
earlier.  
Line 2i. Enter the net amount of any  
additional adjustments not included  
on lines 2a through 2h. List these  
additional adjustments on a separate  
statement. Attach this statement to  
Form 5471. Schedule H is only  
prepared for the general, passive, and  
section 901(j) categories of income.  
For example, if U.S. GAAP income  
reported on Schedule C contains  
items related to PTEP, include the  
necessary adjustments on line 2i of  
Schedule H for the appropriate  
category of income (general or  
passive) and attach a statement that  
itemizes and explains those  
Note. The amounts reported on  
line 5c include both foreign source  
and U.S. source income.  
Line 5d. Enter the line 5c functional  
currency amount translated into U.S.  
dollars at the average exchange rate  
for the foreign corporation's tax year.  
See section 989(b). Report the  
distributes $40 to CFC1. CFC1 pays  
withholding tax of $4 on the  
distribution from CFC2. Such tax is  
related to previously taxed subpart F  
income. On Domestic Corporation’s  
financial statements, Domestic  
Corporation reports the $4 withholding  
tax as current income tax expense.  
Domestic Corporation reports on  
CFC1’s Form 5471, Schedule H,  
line 2g, a positive adjustment for the  
$4 of tax on the PTEP distribution.  
exchange rate using the “divide-by  
convention” specified under Reporting  
earlier. If the foreign corporation uses  
DASTM, enter on line 5d the same  
amount entered on line 5c.  
Line 5e. Enter the exchange rate  
used in computing line 5d. Report the  
exchange rate using the “divide-by  
convention” specified under Reporting  
earlier.  
Blocked income. The E&P of the  
foreign corporation, as reflected on  
Schedule H, must not be reduced by  
all or any part of such E&P that could  
not have been distributed by the  
foreign corporation due to currency or  
other restrictions or limitations  
imposed under the laws of any foreign  
country.  
Line 5b. DASTM gain or (loss),  
reflecting unrealized exchange gain or  
loss, should be entered on line 5b  
only for foreign corporations that use  
DASTM.  
Line 5c. The line 5c current year E&P  
amount may include amounts with  
respect to the general category,  
passive category, or section 901(j)  
category. See Regulations section  
1.960-1(d)(2). Enter on lines 5c(i),  
5c(ii), 5c(iii)(A), 5c(iii)(B), 5c(iii)(C),  
and 5c(iii)(D), as applicable, the  
portion of the line 5c current year E&P  
amount with respect to each  
adjustments. Report adjustments for  
foreign taxes related to the PTEP on  
line 2g. This adjustment is necessary  
because foreign taxes imposed on  
PTEP distributions do not reduce  
current year E&P. Foreign taxes  
imposed on PTEP distributions  
reduce PTEP and are reported on  
Schedule J, line 6.  
applicable category of income. If  
applicable for lines 5c(iii)(A), 5c(iii)(B),  
5c(iii)(C), and 5c(iii)(D), also enter the  
Example. Domestic Corporation, a  
U.S. shareholder, wholly owns the  
only class of stock of CFC1, a foreign  
Instructions for Form 5471 (Rev. 01-2024)  
36  
Worksheet H-1  
Complete a separate Worksheet H-1 in machine-readable Excel format for each person described in Categories 4, 5a, 5b, and 5c with  
respect to which reporting is furnished on this Form 5471 that is an applicable corporation within the meaning of section 59(k).  
Filer’s Pro Rata Share of CFC Adjusted Net Income or Loss for Corporate Alternative Minimum Tax  
1
Net income (or loss) set forth on the applicable ꢀnancial statement .  
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Net  
Net  
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Adjustments made to line 1 (see instructions)  
additions  
subtractions  
a
b
c
d
e
f
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h
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Statements covering different taxable years  
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Consolidated ꢀnancial statements .  
Consolidated returns .  
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Treatment of dividends and other amounts .  
Treatment of partnerships  
Effectively connected income  
Adjustments for certain taxes  
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Adjustments with respect to disregarded entities .  
Depreciation .  
Other adjustments (see instructions) .  
Total net additions .  
Total net subtractions .  
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5a Adjusted net income or loss (line 1 plus line 3 minus line 4)  
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5a  
5b  
5c  
b
c
d
Filer’s pro rata share of line 5a (see instructions) .  
.
.
.
Adjusted net income or loss in U.S. dollars (see instructions) .  
Enter exchange rate used for line 5c .  
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5d  
inclusions by U.S. shareholders under completed once (for general category  
Worksheet H-1 Instructions  
section 951A. The information in this  
schedule will be used by the U.S.  
income, passive category income, or  
both). A Schedule I-1 that includes  
Use Worksheet H-1 to report the  
CFC’s adjusted net income or loss for  
corporate alternative minimum tax  
(CAMT) purposes. Enter the amounts  
on lines 1 through 5b in the CFC’s  
functional currency.  
shareholder(s) of the CFC to file Form passive category income on line 6  
8992, U.S. Shareholder Calculation of must include the code for passive  
Global Intangible Low-Taxed Income  
(GILTI), and may assist in the  
completion of Form 1118 or Form  
1116, if applicable.  
category income (PAS) in the entry  
space for separate category (at the  
top of Schedule I-1). This is the case  
even if the Schedule I-1 also includes  
general category income. With  
Lines 2a through 2j. Certain  
adjustments (required by section  
56A(c)) must be made to the foreign  
corporation’s line 1 net book income  
or (loss) to determine its adjusted net  
income or loss for CAMT purposes.  
These adjustments may include both  
positive and negative adjustments.  
Enter the amounts on lines 1  
respect to a taxpayer completing  
Schedule I-1 with respect to a foreign  
corporation with only general category  
income (and no passive category  
income) on line 6, the taxpayer should  
enter the code “GEN” in the entry  
space for separate category.  
through 10c in the CFC's functional  
currency. The functional currency  
amounts entered on lines 6 through  
10c must be converted to U.S. dollars.  
Certain filers may be able to use  
alternative information (as defined in  
section 3.01 of Rev. Proc. 2019-40) to  
determine certain amounts in this  
Line 2j. Enter the net amount of any  
additional adjustments not included  
on lines 2a through 2i. List these  
additional adjustments on a separate  
statement. Attach this statement to  
Form 5471.  
Line 5b. Enter the filer’s pro rata  
share (determined under rules similar  
to the rules under section 951(a)(2))  
of the amount on line 5a.  
Note. The other reporting  
requirements of a taxpayer that  
includes passive category income  
with general category income on a  
Schedule I-1 do not change because  
the taxpayer includes passive  
category income with general  
category income on a Schedule I-1.  
For example, the taxpayer may still be  
required to complete a Form 1116 or a  
Form 1118, and/or a Form 5471  
(including Schedule J and  
2019-40, earlier, for more details.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Line 5c. Enter the line 5b functional  
currency amount translated into U.S.  
dollars for the CFC’s tax year.  
Schedule P), and separately report  
passive category income and section  
951A category income.  
Schedule I-1  
This schedule is used to report  
information determined at the CFC  
level with respect to amounts used in  
the determination of income  
Separate category. Schedule I-1 is  
no longer completed separately for  
each applicable category of income.  
Therefore, Schedule I-1 is now  
Line 1. Enter the CFC’s gross  
income. The amount of gross income  
entered on line 1 will generally be a  
Instructions for Form 5471 (Rev. 01-2024)  
37  
     
positive amount. However, if a CFC’s  
cost of goods sold exceeds its gross  
receipts, a negative amount is  
permitted on line 1.  
Line 2. Enter the CFC’s exclusions as  
described in Regulations section  
1.951A-2(c).  
the CFC. See Regulations section  
1.951A-1(d)(1).  
Line 3. Combine lines 2a through 2e.  
The line 3 result can be positive or  
negative.  
Line 4. Subtract line 3 from line 1 and  
enter the result on line 4. The line 4  
result can be positive or negative. For  
example:  
Qualified business asset  
investment (QBAI). QBAI is the  
average of the CFC's aggregate  
adjusted bases, as of the close of  
each quarter of its tax year, in  
specified tangible property used in its  
trade or business in the production of  
tested income, and for which a  
Line 2a. Enter the amount of the  
CFC’s income or loss described in  
section 952(b), which is generally  
income or loss from sources within the  
United States that is effectively  
Line 1  
gross  
income  
$1,000 $1,000 $(1,000) $(1,000)  
deduction is allowable under section  
167. Adjusted basis in any property  
must be determined by using the  
alternative depreciation system under  
section 168(g) and allocating  
Line 3 total  
exclusions  
800  
(800)  
800  
(800)  
connected to the conduct of a trade or  
business by the CFC in the United  
States and not reduced or exempt  
from tax pursuant to an income tax  
treaty with the United States.  
Line 4  
(line 1  
minus  
line 3)  
depreciation deductions with respect  
to such property ratably to each day  
during the period in the tax year to  
which such depreciation relates.  
$200 $1,800 $(1,800)  
$(200)  
Line 2b. Enter the amount, if any,  
of the CFC’s gross income or loss  
taken into account in determining the  
CFC’s subpart F income (as defined in  
section 952). Note that an amount  
determined under section 956(a) is  
not considered subpart F income. The  
amount to be entered is computed  
after application of the high-tax  
Line 5. Enter the deductions  
(including taxes) properly allocable to  
the amount on line 4 (or to which such  
deductions would be allocable if there  
were such gross income). See section  
951A(c)(2)(A)(ii) and Regulations  
section 1.951A-2(c)(3). The amount  
entered on line 5 will generally be a  
positive amount. However, a negative  
amount is permitted on line 5.  
Specified tangible property and  
dual-use property. Specified  
tangible property means any tangible  
property used in the production of  
tested income. If such property was  
used in the production of tested  
income and income that is not tested  
income (that is, dual-use property),  
the property is treated as specified  
tangible property in the same  
exception in section 954(b)(4), but  
before application of the E&P  
Line 6. Subtract line 5 from 4 and  
enter the result on line 6. The line 6  
result can be positive or negative. See  
the line 4 instructions above for  
examples. This amount must be  
converted from functional currency to  
U.S. dollars using the average  
exchange rate for the year of the CFC.  
See Regulations section 1.951A-1(d)  
(1).  
Report the exchange rate using the  
“divide-by convention” specified under  
5471, earlier.  
Line 7. If the CFC has a tested loss  
on line 6, enter zero. If the CFC has  
tested income on line 6, enter only  
those foreign income taxes that are  
properly attributable to the CFC’s  
tested income group. This amount  
must be converted from functional  
currency to U.S. dollars using the  
average exchange rate for the year of  
the CFC. See section 986.  
Line 8. If the CFC has a tested loss  
on line 6, enter zero. If the CFC has  
tested income on line 6, enter the  
qualified business asset investment  
(QBAI) (defined below). This amount  
must be converted from functional  
currency to U.S. dollars using the  
average exchange rate for the year of  
limitation in section 952(c)(1)(A).  
proportion that the amount of tested  
income determined before allocable  
deductions (that is, line 4) produced  
with respect to the property bears to  
the total amount of gross income  
produced with respect to the property.  
Line 2c. Enter the amount, if any,  
of the CFC’s gross income excluded  
from foreign base company income  
(as defined in section 954) and  
insurance income (as defined in  
section 953) by reason of section  
954(b)(4), the high-tax exception  
(include amounts excluded from  
tested income under Regulations  
section 1.951A-2(c)(7)).  
Partnership property. A CFC  
with tested income that is a partner of  
a partnership that has depreciable  
tangible property determines its share  
of the partnership’s average adjusted  
basis in the depreciable tangible  
property of the partnership based on  
the amount of the distributive share of  
the gross income produced by the  
property that is included in the CFC’s  
gross tested income (defined below)  
relative to the total amount of gross  
income produced by the property. The  
partnership’s average adjusted basis  
in the depreciable tangible property of  
the partnership is generally  
Line 2d. Enter the amount of any  
dividend income received by the CFC  
from a related person as defined in  
section 954(d)(3). Do not include the  
amounts of any dividend income  
received from a related person that  
are already included in the amounts  
entered on line 2b or line 2c.  
Line 2e. Enter the amount of the  
CFC’s taxable income or loss from  
sources outside the United States and  
its territories from the following.  
determined based on the average of  
the adjusted basis in the property as  
of the close of each quarter of the  
partnership’s tax year that ends with  
or within the CFC’s tax year. See  
Regulations section 1.951A-3(g).  
Gross tested income. For these  
purposes, a CFC’s gross tested  
income is its gross income less total  
exclusions (Schedule I-1, line 4).  
The extraction (by the corporation  
or any other person) of minerals from  
oil or gas wells located outside the  
United States and its territories.  
The sale or exchange of assets  
used (by the corporation) in the trade  
or business of extracting minerals  
from oil or gas wells located outside  
the United States and its territories.  
Instructions for Form 5471 (Rev. 01-2024)  
38  
 
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).  
PTEP amounts required to be  
Lines 9a through 9d. In general,  
see Regulations section 1.951A-4(b)  
(1) to determine how to compute the  
CFC’s tested interest expense.  
included in column (e). If the person  
filing Form 5471 is unable to  
determine whether amounts should  
be reported as PTEP, those amounts  
should be included in column (a),  
Post-2017 E&P Not Previously Taxed  
(post-2017 section 959(c)(3)  
Line 9a. Enter the amount of  
interest expense included on line 5.  
See Line 6, earlier, for foreign  
currency translation.  
Lines a and b. Complete a separate  
Schedule J for each applicable  
balance). For example, one U.S.  
shareholder might not know the  
amount of the other U.S.  
separate category of income. Enter  
the appropriate code on line a (at the  
top of page 1 of Schedule J). To  
determine the appropriate code, see  
Categories of Income in the  
Line 9b. Enter the CFC’s qualified  
interest expense, as defined in  
Regulations section 1.951A-4(b)(1)  
(iii).  
shareholder’s section 951A inclusion  
that is allocated to the CFC because  
the first U.S. shareholder does not  
have information with respect to the  
second U.S. shareholder’s net CFC  
tested income or pro rata share of  
QBAI. See the instructions for  
Line 9c. Enter the CFC’s tested  
loss QBAI amount, as defined in  
Regulations section 1.951A-4(b)(1)  
(iv).  
Instructions for Form 1118. E&P with  
respect to all categories of income  
listed in the Instructions for Form  
1118, except foreign branch category  
income, may need to be reported. A  
foreign corporation may have E&P in  
an income group within the general  
category, passive category, or section  
901(j) category. See Regulations  
section 1.960-1(d)(2)(ii). A foreign  
corporation may have PTEP in a  
PTEP group within any of the separate  
categories of income, except foreign  
branch category income. See  
Schedule P, later, for an example.  
Line 9d. Subtract the sum of  
line 9b and line 9c from line 9a and  
enter the result on line 9d.  
Lines 10a through 10c. In general,  
see Regulations section 1.951A-4(b)  
(2) to determine how to compute the  
CFC’s tested interest income.  
Enter the amounts in this schedule  
in the functional currency of the  
foreign corporation as reported on  
Form 5471, page 1, item 1h. If the  
foreign corporation is the owner of a  
qualified business unit(s) (QBU) with a  
different functional currency, translate  
the E&P of the QBU(s) to the foreign  
corporation’s functional currency.  
Line 10a. Enter the amount of  
interest income included on line 4.  
See Line 6, earlier, for foreign  
currency translation.  
Regulations section 1.960-3(c)(1).  
Columns (a), (b), and (c)  
If code 901j is entered on line a,  
enter on line b the country code for  
the sanctioned country using the  
two-letter code (from the list at  
Report the opening balance, current  
year additions and subtractions, and  
the closing balance in the foreign  
corporation's E&P described in  
section 959(c)(3). In general, this is  
E&P of the foreign corporation that  
has not been included in gross  
income of a U.S. person under section  
951(a)(1) and section 951A.  
Line 10b. Enter the CFC’s  
qualified interest income, as defined in  
Regulations section 1.951A-4(b)(2)  
(iii).  
Note. A separate Schedule J should  
not be completed for the section 951A  
category. Reclassified section 951A  
PTEP and section 951A PTEP that is  
in the section 951A category should  
be reported on the general category  
Schedule J.  
Line 10c. Subtract line 10b from  
line 10a and enter the result on  
line 10c.  
In column (a), report E&P  
Schedule J  
described in section 959(c)(3) and  
earned after the repeal of section 902,  
that is, post-2017 E&P not previously  
taxed (post-2017 section 959(c)(3)  
balance). The repeal of section 902 is  
effective for tax years of foreign  
corporations beginning after  
Use Schedule J to report a CFC’s  
accumulated E&P in its functional  
currency, computed under sections  
964(a) and 986(b). Also use this  
schedule to report the E&P of  
Note. For purposes of this  
Schedule J, include in each separate  
category of income, foreign source  
and U.S. source income.  
specified foreign corporations that are  
only treated as CFCs for limited  
purposes under section 965(e)(2).  
Important. In addition to the  
December 31, 2017, and to tax years  
of U.S. shareholders in which or with  
which such tax years of foreign  
corporations end.  
separate category codes referred to  
above, if you have more than one of  
the categories of income referred to  
above, you must complete and file a  
separate Schedule J using code  
“TOTALthat aggregates all amounts  
listed for each line and column in Part  
I of all other Schedules J.  
Note. Category 1b, 1c, 5b, and 5c  
filers are not required to file  
Schedule J for foreign-controlled  
section 965 SFCs or  
In column (b), report post-1986  
undistributed earnings, as defined  
under section 902(c)(1), and as in  
effect prior to the repeal of section  
902.  
foreign-controlled CFCs.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
Part I—Accumulated E&P of  
Use column (c) to report the  
aggregate amount of the foreign  
corporation's pre-1987 section 964(a)  
E&P accumulated since 1962 and not  
previously distributed or deemed  
distributed. These amounts are  
Controlled Foreign Corporation  
Check the box at the top of Part I if the  
person filing Form 5471 does not have  
all U.S. shareholders’ information  
necessary to complete any one of the  
Instructions for Form 5471 (Rev. 01-2024)  
39  
 
figured in U.S. dollars using the rules  
of Regulations section 1.964-1(a)  
through (d), and translated into the  
foreign corporation's functional  
currency according to Notice 88-70,  
1988-2 C.B. 369.  
investments in U.S. property (section  
959(c)(1) amounts).  
attributable to a distribution of such  
PTEP. See section 965(g) and  
Column (e)(v) is PTEP described in  
Regulations section 1.965-5 for more  
information. This is the case for both  
direct foreign tax credits (that is, those  
foreign taxes paid or accrued directly  
by the shareholder upon receipt of the  
PTEP distribution and allowed as a  
credit under section 901 or 903) and  
indirect foreign tax credits (that is,  
those taxes deemed paid by the  
shareholder with respect to taxes  
originally paid or accrued by the CFC  
under section 960(b)). With respect to  
direct credits, this reduction applies  
regardless of whether such individual  
made an election under section 962.  
Therefore, the reporting on  
the following three subgroups (which  
are aggregated into a single PTEP  
group) (section 959(c)(1) amounts).  
1. PTEP attributable to hybrid  
dividends under section 245A(e)(2)  
and reclassified as investments in  
U.S. property.  
2. PTEP attributable to section  
1248 amounts under section 959(e)  
and reclassified as investments in  
U.S. property.  
3. PTEP attributable to section  
1248 amounts from the gain on the  
sale of foreign corporation stock by a  
CFC and reclassified as investments  
in U.S. property.  
Column (d)  
Use column (d) to report hovering  
deficits (see section 381(c)(2)(B) and  
Regulations section 1.367(b)-7) and  
suspended taxes (see section 909).  
See Specific Instructions Related to  
Lines 1 Through 13, later, for  
additional information pertaining to  
reporting amounts in column (d).  
Column (e)  
Use column (e) to report the running  
balance of the foreign corporation's  
PTEP, section 964(a) E&P  
Schedule J is necessary regardless of  
whether the U.S. shareholder made a  
section 962 election.  
Column (e)(vi) is PTEP attributable  
accumulated since 1962 that have  
resulted in deemed inclusions under  
subpart F, or amounts treated as  
PTEP under section 965(b)(4)(A).  
Pre-1987 U.S. dollar PTEP should be  
translated into the foreign  
to section 965(a) inclusions (section  
959(c)(2) amounts). Do not include in  
column (e)(vi) E&P reported in column  
(e)(vii).  
Column (f)  
Use column (f) to report the opening  
and closing balances of the foreign  
corporation's accumulated E&P. This  
amount is the sum of post-2017 E&P  
not previously taxed, post-1986  
Column (e)(vii) is E&P treated as  
PTEP under section 965(b)(4)(A)  
(section 959(c)(2) amounts).  
corporation's functional currency  
using the rules of Notice 88-70 and  
added to post-1986 amounts in the  
appropriate PTEP group.  
undistributed earnings, pre-1987 E&P  
not previously taxed, and PTEP. Do  
not include column (d) amounts in the  
total reported in column (f).  
Column (e)(viii) is PTEP attributable  
to section 951A inclusions (section  
959(c)(2) amounts).  
Columns (e)(i) and (e)(ii) are PTEP  
Column (e)(ix) is PTEP described in  
originally attributable to inclusions  
under section 965(a) and E&P treated  
as PTEP under section 965(b)(4)(A),  
respectively, and reclassified as  
investments in U.S. property (section  
959(c)(1) amounts).  
the following three subgroups (which  
are aggregated into a single PTEP  
group) (section 959(c)(2) amounts).  
Specific Instructions Related to  
Lines 1 Through 13  
Line 1a. Enter the balances for each  
column at the beginning of the tax  
year. These balances should equal  
the amounts reported as the ending  
balances in the prior year Schedule J.  
1. PTEP attributable to hybrid  
dividends under section 245A(e)(2).  
2. PTEP attributable to section  
Column (e)(iii) is PTEP described in  
1248 amounts under section 959(e).  
the following three subgroups (which  
are aggregated into a single PTEP  
group) (section 959(c)(1) amounts).  
3. PTEP attributable to section  
1248 amounts from the gain on the  
sale of foreign corporation stock by a  
CFC.  
Line 1b. If there is a difference  
between last year’s ending balance on  
Schedule J and the amount that  
should be last year’s ending balance,  
taking into account modifications on  
Schedule J, include the difference on  
line 1b and attach an explanation for  
the difference. If there are multiple  
reasons for differences, include the  
explanation and amount of each such  
difference on the attachment. Do not  
include adjustments required to be  
reported on line 6 or 12.  
1. PTEP attributable to  
investments in U.S. property and not  
by reason of reclassification.  
Column (x) is PTEP attributable to  
section 951(a)(1)(A) inclusions  
(section 959(c)(2) amounts) not  
otherwise described in the  
instructions for columns (e)(vi)  
through (ix).  
2. PTEP attributable to inclusions  
under section 951(a)(1)(A) (other than  
inclusions under section 951(a)(1)(A)  
described in the instructions for  
columns (e)(vi) through (ix)) and  
reclassified as investments in U.S.  
property (for example, PTEP  
Schedule J reports PTEP by  
subgroups because those groups may  
be subject to different rules under  
sections 960, 965(g), 245A(e)(3), and  
986(c). The different rules are  
attributable to subpart F income  
inclusions and reclassified as  
Lines 1a through 1c. These lines of  
column (d) account for the balance of  
prior year hovering deficits and  
investments in U.S. property).  
applicable for individuals, as well as  
corporations, estates, and trusts. For  
example, an individual U.S.  
3. PTEP attributable to inclusions  
under former section 951(a)(1)(C) and  
subpart F income inclusions  
suspended taxes that have not yet  
been deducted. Such amounts are  
reported as negative numbers.  
shareholder who receives a  
reclassified as investments in excess  
passive assets.  
distribution of PTEP originally  
attributable to inclusions under  
section 965(a) may only claim a credit  
for a portion of the foreign taxes  
Line 2a. This line of column (d) is the  
unsuspended taxes under section 909  
as a result of related income taken  
Column (e)(iv) is PTEP originally  
attributable to inclusions under  
section 951A and reclassified as  
Instructions for Form 5471 (Rev. 01-2024)  
40  
 
into account by the foreign  
nonrecognition transaction. See  
(1)(A) or section 951A with respect to  
the CFC. Report the inclusion as a  
negative amount in columns (a)  
through (c), as applicable. Report the  
inclusion as a positive amount in  
corporation, certain U.S. corporate  
section 381(c)(2)(B) and Regulations  
owners of the foreign corporation, or a section 1.367(b)-7(d)(2)(i) (post-1986  
member of such U.S. corporate  
owner’s consolidated group. Report  
the unsuspended taxes on line 2a of  
column (d) as a positive number.  
Report the unsuspended taxes as  
negative numbers on line 2a of  
column (a), (b), (c), or (e), as  
applicable.  
undistributed earnings) and  
1.367(b)-7(e)(1) (pre-1987 E&P not  
previously taxed). An amount equal to columns (e)(vi) through (e)(x), as  
the deficit reported in column (a), (b),  
or (c) of line 5a is included as a  
applicable. Amounts reported as  
positive numbers on line 8 of column  
(e)(viii) should only be reported with  
positive amount on line 5b of column  
(a), (b), or (c), respectively. An amount respect to negative amounts on line 8  
equal to the total hovering deficits  
of column (a). The negative amounts  
reported on line 5b of columns (a), (b), could be reported on a different  
Line 2b. This line of column (d)  
accounts for foreign income taxes that  
are suspended in the current tax year.  
Report such amounts as negative  
numbers.  
and (c) is included as a negative  
number in column (d) of line 5b.  
Schedule J than the positive amounts  
if such amounts are reclassified from  
one separate category to another  
separate category.  
Line 6. Attach a statement detailing  
the nature and amount of any  
adjustments not accounted for in the  
E&P determined before reduction for  
distributions and inclusions (that is,  
adjustments other than those listed on  
lines 2a through 5b). Do not include  
amounts reported on line 1b. An  
example of an adjustment entered on  
line 6 is the foreign taxes imposed on  
receipt of a distribution of PTEP from  
a lower-tier foreign corporation.  
Note. Section 951(a)(1)(A) inclusions  
are taken into account for the tax year  
before actual distributions and section  
951(a)(1)(B) inclusions. See section  
959.  
Line 3. Enter the current year E&P (or  
deficit in E&P) amount from the  
applicable line 5c of Schedule H  
(Form 5471). For example, if you are  
completing Schedule J for the passive  
category (that is, you have entered  
PAS” on line a at the top of page 1 of  
Schedule J), enter the current year  
E&P (or deficit in E&P) amount from  
Schedule H (Form 5471), line 5c(ii), in  
the applicable column. Line 3 should  
never have an amount entered in  
column (e).  
Note. The amount included in gross  
income of U.S. shareholders of the  
CFC under section 951A might not be  
known if there is more than one U.S.  
shareholder. In that case, see the  
example in the instructions for  
Example. Domestic Corporation, a  
U.S. shareholder, wholly owns the  
only class of stock of CFC1, a foreign  
corporation. CFC1, in turn, wholly  
owns the only class of stock of CFC2,  
a foreign corporation. CFC2, in turn,  
wholly owns the only class of stock of  
CFC3, a foreign corporation. The  
functional currency of Domestic  
Corporation, CFC1, CFC2, and CFC3  
is the U.S. dollar. During Year 1,  
Domestic Corporation reports an  
inclusion under section 951(a)(1) of  
$100 as a result of subpart F income  
of CFC3. During Year 2, CFC3  
Schedule P for reporting information.  
Line 4. Report as a positive number  
E&P attributable to distributions of  
PTEP from lower-tier foreign  
Note. The amount reported in column  
(e)(viii) on line 8 will not necessarily  
equal the tested income reported on  
Schedule I-1. For an example of when  
this might occur, see Regulations  
section 1.951A-5(b)(2)(ii).  
corporations. Generally, the E&P of a  
CFC attributable to amounts that are,  
or have been, included in the gross  
income of a U.S. shareholder under  
section 951(a) are not, when  
Line 9. Report actual distributions as  
negative numbers.  
distributed through a chain of  
ownership described in section  
958(a), also included in the gross  
income of another CFC in such chain  
for purposes of the application of  
section 951(a) to such other CFC with  
respect to such U.S. shareholder. See  
section 959(b).  
Note. Actual distributions are taken  
into account for the tax year before  
section 951(a)(1)(B) inclusions. See  
section 959(f)(2). An actual  
distributes $40 to CFC2. CFC2 pays  
withholding tax of $4 on the  
distribution is first out of PTEP, if any,  
and then out of the section 959(c)(3)  
balance. See section 959(c).  
distribution from CFC3. Such tax is  
related to previously taxed subpart F  
income. Domestic Corporation reports  
on CFC2’s Form 5471, Schedule J,  
line 4, column (e)(x), as a positive  
number, the $40 PTEP distribution.  
Domestic Corporation reports on  
line 6, column (e)(x), as a negative  
number, the $4 of tax on the PTEP  
distribution.  
Line 5a. Enter earnings carried over  
to a foreign surviving corporation after  
an acquisition by a foreign corporation  
of the assets of another foreign  
corporation in a transaction described  
in section 381. See Regulations  
section 1.367(b)-7. The amounts  
entered on line 5a may be negative or  
positive. Negative amounts are  
hovering deficits reported in column  
(d) of line 5a.  
Line 5b. If the foreign surviving  
corporation had a deficit in E&P prior  
to a transaction described in section  
381, such deficit is recharacterized as  
a hovering deficit after such  
Note. The total of all amounts  
entered in Schedule R (Form 5471),  
column (d), must equal the amount on  
line 9, column (f), of the Schedule J  
(Form 5471) that is filed, or if more  
than one Schedule J (Form 5471) is  
filed, the Schedule J (Form 5471) with  
code “TOTALentered on line a of that  
Schedule J.  
Line 7. Enter on line 7 E&P as of the  
close of the tax year before actual  
distributions or inclusions under  
section 951(a)(1) or section 951A  
during the year.  
Line 10. Use line 10 to report  
reclassifications of section 959(c)(2)  
PTEP in columns (e)(vi) through (e)(x)  
to section 959(c)(1) PTEP in columns  
(e)(i) through (e)(v). A potential  
Line 8. Enter amounts included in  
gross income of the U.S.  
shareholder(s) under section 951(a)  
section 951(a)(1)(B) inclusion results  
Instructions for Form 5471 (Rev. 01-2024)  
41  
in a reclassification of section 959(c)  
(2) PTEP, if any, to section 959(c)(1)  
category or categories of filers (see  
specified other amounts received  
Categories of Filers, earlier). However, during the annual accounting period  
PTEP before reclassification out of the in the case of a consolidated return,  
by the foreign corporation from the  
persons listed in the headings for  
columns (b) through (f). These  
section 959(c)(3) E&P balance. See  
section 959(a)(2) and (f)(1). The  
amounts reclassified are reported as  
negative numbers in columns (e)(vi)  
through (e)(x) and positive numbers in  
columns (e)(i) through (e)(v), as  
applicable.  
Line 11. Use this line to report E&P  
not previously taxed, which is treated  
as earnings invested in U.S. property  
and, therefore, reclassified to section  
959(c)(1) PTEP (column (e)(iii)). The  
amounts reclassified are reported as  
negative numbers in columns (a)  
through (c) and positive numbers in  
column (e)(iii), as applicable.  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
headings must comport to those used  
on the Schedule M (Form 5471) to  
which this statement is attached. The  
attached statement must include a  
“totals” line that ties into the amounts  
reported in each column of line 14.  
Reference ID number of foreign  
corporation. Use the reference ID  
number shown on Form 5471, page 1,  
item 1b(2).  
Lines 4 and 19. Report on these  
lines platform contribution transaction  
payments received and paid by the  
foreign corporation (without giving  
effect to any netting of payments).  
See Regulations section 1.482-7(b)(1)  
(ii).  
If an amount is entered on line 29,  
you must attach a statement that  
includes the following information.  
Column (a) of the attached statement  
should provide a description of the  
type of other amount paid during the  
annual accounting period. Columns  
(b) through (f) should provide dollar  
amounts of the specified other  
Lines 5 and 20. Report on these  
lines cost sharing transaction  
Line 12. Attach a statement detailing  
the nature and amount of any  
amounts paid during the annual  
accounting period by the foreign  
corporation to the persons listed in the  
headings for columns (b) through (f).  
These headings must comport to  
those used on the Schedule M (Form  
5471) to which this statement is  
attached. The attached statement  
must include a “totals” line that ties  
into the amounts reported in each  
column of line 29.  
payments received and paid by the  
foreign corporation (without giving  
effect to any netting of payments).  
See Regulations section 1.482-7(b)(1)  
(i). The corporation is required to  
complete line 5 only if the corporation  
itself incurred intangible development  
adjustments in E&P not accounted for  
on lines 8 through 11. Do not include  
adjustments required to be reported  
on line 1b or line 6.  
Line 13. The hovering deficit offset  
included in column (d) is reported as a costs. If the corporation does not itself  
positive number. The same amount  
entered in column (d) is reported as a  
negative number on line 13 of column  
(a) or (b), as appropriate. See section  
381(c)(2)(B) and Regulations section  
1.367(b)-7(d)(2)(ii).  
incur intangible development costs,  
then it should only report cost sharing  
transaction payments made on  
line 20.  
Lines 31 and 33. Report on these  
lines the largest aggregate  
Lines 9 and 24. Report on line 9 the  
sum of tiered hybrid dividends  
outstanding accounts receivable and  
payable balances during the year with  
the related parties described in  
received by the foreign corporation  
during its tax year. Report on line 24  
the sum of hybrid dividends or tiered  
hybrid dividends paid by the foreign  
corporation during its tax year.  
Schedule M  
columns (b) through (f). Report only  
accounts receivable or payable arising  
in connection with the provision of  
services or the sale or processing of  
property. Only net accounts receivable  
and payable to the extent that the  
CFC’s books net the accounts  
Every U.S. person described in  
Category 4 must file Schedule M to  
report the transactions that occurred  
during the foreign corporation's  
Lines 10 and 25. Report on these  
lines dividends received and paid by  
the foreign corporation not previously  
taxed under subpart F in the current  
year or in any prior year.  
Lines 13 and 28. Report on these  
lines loan guarantee fees received  
(line 13) and loan guarantee fees paid  
(line 28). See section 482.  
Lines 14 and 29. Report on these  
lines “other amounts received”  
(line 14) and “other amounts paid”  
(line 29).  
annual accounting period ending with  
or within the U.S. person's tax year.  
If a U.S. corporation that owns  
stock in a foreign corporation is a  
member of a consolidated group, list  
the common parent as the U.S.  
person filing Schedule M.  
payable against the receivable as  
payment of the accounts receivable.  
Lines 32 and 34. Report on these  
lines the largest outstanding balances  
during the year of gross amounts  
borrowed from, and gross amounts  
loaned to, the related parties  
Important. In translating the amounts  
from functional currency to U.S.  
dollars, use the average exchange  
rate for the foreign corporation's tax  
year. See section 989(b). Report the  
exchange rate in the entry space  
provided at the top of Schedule M  
using the “divide-by convention”  
specified under Reporting exchange  
rates on Form 5471, earlier.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
described in columns (b) through (f).  
Do not enter aggregate cash flows,  
year-end loan balances, average  
balances, or net balances. Do not  
include an account receivable or  
payable balance arising in connection  
with the provision of services or the  
sale or processing of property if the  
amount of such balance does not, at  
any time during the tax year, exceed  
what is ordinary and necessary to  
carry on the trade or business. Any  
If an amount is entered on line 14,  
you must attach a statement that  
includes the following information.  
Column (a) of the attached statement  
should provide a description of the  
type of other amounts received during  
the annual accounting period.  
Columns (b) through (f) should  
provide dollar amounts of the  
Instructions for Form 5471 (Rev. 01-2024)  
42  
 
outstanding balance from these  
transactions should be reported on  
the Balance Sheet (Form 5471,  
Schedule F, page 4) and possibly also  
on Schedule M, lines 31 and 33.  
Accrued payments and receipts. A  
corporation that uses an accrual  
method of accounting must use  
accrued payments and accrued  
receipts for purposes of computing  
the total amount to enter on each line  
of Schedule M.  
Enters “5,000” in column (e)(1).  
Enters “-0-” in column (f) because  
Part II  
Section A—General Shareholder  
Information  
the disposition was by gift.  
Enters the name and address of his  
son, John, in column (g).  
If the shareholder's latest tax return  
was filed electronically, enter “e-filed”  
in column (b)(3) instead of a service  
center.  
Section F—Additional Information  
Item (b). List the date of any  
reorganization of the foreign  
corporation that occurred during the  
last 4 years while any U.S. person  
held 10% or more in value or vote  
(directly or indirectly) of the  
Section C—Acquisition of Stock  
Section C is completed by  
shareholders who are completing  
Schedule O because they have  
acquired sufficient stock in a foreign  
corporation. If the shareholder  
acquired the stock in more than one  
transaction, use a separate line to  
report each transaction.  
corporation's stock. If there is more  
than one such date, use the most  
recent date. However, do not enter a  
date for which information was  
reported in Section E. Instead, enter  
the date (if any) of any reorganization  
prior to that date (if it is within the last  
4 years).  
Schedule O  
Schedule O is used to report the  
organization or reorganization of a  
foreign corporation and the acquisition  
or disposition of its stock.  
Every U.S. citizen or resident  
described in Category 2 must  
complete Part I. Every U.S. person  
described in Category 3 must  
complete Part II.  
Column (d). Enter the method of  
acquisition (for example, purchase,  
gift, bequest, trade).  
Column (e)(2). Enter the number of  
shares acquired indirectly (within the  
meaning of section 958(a)(2)) by the  
shareholder listed in column (a).  
Column (e)(3). Enter the number of  
shares constructively owned (within  
the meaning of section 958(b)) by the  
shareholder listed in column (a).  
Example for item (c). Mr. Lyons,  
a U.S. person, acquires a 10%  
ownership in foreign corporation F. F  
is the 100% owner of two foreign  
corporations, FI and FJ. F is also a  
50% owner of foreign corporation FK.  
In addition, F is 90% owned by foreign  
corporation W. Mr. Lyons does not  
own any of the stock of corporation W.  
See Regulations section  
1.6046-1(i) for rules on determining  
when U.S. persons constructively own  
stock of a foreign corporation and are  
therefore subject to the section 6046  
filing requirements.  
Mr. Lyons completes and files Form  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. Use the reference ID  
number shown on Form 5471, page 1,  
item 1b(2).  
5471 and Schedule O for the  
Section D—Disposition of Stock  
corporations in which he is a  
10%-or-more shareholder. Mr. Lyons  
is also required to submit a chart if the  
foreign corporation is a member of a  
chain of corporations, and to indicate  
if he is a 10%-or-more shareholder in  
any of those corporations.  
Section D must be completed by  
shareholders who dispose of their  
interest (in whole or in part) in a  
foreign corporation.  
Column (d). Enter the method of  
disposition (for example, sale,  
bequest, gift, trade).  
Mr. Lyons would prepare a list  
showing the corporations as follows.  
Corporation W.  
Corporation F.  
Corporation FI.  
Corporation FJ.  
Corporation FK.  
Example. In 1999, Mr. Jackson, a  
U.S. citizen, purchased 10,000 shares  
of common stock of foreign  
corporation X. The purchase  
represented 10% ownership of the  
foreign corporation.  
Part I  
Then Mr. Lyons is required to  
Column (d). Enter the date the  
shareholder first acquired 10% or  
more (in value or voting power) of the  
outstanding stock of the foreign  
corporation.  
Column (e). Enter the date the  
shareholder acquired (whether in one  
or more transactions) an additional  
10% or more (in value or voting  
power) of the outstanding stock of the  
foreign corporation.  
indicate that he is a 10%-or-more  
shareholder in corporations F, FI, and  
FJ.  
On July 1, 2023, Mr. Jackson made  
a gift of 5,000 shares of foreign  
corporation X to his son, John.  
Because Mr. Jackson has reduced his  
holding in the foreign corporation, he  
is required to complete Form 5471  
and Schedule O. To show the required  
information about the disposition, Mr.  
Jackson completes Section D as  
follows.  
Schedule P  
Use Schedule P to report the PTEP in  
the U.S. shareholder’s annual PTEP  
accounts with respect to a CFC in the  
CFC’s functional currency (Part I) and  
the U.S. shareholder’s U.S. dollar  
basis in that PTEP (Part II). For  
Enters his name in column (a).  
Enters “common” in column (b).  
Enters July 1, 2023” in column (c).  
Enters “gift” in column (d).  
purposes of the preceding sentence,  
a CFC includes an SFC that is only  
Instructions for Form 5471 (Rev. 01-2024)  
43  
   
treated as a CFC for limited purposes  
under section 965(e)(2).  
respect to its PTEP of $50x on line 8,  
column (e)(viii). In the following year,  
Corporation A and Corporation B  
should each report the other  
“TOTALthat aggregates all amounts  
listed for each line and column of all  
other Schedules P.  
Note. A separate Schedule P must  
be completed by each Category 1a,  
1b, 4, 5a, or 5b filer.  
Part I  
corporation’s PTEP on Schedule J,  
Part I, line 1b, column (e)(viii), and the  
corresponding reduction to CFC1’s  
E&P described in section 959(c)(3) on  
Schedule J, Part I, line 1b, column (a).  
Enter amounts in the functional  
currency of the foreign corporation as  
reported on Form 5471, page 1, item  
1h.  
If a U.S. shareholder wholly owns  
the CFC, Schedule P should include  
the same information reported on  
Schedule J, Part I, column (e). If there  
is more than one U.S. shareholder, the  
amounts reported on Schedule P with  
respect to each U.S. shareholder  
might be different from the amounts  
reported on Schedule J.  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. If applicable, use the  
reference ID number shown on Form  
5471, page 1, item 1b(2).  
Pre-1987 U.S. dollar PTEP should  
be translated into the foreign  
corporation's functional currency  
using the rules of Notice 88-70 and  
added to post-1986 amounts in the  
appropriate PTEP category.  
Example. Corporation A, a  
Part II  
domestic corporation, owns 50% of  
the only class of stock of CFC1, and  
Corporation B, a domestic  
Dollar basis. Enter amounts in U.S.  
dollars. The U.S. shareholder’s U.S.  
dollar basis in PTEP is generally equal  
to the U.S. dollar amount of E&P that  
the U.S. shareholder previously  
included in gross income. See section  
989(b)(1) and (3); and Regulations  
sections 1.951A-1(d)(1) and  
corporation, owns the remaining 50%  
of the stock of CFC1. Corporation A  
wholly owns the only class of stock of  
CFC2. The functional currency of all  
corporations is the U.S. dollar. CFC1  
has tested income of $100x and  
CFC2 has tested loss of $30x. See  
section 951A(c)(2). Neither  
Lines a and b. Complete a separate  
Schedule P for each applicable  
separate category of income. Enter  
the appropriate code on line a (at the  
top of page 1 of Schedule P). To  
determine the appropriate code, see  
Categories of Income in the  
1.965-1(b)(1) and (2).  
The U.S. shareholder’s U.S. dollar  
basis is used by the U.S. shareholder  
to determine the amount of foreign  
currency gain or loss on the PTEP that  
the U.S. shareholder is required to  
recognize under section 986(c).  
Columns (a) through (k). Use  
columns (a) through (k) to report the  
opening balance of, current year  
additions and subtractions to, and the  
closing balance of, the PTEP in the  
U.S. shareholder’s annual PTEP  
accounts with respect to a CFC.  
Corporation A nor Corporation B has  
any net deemed tangible income  
return that would reduce the GILTI  
inclusion of Corporation A or B.  
Corporation A has a section 951A  
inclusion of $20 because its pro rata  
share of CFC1’s tested income ($50x)  
is offset by its pro rata share of  
Instructions for Form 1118.  
A foreign corporation may have  
PTEP in a PTEP group within any of  
the separate categories of income,  
with the exception of foreign branch  
category income. See Regulations  
section 1.960-3(c)(1).  
If code 901j is entered on line a,  
enter on line b the country code for  
the sanctioned country using the  
CFC2’s tested loss ($30x).  
Corporation B has a section 951A  
inclusion of $50x. On Schedule P of  
the Form 5471 with respect to CFC1  
filed by Corporation B, Corporation B  
will report on line 7, column (h), $50x  
Columns (a) through (j) of  
Schedule P correspond to  
of PTEP as a result of its section 951A two-letter code (from the list at  
Schedule J, columns (e)(i) through (e)  
(x). See Schedule J, earlier, for  
specific line instructions.  
inclusion with respect to CFC1.  
Corporation A will report $20x of  
PTEP as a result of its section 951A  
inclusion on its Form 5471,  
Note. A separate Schedule P should  
not be completed for the section 951A  
category. Reclassified section 951A  
PTEP and section 951A PTEP that is  
in the section 951A category should  
be reported on the Schedule P  
Line 1b. If there is a difference  
between last year’s ending balance on  
Schedule P and the amount that  
should be last year’s ending balance,  
taking into account modifications on  
Schedule P, include the difference on  
line 1b and attach an explanation for  
the difference. If there are multiple  
differences, include the explanation  
and amount of each such difference  
on the attachment.  
Schedule P, line 7, column (h), with  
respect to CFC1.  
The Form 5471, Schedule J, for  
CFC1 should include PTEP of $70x  
with respect to the aggregate section  
951A inclusions of Corporation A and  
Corporation B. However, if  
completed for the general category.  
Note. For purposes of this  
Schedule P, include in each separate  
category of income, foreign source  
and U.S. source income.  
Corporation A does not know  
Corporation B’s section 951A  
inclusion at the time Corporation A  
files its Form 5471, Corporation A will  
only be able to complete Schedule J,  
Part I, with respect to its PTEP of $20x  
on line 8, column (e)(viii). Similarly,  
Corporation B will only be able to  
complete Schedule J, Part I, with  
Important. In addition to the  
separate category codes referred to  
above, if you have more than one of  
the categories of income referred to  
above, you must complete and file a  
separate Schedule P using code  
Schedule Q  
Use Schedule Q to report the CFC’s  
income, deductions, taxes, and assets  
by CFC income groups for purposes  
of section 960(a) and (d).  
Instructions for Form 5471 (Rev. 01-2024)  
44  
 
In general, a taxpayer that is  
subject to tax as a domestic  
category or categories of filers (see  
Categories of Filers, earlier). However,  
in the case of a consolidated return,  
enter the name of the U.S. parent in  
the field for “Name of person filing  
Form 5471.”  
Reference ID number of foreign  
corporation. If applicable, use the  
reference ID number shown on Form  
5471, page 1, item 1b(2).  
Codes for Passive Groups  
corporation that is a U.S. shareholder  
(“corporate U.S. shareholder”) of a  
CFC is deemed to pay all or a portion  
of the foreign income taxes paid or  
accrued by the CFC that are properly  
attributable to subpart F income or  
tested income included in gross  
income by the corporate U.S.  
Code Passive Group  
i
All passive income received during  
the tax year that is subject to a  
withholding tax of 15% or greater  
must be treated as one item of  
income. See Regulations section  
1.904-4(c)(3)(i).  
ii  
All passive income received during  
the tax year that is subject to a  
withholding tax of less than 15% (but  
greater than zero) must be treated as  
one item of income. See Regulations  
section 1.904-4(c)(3)(ii).  
shareholder. See section 960(a) and  
(d). A corporate U.S. shareholder may  
claim a credit for such foreign taxes,  
subject to certain limitations.  
Line A. Complete a separate  
Schedule Q for each applicable  
separate category of income. Enter  
the appropriate code from the table  
below for the separate category of  
income with respect to which the  
Schedule Q is being completed.  
Note. If an individual, estate, or trust  
that is a U.S. shareholder of a CFC  
makes an election under section 962  
(“962 electing shareholder”), any  
inclusions under section 951 or 951A  
of the U.S. shareholder will be treated  
as received by a corporate U.S.  
iii All passive income received during  
the tax year that is subject to no  
withholding tax or other foreign tax  
must be treated as one item of  
income. See Regulations section  
1.904-4(c)(3)(iii).  
Codes for Categories of Income  
iv All passive income received during  
the tax year that is subject to no  
withholding tax but is subject to  
foreign tax other than a withholding  
tax must be treated as one item of  
income. See Regulations section  
1.904-4(c)(3)(iv).  
Code Category of Income  
PAS Passive category income  
901j Section 901(j) income  
GEN General category income  
shareholder for purposes of section  
960. See section 962(b) and  
Regulations section 1.962-2(b). As a  
result, these U.S. shareholders may  
also claim a foreign tax credit for  
foreign income taxes deemed paid  
with respect to such inclusions. See  
sections 962(a)(1) and 951A(f)(1)(A).  
If code 901j is entered on line A,  
enter on line 1m, column (i), the  
country code for the sanctioned  
country using the two-letter code  
(from the list at IRS.gov/  
Note. The grouping rules of  
Regulations section 1.904-4(c)(3)(i)  
through (iv) apply separately to  
income attributable to each tested unit  
of a CFC. See Regulations section  
1.904-4(c)(4). This is one reason that,  
in the case of a CFC,  
Note. See also section 1293(f) for  
inclusions with respect to a PFIC.  
To calculate the foreign taxes  
deemed paid by the corporate U.S.  
shareholder (including a 962 electing  
shareholder), determine for each of its  
CFCs the income, deductions, and  
taxes that are assigned to each  
separate category of income and  
each income group within each  
separate category. See Regulations  
section 1.960-1(c)(1). The income  
groups include the subpart F income  
groups, the tested income group, and  
the residual income group.  
Important. In addition to the  
separate category codes referred to  
above, if you have more than one of  
the categories of income referred to  
above, you must complete and file a  
separate Schedule Q using code  
“TOTALthat aggregates all amounts  
listed for each line and column in all  
other Schedules Q.  
tested-unit-by-tested-unit reporting is  
required with respect to the income  
groups on lines 1a through 1j and  
lines 3 and 4. A foreign corporation  
that is not a CFC but that is a  
noncontrolled 10%-owned foreign  
corporation must report this  
information on a  
Line B. If category code “PAS” is  
entered on line A, a separate  
foreign-QBU-by-foreign-QBU basis.  
This would be the case, for example, if  
you are completing Schedule Q for  
purposes of attaching it to Schedules  
K-2 and K-3 for purposes of section  
1293(f).  
Schedule Q must be completed for  
each applicable grouping under  
Regulations section 1.904-4(c)(3).  
See Regulations sections 1.954-1(c)  
(1)(iii)(B) and 1.904-4(c)(3) through  
(5). Enter on line B the appropriate  
code from the table below for each of  
the following groups under  
Computer-Generated  
Schedule Q  
Expand the Schedule Q if you are  
reporting with respect to more than  
two units. Specifically, if you are  
reporting with respect to more than  
two units, add to pages 1 to 4, as  
appropriate, new lines (3), (4), (5),  
etc., in all necessary locations.  
To figure the amounts to enter on  
lines 1a through 1j, on lines (1), (2),  
etc., under each line 1a through 1j,  
enter the name of each unit of the  
foreign corporation (the relevant unit  
being each tested unit in the case of a  
CFC and each QBU in the case of a  
10%-owned foreign corporation),  
including the foreign corporation itself,  
and the information required in each  
column (i) through (xvi) with respect to  
the amount in each subpart F income  
group within each category for each  
unit.  
Regulations section 1.904-4(c)(3).  
Specific Instructions for  
Schedule Q  
Name of person filing Form 5471.  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the applicable  
Instructions for Form 5471 (Rev. 01-2024)  
45  
On lines (1), (2), etc., under line 4,  
enter the name of each unit and enter  
the information required for columns  
(i) through (xvi) for each unit, but do  
not enter amounts excluded from  
income described in each of  
QBU. On lines 1a through 1j, enter the  
total for each column by adding the  
Regulations section 1.954-1(c)(1)(iii)  
(A)(2)(i) through (v). For example, with amounts on lines (1), (2), etc.,  
respect to line 1g, there is a single  
subpart F income group within the  
excluding from such total any amounts  
reported with respect to income  
subpart F income under the subpart F general category that consists of all of excluded from subpart F income  
high-tax exception (those amounts are a CFC’s foreign base company sales  
under the high-tax exception in  
reported on lines (1), (2), etc., under  
lines 1a through 1j) or tested income  
under the GILTI high-tax exclusion  
(those amounts are reported on lines  
(1), (2), etc., under line 3).  
income.  
Use lines 1a through 1f to enter the  
section 954(b)(4) (“subpart F high-tax  
exception”). These amounts are  
included in the total amount of  
passive category foreign personal  
holding company income of the CFC  
under the appropriate income group  
(dividends, interest, rents, royalties,  
and annuities; net gain from certain  
property transactions; net gain from  
commodities transactions; net foreign  
currency gain; income equivalent to  
interest; and other passive category  
foreign personal holding company  
income of the CFC), each of which is  
also treated as a separate subpart F  
income group under Regulations  
section 1.960-1. See Regulations  
section 1.954-1(c)(1)(iii)(B).  
residual income, which is reported on  
line 4. As a result, the amounts  
included on lines 1a through 1j for  
each column may not equal the sum  
of the amounts reported on lines (1),  
(2), etc., for each column because any  
item excluded from subpart F income  
by reason of the high-tax election is  
included in the summation on line 4  
instead of the summations on lines 1a  
through 1j. See the instructions for  
column (xiv) and line 4.  
Line C. If code 901j is entered on line  
A, enter the country code for the  
sanctioned country using the  
two-letter code from the list at  
Line D. Taxpayers are generally  
required to complete a separate  
Schedule Q for foreign source income  
in each separate category and U.S.  
source income in each separate  
category. On a given Schedule Q,  
taxpayers are generally required to  
check the box for either foreign source  
income or U.S. source income, as  
applicable. However, if a taxpayer has  
entered code “TOTALon line A and  
the total reported on that Schedule Q  
includes both foreign source income  
and U.S. source income, the taxpayer  
may check both boxes on line D.  
Line E. A separate Schedule Q is  
required for foreign oil and gas  
extraction income (FOGEI) and  
foreign oil related income (FORI). If  
the Schedule Q is being prepared to  
report the FOGEI or FORI of a CFC,  
check the box for line E. Indicate the  
amount of FOGEI and FORI in each  
income group.  
Example. For line 1a(1), gross  
income of $50 is reported in column  
(ii), foreign tax of $20 is reported in  
each of columns (x) and (xii), and the  
checkbox in column (xiv) is checked.  
For line 1a(2), gross income of $100 is  
reported in column (ii), $5 of foreign  
tax is reported in each of columns (x)  
and (xii), and the checkbox in column  
(xiv) is not checked. For line 1a(3),  
gross income of $75 is reported in  
column (ii), $3 of foreign tax is  
Note. Enter the following passive  
category foreign personal holding  
company income of the CFC on line 1f  
(other foreign personal holding  
company income).  
Income from notional principal  
contracts.  
Payments in lieu of dividends.  
Personal service contracts.  
reported in each of columns (x) and  
(xii), and the checkbox in column (xiv)  
is not checked. As a result, the  
See section 954(c)(1)(F) through (H).  
Attach a statement that includes all  
of the information requested by  
Schedule Q, line 1f, delineating the  
amount on line 1f for each of the three  
groups reporting on line 1f. For  
example, if both payments in lieu of  
dividends and income from notional  
principal contracts are included on  
line 1f, on the statement, identify the  
amount related to each of those  
income groups for each column of  
line 1f.  
amount reported in column (ii) on  
line 1a is the sum of the amounts  
reported in column (ii) on lines 1a(2)  
and 1a(3), which is equal to $175  
($100 + $75). The amounts reported  
in columns (x) and (xii) on line 1a are  
the sum of the amounts reported in  
each column on lines 1a(2) and 1a(3),  
which is equal to $8 ($5 + $3). The  
items reported on line 1a(1), gross  
income of $50 and $20 of foreign tax,  
are not included in the totals reported  
on line 1a. These amounts are  
Line 1. Subpart F Income  
Groups  
The separate subpart F income  
groups within each applicable section  
904 category of a CFC are on line 1  
(“subpart F income groups”). See  
Regulations section 1.960-1(d)(2)(ii)  
(B). Each single item of foreign base  
company income (as defined in  
Use lines 1g through 1j to enter the  
foreign base company sales income,  
foreign base company services  
income, full inclusion income, and  
insurance income described in  
section 952(a)(1) of the CFC.  
included in the totals for each  
respective column on line 4. As a  
result, the amount reported on line 4,  
column (ii), is increased by $50 and  
the amount reported in column (x) on  
line 4 is increased by $20. No amount  
is reported on line 4, column (xii),  
because foreign income taxes  
Regulations section 1.954-1(c)(1)(iii))  
is a separate subpart F income group.  
With respect to a CFC, Regulations  
section 1.954-1(c)(1)(iii)(A)(2)  
To figure the amounts to enter on  
lines 1a through 1j, on lines (1), (2),  
etc., under each line 1a through 1j,  
enter the name of each QBU of the  
CFC, including the CFC itself, and the  
information required in each column  
(i) through (xvi) with respect to the  
amount in each subpart F income  
group within each category for each  
identifies as a single item of income all  
foreign base company income (other  
than foreign personal holding  
attributable to high-tax exception or  
high-tax exclusion income are not  
creditable.  
company income) that falls within both  
a single separate category (typically,  
general category income) and a single  
category of foreign base company  
On lines 1k through 1m, enter  
international boycott income  
Instructions for Form 5471 (Rev. 01-2024)  
46  
described in section 952(a)(3); illegal  
bribes, kickbacks, and other  
amount should be reported in column  
(xii) of line 4 as foreign tax on residual  
amounts are not creditable. The  
amounts reported on line 1a(1) would  
not be included in the total for line 1a,  
but the amount reported on line 1a(2)  
would be included in the total reported  
on line 1a. Similarly, the amounts  
reported on line 3(1) would not be  
included in the total reported on line 3,  
but the amounts reported on line 3(2)  
would be reported in the total reported  
on line 3.  
Column (i). Consistent with the  
reporting requirement on Form 1118,  
enter the two-letter code (from the list  
at IRS.gov/CountryCodes) of each  
foreign country and U.S. territory  
within which income is sourced and/or  
to which taxes were paid or accrued.  
Line 4. Residual Income Group  
Use line 4 to report the information  
required in columns (i) through (xvi)  
that is in a section 904 category but  
that is not of a type that is included in  
one of the subpart F income groups or  
a tested income group and is  
payments described in section 952(a)  
(4); and income included in a section  
901(j) separate category described in  
section 952(a)(5). See Regulations  
section 1.960-1(d)(2)(ii)(B)(2).  
therefore assigned to the residual  
income group. See Regulations  
section 1.960-1(d)(2)(ii)(D). Enter the  
name of each QBU and enter the  
information required for columns (i)  
through (xvi) for each QBU on lines  
4(1), 4(2), etc., but do not enter  
amounts excluded from subpart F  
income under the subpart F high-tax  
exception (those amounts are  
Line 2. Recaptured Subpart F  
Income  
Enter income that is recaptured as  
subpart F income in the current year.  
See section 952(c)(2).  
Line 3. Tested Income Group  
Use line 3 to report tested income in  
the tested income group of the CFC (a  
“tested income group”). See  
reported on lines (1), (2), etc., under  
lines 1a through 1j) or tested income  
under the GILTI high-tax exclusion  
(those amounts are reported on lines  
3(1), 3(2), etc.,). Enter the sum of the  
amounts reported on lines 4(1), 4(2),  
etc., plus the sum of amounts  
Regulations section 1.960-1(d)(2)(ii)  
(C). On lines (1), (2), etc., under  
line 3, enter the name of each tested  
unit of the CFC (including the CFC  
tested unit itself) and enter for each  
tested unit the information required in  
columns (ii) through (xvi), based on  
the tentative gross tested income  
attributable to each tested unit  
Column (ii). Enter the amount of  
gross income of the CFC that is  
assigned to each income group within  
each section 904 category.  
Columns (iii) through (vii). Expen-  
ses. Deductions of the CFC,  
excluded from subpart F income  
under the subpart F high-tax  
exception and tested income under  
the GILTI high-tax exclusion, in the  
appropriate column on line 4.  
(without regard to any amounts  
including for current year taxes, are  
allocated and apportioned to the  
income groups to determine net  
income (or loss) in each income group  
and to identify the current year foreign  
income taxes that relate to the income  
in each income group for section 960  
purposes. See Regulations section  
1.960-1(c)(1) and 1.960-1(d)(3)(ii).  
Enter the expenses allocated and  
apportioned to the item of gross  
income reported for each QBU or  
tested unit as well as the aggregate  
amount of such expenses allocated  
and apportioned to each group. See  
the instructions for lines 1 through 4.  
excluded under the GILTI high-tax  
exclusion in Regulations section  
1.951A-2(c)(7) (“GILTI high-tax  
Example. For line 1a(1), $100 of  
gross income is reported in column  
(ii), $35 of foreign tax is reported in  
each of columns (x) and (xii), and the  
checkbox in column (xiv) is checked.  
For line 1a(2), $75 of gross income is  
reported in column (ii), $5 of foreign  
tax is reported in each of columns (x)  
and (xii), and the checkbox in column  
(xiv) is not checked. For line 3(1),  
$200 of gross income is reported in  
column (ii), $70 of foreign tax is  
exclusion”)). If the GILTI high-tax  
exclusion applies with respect to any  
tested unit of the CFC, include the  
amounts reported for columns (ii)  
through (xiii) and (xvi) in the total  
reported on line 4. See the  
instructions for line 4. As a result, the  
total amount entered on line 3 may not  
equal the sum of the amounts  
reported in columns (ii) through (xiii)  
and (xvi) on lines 3(1), 3(2), etc., if any  
tested unit’s tentative tested income is  
excluded under the GILTI high-tax  
exclusion (these amounts are  
reported in each of columns (x) and  
(xii), and the checkbox in column (xiv)  
is checked. For line 3(2), $150 of  
gross income is reported in column  
(ii), $10 of foreign tax is reported in  
each of columns (x) and (xii), and the  
checkbox in column (xiv) is not  
Column (viii). Current year tax on  
reattributed income from disregar-  
ded payments. This column is used  
to report current year tax imposed  
solely by reason of the receipt of a  
disregarded payment that is a  
included in the total amounts reported  
on line 4). In general, tested income  
will be in a single tested income group  
within the general category. Because  
a CFC cannot earn section 951A  
category income or foreign branch  
category income at the CFC level,  
there is no tested income group within  
either section 904 category. With  
respect to the general category tested  
income group of a CFC, GILTI  
checked. For line 4(1), $300 of gross  
income is reported in column (ii) and  
$105 of foreign tax is reported in  
column (x). On line 4(1), both columns  
(xii) and (xiv) should be blank in all  
cases. As a result, the amount  
reattribution payment. The current  
year tax is allocated and apportioned  
to the income group to which an  
amount of gross income is assigned  
by reason of the receipt of the  
reported on line 4 for column (ii) is the  
sum of the amounts reported in  
reattribution payment. See  
inclusion amounts and taxes with  
respect to the tested income group  
will generally be treated as income  
and deemed paid taxes in the section  
951A category. See Regulations  
sections 1.904-4(g) and 1.904-6(e).  
Regulations sections 1.960-1(d)(3)(ii)  
(A) and 1.861-20(d)(3)(v)(B). Report  
current year taxes allocated and  
apportioned to the item of gross  
income reported for each QBU or  
tested unit as well as the aggregate  
amount of such foreign taxes in each  
column (ii) on lines 1a(1), 3(1), and  
4(1), which equals $600 ($100 + $200  
+ $300). The amount reported in  
column (x) of line 4 is the sum of the  
amounts reported in column (x) on  
lines 1a(1), 3(1), and 4(1), which  
equals $210 ($35 + $70 + $105). No  
Instructions for Form 5471 (Rev. 01-2024)  
47  
group. See the instructions for lines 1  
through 4.  
Column (ix). Current year tax on all Column (xiii). Average asset value.  
and (l); and taxes paid or accrued to  
the United States.  
corporation's subpart F income  
exceeds current year E&P. See  
Regulations sections 1.952-1(c) and  
(e) and 1.951A-6.  
other disregarded payments. This  
column is used to report current tax  
imposed solely by reason of the  
receipt of a disregarded payment  
other than a reattribution payment,  
and which is therefore either a  
Foreign gross income that arises from  
a disregarded payment that is treated  
as a remittance for U.S. tax purposes  
is assigned to an income group by  
reference to the income groups to  
which the assets of the payor taxable  
unit are assigned (or would be  
Schedule R  
Schedule R is used to report basic  
information pertaining to distributions  
from foreign corporations. This  
information is required by sections  
245A, 959, and 986(c).  
remittance or a contribution. See  
Regulations section 1.861-20(d)(3)(v)  
(C). Foreign tax imposed by reason of  
a disregarded payment that is a  
remittance is assigned to the income  
groups based upon the assets of the  
payor. See Regulations section  
assigned if the taxable unit were a  
U.S. person) under the rules of  
Name of Person Filing Form  
5471  
Regulations section 1.861-9 for  
purposes of apportioning interest  
expense. This rule uses the payor’s  
asset apportionment percentages as  
a proxy for the accumulated earnings  
of the payor taxable unit from which  
the remittance is made. For this  
The name of the person filing Form  
5471 is generally the name of the U.S.  
person described in the category or  
categories of filers (see Categories of  
Filers, earlier). However, in the case of  
a consolidated return, enter the name  
of the U.S. parent in the field for  
1.861-20(d)(3)(v)(C)(1). Foreign tax  
imposed by reason of a disregarded  
payment that is a contribution is  
assigned to the residual grouping.  
See Regulations section 1.861-20(d)  
purpose, the assets of the taxable unit  
making the remittance are determined  
(3)(v)(C)(2). Report current year taxes in accordance with the rules of  
“Name of person filing Form 5471.”  
allocated and apportioned to the item  
of gross income reported for each  
QBU or tested unit as well as the  
aggregate amount of such foreign  
taxes allocated and apportioned to  
each group. See the instructions for  
lines 1 through 4.  
Regulations section 1.987-6(b) that  
apply in determining the source and  
separate category of exchange gain  
or loss on a section 987 remittance,  
as modified in two respects. See  
Regulations section 1.861-20(d)(3)(v)  
(C)(1). Report asset values for each  
QBU or tested unit as well as the  
aggregate amount of assets in each  
group. See the instructions for lines 1  
through 4.  
Reference ID Number of  
Foreign Corporation  
If applicable, use the reference ID  
number shown on Form 5471, page 1,  
item 1b(2).  
Column (a). Description of distri-  
bution. The description should  
include whether the distribution was  
cash or noncash and taxable or  
nontaxable to shareholders. Use code  
sections to properly identify the  
taxable or nontaxable consequences  
of the distribution. For example,  
“taxable cash dividend eligible for a  
dividends received deduction under  
section 245A” or “nontaxable cash  
distribution of PTEP.” Report parts of a  
distribution on separate rows if the  
distribution is partially taxable and  
partially nontaxable, or if the  
Column (x). Other current year tax-  
es. Any other current year tax is  
allocated and apportioned among the  
section 904 categories under the rules  
of Regulations section 1.904-6(a)  
based on the portion of the foreign  
taxable income (as characterized  
under federal income tax principles)  
Column (xiv). High-tax election.  
Check the box in column (xiv) of the  
line corresponding to any item of  
income with respect to which the  
that is assigned to a particular section subpart F high-tax exception applies.  
904 category. Any other current year  
foreign tax is allocated to the CFC  
income group to which the items of  
foreign gross income are assigned  
If any amount is excluded under the  
subpart F high-tax exception, do not  
include it in the total for lines 1a  
through 1j, but instead add the  
under the rules of Regulations section amount to the total for line 4. See the  
1.861-20. Report current year taxes  
allocated and apportioned to the item  
of gross income reported for each  
QBU or tested unit as well as the  
aggregate amount of such foreign  
taxes allocated and apportioned to  
each group. See the instructions for  
lines 1 through 4.  
instructions for lines 1 and 4. If a GILTI  
high-tax exclusion under Regulations  
section 1.951A-2(c)(7)(viii) is effective  
with respect to the CFC for the CFC  
inclusion year, check the box in  
column (xiv) that corresponds to the  
item(s) of income to which the  
distribution is either taxable or  
nontaxable by reason of different  
Code sections. For example, a cash  
distribution of $100 that is a  
nontaxable distribution of PTEP under  
section 959(a) of $30, a taxable  
dividend eligible for a dividends  
received deduction under section  
245A of $15, a taxable dividend under  
section 301(c)(1) of $25, a nontaxable  
distribution applied against basis  
under section 301(c)(2) of $10, and a  
taxable distribution treated as gain  
from the sale or exchange of property  
under section 301(c)(3) of $20 would  
be reported on five rows.  
exception applies. If an amount  
reported on line 3(1), 3(2), etc., is  
excluded from gross income under the  
GILTI high-tax exclusion, do not  
include it in the total amount for line 3.  
Instead, include the amounts in the  
total for line 4. See the instructions for  
lines 3 and 4.  
Column (xv). Loss allocation. This  
column is used to report a reduction to  
subpart F income in each applicable  
income group when the foreign  
Column (xii). Foreign taxes for  
which credit is allowed (U.S. dol-  
lars). The amount reported in column  
(xii) may not be the same as the sum  
of the amounts in columns (viii)  
through (x) if columns (viii) through (x)  
include taxes that are not creditable,  
including taxes paid or accrued to  
sanctioned countries; foreign taxes  
disallowed under section 901(k), (m),  
If noncash distributions were made,  
attach a statement and show both the  
tax bases and FMVs.  
Instructions for Form 5471 (Rev. 01-2024)  
48  
 
generally treated as a distribution of  
E&P. Report distributions from current  
and accumulated E&P. Do not report  
any part of a distribution that is not  
from E&P in column (d).  
An actual distribution is first out of  
PTEP, if any, and then out of the  
section 959(c)(3) balance. See  
section 959(c).  
on the comparable line of other  
noncorporate tax returns.  
Column (b). Date of distribution.  
Enter the month, day, and year using  
the following format: MM-DD-YYYY.  
For example, June 30, 2023, would be  
entered as “06-30-2023.”  
Column (c). Amount of distribution  
in foreign corporation's functional  
currency. The amount of a  
Note. E&P described in section  
959(c)(3) is generally E&P of the  
foreign corporation that has not been  
included in gross income of a U.S.  
shareholder under section 951(a)(1)  
or section 951A.  
distribution is generally the amount of  
any money paid to the shareholder  
plus the FMV of any property  
transferred to the shareholder.  
However, this amount is reduced (but  
not below zero) by the following  
liabilities.  
If PTEP were distributed, include  
on Form 5471, Schedule I, line 6, any  
foreign currency gain or loss on the  
distribution that is recognized under  
section 986(c). See the instructions  
for Schedule I, Line 6, earlier, for  
details. With respect to foreign  
Note. Amounts entered in  
Schedule R (Form 5471), column (d),  
are also included on line 9, column (f),  
of Schedule J (Form 5471) and Part I,  
line 8, of Schedule P (Form 5471),  
both of which are completed by  
separate category of income. If the  
filer is required to complete  
Any liability of the corporation the  
currency gain or loss on a distribution  
of PTEP, for a corporate U.S.  
shareholder assumes in connection  
with the distribution.  
Schedule J (Form 5471) with respect  
to more than one category of income,  
the total of all amounts entered in  
Schedule R (Form 5471), column (d),  
should equal the amount entered on  
line 9, column (f), of the Schedule J  
(Form 5471) that is filed with code  
“TOTALentered on line a of that  
Schedule J.  
shareholder, include the gain or (loss)  
as “Other income” on Form 1120,  
line 10, or on the comparable line of  
other corporate tax returns. For a  
noncorporate U.S. shareholder,  
include the result as “Other income”  
on Schedule 1 (Form 1040), line 8z, or  
Any liability to which the property is  
subject immediately before, and  
immediately after, the distribution.  
Column (d). Amount of E&P distri-  
bution in foreign corporation's  
functional currency. A corporate  
distribution to a shareholder is  
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retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax  
returns and return information are confidential, as required by section 6103.  
The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden  
for individual and business taxpayers filing this form is approved under OMB control number 1545-0074 and 1545-0123  
and is included in the estimates shown in the instructions for their individual and business income tax return.  
Instructions for Form 5471 (Rev. 01-2024)  
49  
Using the list of activities and codes below,  
determine from which activity the company derives  
the largest percentage of its “total receipts.If the  
company purchases raw materials and supplies  
them to a subcontractor to produce the finished  
product, but retains title to the product, the  
use one of the manufacturing codes  
(311110-339900).  
Enter on page 1, Item 1f, the six-digit code  
selected from the list below. In item 1g, enter a  
brief description of the company's business  
activity.  
Principal Business Activity Codes  
This list of principal business activities and their  
associated codes is designed to classify an  
enterprise by the type of activity in which it is  
engaged to facilitate the administration of the  
Internal Revenue Code. These principal business  
activity codes are based on the North American  
Industry Classification System.  
company is considered a manufacturer and must  
237990 Other Heavy & Civil  
Printing and Related Support  
333510 Metalworking Machinery Mfg  
333610 Engine, Turbine & Power  
Agriculture, Forestry, Fishing,  
and Hunting  
Engineering Construction  
Activities  
Specialty Trade Contractors  
323100 Printing & Related Support  
Transmission Equipment Mfg  
Crop Production  
Activities  
238100 Foundation, Structure, &  
Building Exterior Contractors  
(including framing carpentry,  
masonry, glass, roofing, &  
siding)  
333900 Other General Purpose  
111100 Oilseed & Grain Farming  
Petroleum and Coal Products  
Manufacturing  
Machinery Mfg  
111210 Vegetable & Melon Farming  
Computer and Electronic Product  
Manufacturing  
(including potatoes & yams)  
324110 Petroleum Refineries  
(including integrated)  
111300 Fruit & Tree Nut Farming  
334110 Computer & Peripheral  
238210 Electrical Contractors  
324120 Asphalt Paving, Roofing, &  
Saturated Materials Mfg  
Equipment Mfg  
111400 Greenhouse, Nursery, &  
238220 Plumbing, Heating, &  
Floriculture Production  
334200 Communications Equipment  
Mfg  
Air-Conditioning Contractors  
324190 Other Petroleum & Coal  
111900 Other Crop Farming  
(including tobacco, cotton,  
sugarcane, hay, peanut,  
sugar beet & all other crop  
farming)  
238290 Other Building Equipment  
Contractors  
Products Mfg  
334310 Audio & Video Equipment  
Chemical Manufacturing  
Mfg  
238300 Building Finishing  
Contractors (including  
drywall, insulation, painting,  
wallcovering, flooring, tile, &  
finish carpentry)  
325100 Basic Chemical Mfg  
334410 Semiconductor & Other  
Electronic Component Mfg  
325200 Resin, Synthetic Rubber, &  
Artificial & Synthetic Fibers &  
Filaments Mfg  
Animal Production  
334500 Navigational, Measuring,  
Electromedical, & Control  
Instruments Mfg  
112111 Beef Cattle Ranching &  
Farming  
325300 Pesticide, Fertilizer, & Other  
238900 Other Specialty Trade  
Contractors (including site  
preparation)  
112112 Cattle Feedlots  
Agricultural Chemical Mfg  
334610 Manufacturing & Reproducing  
Magnetic & Optical Media  
112120 Dairy Cattle & Milk Production  
112210 Hog & Pig Farming  
325410 Pharmaceutical & Medicine  
Mfg  
Electrical Equipment, Appliance,  
and Component Manufacturing  
Manufacturing  
Food Manufacturing  
325500 Paint, Coating, & Adhesive  
112300 Poultry & Egg Production  
112400 Sheep & Goat Farming  
Mfg  
335100 Electric Lighting Equipment  
Mfg  
311110 Animal Food Mfg  
311200 Grain & Oilseed Milling  
325600 Soap, Cleaning Compound, &  
Toilet Preparation Mfg  
112510 Aquaculture (including  
shellfish & finfish farms &  
hatcheries)  
335200 Household Appliance Mfg  
335310 Electrical Equipment Mfg  
325900 Other Chemical Product &  
311300 Sugar & Confectionery  
Preparation Mfg  
Product Mfg  
335900 Other Electrical Equipment &  
112900 Other Animal Production  
Forestry and Logging  
Plastics and Rubber Products  
Manufacturing  
Component Mfg  
311400 Fruit & Vegetable Preserving  
& Specialty Food Mfg  
Transportation Equipment  
Manufacturing  
113110 Timber Tract Operations  
326100 Plastics Product Mfg  
326200 Rubber Product Mfg  
311500 Dairy Product Mfg  
113210 Forest Nurseries & Gathering  
336100 Motor Vehicle Mfg  
311610 Animal Slaughtering and  
of Forest Products  
Processing  
Nonmetallic Mineral Product  
336210 Motor Vehicle Body & Trailer  
113310 Logging  
Manufacturing  
Mfg  
311710 Seafood Product Preparation  
& Packaging  
Fishing, Hunting, and Trapping  
114110 Fishing  
327100 Clay Product & Refractory  
Mfg  
336300 Motor Vehicle Parts Mfg  
311800 Bakeries, Tortilla & Dry Pasta  
336410 Aerospace Product & Parts  
114210 Hunting & Trapping  
Mfg  
327210 Glass & Glass Product Mfg  
Mfg  
Support Activities for Agriculture  
311900 Other Food Mfg (including  
coffee, tea, flavorings, &  
seasonings)  
327300 Cement & Concrete Product  
336510 Railroad Rolling Stock Mfg  
336610 Ship & Boat Building  
and Forestry  
Mfg  
115110 Support Activities for Crop  
Production (including cotton  
ginning, soil preparation,  
327400 Lime & Gypsum Product Mfg  
336990 Other Transportation  
Beverage and Tobacco Product  
327900 Other Nonmetallic Mineral  
Equipment Mfg  
Manufacturing  
Product Mfg  
Furniture and Related Product  
Manufacturing  
planting, & cultivating)  
312110 Soft Drink & Ice Mfg  
312120 Breweries  
Primary Metal Manufacturing  
115210 Support Activities for Animal  
331110 Iron & Steel Mills & Ferroalloy 337000 Furniture & Related Product  
Production (including farriers)  
312130 Wineries  
Mfg  
Manufacturing  
115310 Support Activities For  
Forestry  
312140 Distilleries  
331200 Steel Product Mfg from  
Miscellaneous Manufacturing  
Purchased Steel  
312200 Tobacco Manufacturing  
339110 Medical Equipment &  
Mining  
331310 Alumina & Aluminum  
Production & Processing  
Supplies Mfg  
Textile Mills and Textile Product  
211120 Crude Petroleum Extraction  
211130 Natural Gas Extraction  
212110 Coal Mining  
Mills  
339900 Other Miscellaneous  
Manufacturing  
331400 Nonferrous Metal (except  
Aluminum) Production &  
Processing  
313000 Textile Mills  
314000 Textile Product Mills  
Apparel Manufacturing  
315100 Apparel Knitting Mills  
Wholesale Trade  
212200 Metal Ore Mining  
212310 Stone Mining & Quarrying  
Merchant Wholesalers, Durable  
331500 Foundries  
Goods  
Fabricated Metal Product  
212320 Sand, Gravel, Clay, &  
315210 Cut & Sew Apparel  
423100 Motor Vehicle & Motor Vehicle  
Parts & Supplies  
Manufacturing  
Ceramic & Refractory  
Contractors  
332110 Forging & Stamping  
Minerals Mining & Quarrying  
315250 Cut & Sew Apparel Mfg  
(except Contractors)  
423200 Furniture & Home Furnishings  
332210 Cutlery & Handtool Mfg  
212390 Other Nonmetallic Mineral  
423300 Lumber & Other Construction  
Mining & Quarrying  
332300 Architectural & Structural  
315990 Apparel Accessories & Other  
Materials  
Metals Mfg  
213110 Support Activities for Mining  
Apparel Mfg  
423400 Professional & Commercial  
Equipment & Supplies  
332400 Boiler, Tank, & Shipping  
Container Mfg  
Utilities  
Leather and Allied Product  
Manufacturing  
423500 Metal & Mineral (except  
221100 Electric Power Generation,  
332510 Hardware Mfg  
316110 Leather & Hide Tanning &  
Petroleum)  
Transmission & Distribution  
332610 Spring & Wire Product Mfg  
Finishing  
423600 Household Appliances &  
Electrical & Electronic Goods  
221210 Natural Gas Distribution  
332700 Machine Shops; Turned  
Product; & Screw, Nut, & Bolt  
Mfg  
316210 Footwear Mfg (including  
rubber & plastics)  
221300 Water, Sewage & Other  
423700 Hardware & Plumbing &  
Heating Equipment &  
Supplies  
Systems  
316990 Other Leather & Allied  
221500 Combination Gas & Electric  
Construction  
332810 Coating, Engraving, Heat  
Product Mfg  
Treating, & Allied Activities  
Wood Product Manufacturing  
423800 Machinery, Equipment, &  
332900 Other Fabricated Metal  
Product Mfg  
Supplies  
Construction of Buildings  
321110 Sawmills & Wood  
Preservation  
423910 Sporting & Recreational  
Goods & Supplies  
236110 Residential Building  
Machinery Manufacturing  
Construction  
321210 Veneer, Plywood, &  
Engineered Wood Product  
Mfg  
333100 Agriculture, Construction, &  
423920 Toy & Hobby Goods &  
236200 Nonresidential Building  
Construction  
Mining Machinery Mfg  
Supplies  
333200 Industrial Machinery Mfg  
321900 Other Wood Product Mfg  
423930 Recyclable Materials  
Heavy and Civil Engineering  
Construction  
333310 Commercial & Service  
Paper Manufacturing  
423940 Jewelry, Watch, Precious  
Industry Machinery Mfg  
Stone, & Precious Metals  
237100 Utility System Construction  
237210 Land Subdivision  
322100 Pulp, Paper, & Paperboard  
333410 Ventilation, Heating,  
Air-Conditioning, &  
Mills  
423990 Other Miscellaneous Durable  
Goods  
322200 Converted Paper Product Mfg  
237310 Highway, Street, & Bridge  
Commercial Refrigeration  
Equipment Mfg  
Construction  
50  
 
Principal Business Activity Codes (Continued)  
Merchant Wholesalers, Nondurable Gasoline Stations & Fuel Dealers  
488210 Support Activities for Rail  
Transportation  
Securities, Commodity Contracts,  
and Other Financial Investments  
and Related Activities  
Goods  
457100 Gasoline Stations (including  
424100 Paper & Paper Products  
424210 Drugs & Druggists' Sundries  
convenience stores with gas)  
488300 Support Activities for Water  
Transportation  
523150 Investment Banking &  
457210 Fuel Dealers (including  
Heating Oil & Liquefied  
Petroleum)  
Securities Intermediation  
488410 Motor Vehicle Towing  
424300 Apparel, Piece Goods, &  
523160 Commodity Contracts  
Intermediation  
Notions  
488490 Other Support Activities for  
Clothing and Accessories Retailers  
Road Transportation  
424400 Grocery & Related Products  
424500 Farm Product Raw Materials  
424600 Chemical & Allied Products  
523210 Securities & Commodity  
458110 Clothing & Clothing  
488510 Freight Transportation  
Arrangement  
Exchanges  
Accessories Retailers  
523900 Other Financial Investment  
Activities (including portfolio  
management & investment  
advice)  
458210 Shoe Retailers  
488990 Other Support Activities for  
424700 Petroleum & Petroleum  
Transportation  
458310 Jewelry Retaileres  
Products  
Couriers and Messengers  
458320 Luggage & Leather Goods  
424800 Beer, Wine, & Distilled  
Alcoholic Beverages  
Retailers  
492110 Couriers & Express Delivery  
Insurance Carriers and Related  
Services  
Sporting, Hobby, Book, Musical  
Instrument & Miscellaneous  
Retailers  
Activities  
424910 Farm Supplies  
492210 Local Messengers & Local  
Delivery  
524110 Direct Life, Health, & Medical  
Insurance Carriers  
424920 Book, Periodical, &  
Newspapers  
459110 Sporting Goods Retailers  
Warehousing and Storage  
524120 Direct Insurance (except Life,  
424930 Flower, Nursery Stock, &  
Florists' Supplies  
459120 Hobby, Toy, & Game Retailers 493100 Warehousing & Storage  
Health & Medical) Carriers  
(except lessors of  
mini-warehouses &  
self-storage units)  
459130 Sewing, Needlework, & Piece  
524210 Insurance Agencies &  
Brokerages  
424940 Tobacco Products &  
Goods Retailers  
Electronic Cigarettes  
459140 Musical Instrument &  
Supplies Retailers  
524290 Other Insurance Related  
424950 Paint, Varnish, & Supplies  
Information  
Activities (including  
424990 Other Miscellaneous  
third-party administration of  
insurance and pension funds)  
459210 Book Retailers & News  
Motion Picture and Sound  
Nondurable Goods  
Dealers (including  
Recording Industries  
Wholesale Trade Agents and  
Brokers  
newsstands)  
Funds, Trusts, and Other Financial  
512100 Motion Picture & Video  
Industries (except video  
rental)  
Vehicles  
459310 Florists  
425120 Wholesale Trade Agents &  
525100 Insurance & Employee  
Benefit Funds  
459410 Office Supplies & Stationery  
Brokers  
Retailers  
512200 Sound Recording Industries  
Publishing Industries  
Retail Trade  
525910 Open-End Investment Funds  
(Form 1120-RIC, U.S. Income  
Tax Return for Regulated  
459420 Gift, Novelty, & Souvenir  
Retailers  
Motor Vehicle and Parts Dealers  
441110 New Car Dealers  
441120 Used Car Dealers  
441210 Recreational Vehicle Dealers  
441222 Boat Dealers  
513110 Newspaper Publishers  
513120 Periodical Publishers  
513130 Book Publishers  
459510 Used Merchandise Retailers  
459910 Pet & Pet Supplies Retailers  
459920 Art Dealers  
Investment Companies)  
525920 Trusts, Estates, & Agency  
Accounts  
513140 Directory & Mailing List  
459930 Manufactured (Mobile) Home  
Publishers  
525990 Other Financial Vehicles  
(including mortgage REITs  
and closed-end investment  
funds)“Offices of Bank  
Dealers  
441227 Motorcycle, ATV, & All other  
513190 Other Publishers  
Motor Vehicle Dealers  
459990 All Other Miscellaneous  
Retailers (including tobacco,  
candle, & trophy retailers)  
513210 Software Publishers  
441300 Automotive Parts,  
Accessories, & Tire Retailers  
Broadcasting & Content Providers  
Holding Companies” and  
“Offices of Other Holding  
Companies” are located  
under Management of  
Companies (Holding  
& Telecommunications  
Nonstore Retailers  
Building Material and Garden  
516100 Radio & Television  
Broadcasting Stations  
Equipment and Supplies Dealers  
various Nonstore retailers sell all  
types of merchandise using  
such methods as Internet,  
mail-order catalogs,  
444110 Home Centers  
516210 Media Streaming, Social  
Networks, & Other Content  
Providers  
Companies) below.  
444120 Paint & Wallpaper Retailers  
444140 Hardware Retailers  
interactive television, or direct  
sales. These types of  
Real Estate and Rental and  
517000 Telecommunications  
(including Wired, Wireless,  
Satellite, Cable & Other  
Program Distribution,  
444180 Other Building Material  
Leasing  
Retailers should select the  
PBA associated with their  
primary line of products sold.  
For example, establishments  
primarily selling prescription  
and non-prescription drugs,  
select PBA code 456110  
Pharmacies & Drug Retailers.  
Dealers  
Real Estate  
444200 Lawn & Garden Equipment &  
Supplies Retailers  
531110 Lessors of Residential  
Resellers, Agents & Other  
Telecommunications, &  
Internet Service Providers)  
Buildings & Dwellings  
Food and Beverage Retailers  
(including equity REITs)  
445110 Supermarkets and Other  
Grocery Retailers (except  
Convenience)  
531120 Lessors of Nonresidential  
Data Processing, Web Search  
Portals, & Other Information  
Services  
Buildings (except  
Mini-warehouses) (including  
equity REITs)  
445131 Convenience Retailers  
445132 Vending Machine Operators  
445230 Fruit & Vegetable Retailers  
445240 Meat Retailers  
Transportation and  
518210 Computing Infrastructure  
Providers, Data Processing,  
Web Hosting & Related  
Services  
531130 Lessors of Mini-warehouses  
Warehousing  
& Self-Storage Units  
Air, Rail, and Water Transportation  
481000 Air Transportation  
482110 Rail Transportation  
483000 Water Transportation  
Truck Transportation  
(including equity REITs)  
531190 Lessors of Other Real Estate  
Property (including equity  
REITs)  
445250 Fish & Seafood Retailers  
445291 Baked Goods Retailers  
445292 Confectionery & Nut Retailers  
519200 Web Search Portals,  
Libraries, Archives, & Other  
Info. Services  
531210 Offices of Real Estate Agents  
& Brokers  
445298 All Other Specialty Food  
Finance and Insurance  
Depository Credit Intermediation  
522110 Commercial Banking  
522130 Credit Unions  
484110 General Freight Trucking,  
Retialers  
531310 Real Estate Property  
Managers  
Local  
445320 Beer, Wine, & Liquor  
Retailers  
484120 General Freight Trucking,  
Long-distance  
531320 Offices of Real Estate  
Appraisers  
Furniture and Home Furnishings  
484200 Specialized Freight Trucking  
522180 Savings Institutions & Other  
Retailers  
531390 Other Activities Related to  
Real Estate  
Transit and Ground Passenger  
Depository Credit  
449110 Furniture Retailers  
Transportation  
Intermediation  
Rental and Leasing Services  
449121 Floor Covering Retailers  
449122 Window Treatment Retailers  
485110 Urban Transit Systems  
Nondepository Credit  
532100 Automotive Equipment Rental  
Intermediation  
485210 Interurban & Rural Bus  
& Leasing  
449129 All Other Home Furnishings  
Transportation  
522210 Credit Card Issuing  
522220 Sales Financing  
522291 Consumer Lending  
532210 Consumer Electronics &  
Appliances Rental  
Retailers  
485310 Taxi Service  
Electronics and Appliance Retailers  
485320 Limousine Service  
532281 Formal Wear & Costume  
449210 Electronic & Appliance  
Retailers (including  
computers)  
485410 School & Employee Bus  
522292 Real Estate Credit (including  
Rental  
Transportation  
mortgage bankers &  
532282 Video Tape & Disc Rental  
originators)  
485510 Charter Bus Industry  
532283 Home Health Equipment  
General Merchandise Retailers  
522299 Intl, Secondary Market, &  
Other Nondepos. Credit  
Intermediation  
485990 Other Transit & Ground  
Rental  
455110 Department Stores  
Passenger Transportation  
532284 Recreational Goods Rental  
455210 Warehouse Clubs,  
Pipeline Transportation  
532289 All Other Consumer Goods  
Supercenters,& Other  
Activities Related to Credit  
486000 Pipeline Transportation  
Rental  
General Merch. Retailers  
Intermediation  
Scenic & Sightseeing  
532310 General Rental Centers  
Health and Personal Care Retailers  
522300 Activities Related to Credit  
Intermediation (including loan  
brokers, check clearing, &  
money transmitting)  
Transportation  
532400 Commercial & Industrial  
Machinery & Equipment  
Rental & Leasing  
456110 Pharmacies & Drug Retailers  
487000 Scenic & Sightseeing  
Transportation  
456120 Cosmetics, Beauty Supplies,  
& Perfume Retailers  
Support Activities for  
456130 Optical Goods Retailers  
Transportation  
456190 Other Health & Personal Care  
488100 Support Activities for Air  
Transportation  
Retailers  
51  
Principal Business Activity Codes (Continued)  
Lessors of Nonfinancial Intangible  
Assets (except copyrighted works)  
561210 Facilities Support Services  
Home Health Care Services  
Other Services  
561300 Employment Services  
621610 Home Health Care Services  
Repair and Maintenance  
533110 Lessors of Nonfinancial  
Intangible Assets (except  
copyrighted works)  
561410 Document Preparation  
Other Ambulatory Health Care  
811110 Automotive Mechanical &  
Services  
Services  
Electrical Repair &  
561420 Telephone Call Centers  
621900 Other Ambulatory Health  
Care Services (including  
ambulance services & blood  
& organ banks)  
Maintenance  
Professional, Scientific, and  
561430 Business Service Centers  
(including private mail centers  
& copy shops)  
811120 Automotive Body, Paint,  
Technical Services  
Interior, & Glass Repair  
811190 Other Automotive Repair &  
Maintenance (including oil  
change & lubrication shops &  
car washes)  
Legal Services  
Hospitals  
561440 Collection Agencies  
561450 Credit Bureaus  
541110 Offices of Lawyers  
541190 Other Legal Services  
622000 Hospitals  
Nursing and Residential Care  
561490 Other Business Support  
Accounting, Tax Preparation,  
Facilities  
811210 Electronic & Precision  
Equipment Repair &  
Maintenance  
Services (including  
Bookkeeping, and Payroll Services  
repossession services, court  
reporting, & stenotype  
services)  
623000 Nursing & Residential Care  
Facilities  
541211 Offices of Certified Public  
Accountants  
811310 Commercial & Industrial  
Machinery & Equipment  
(except Automotive &  
Electronic) Repair &  
Social Assistance  
541213 Tax Preparation Services  
541214 Payroll Services  
561500 Travel Arrangement &  
624100 Individual & Family Services  
Reservation Services  
624200 Community Food & Housing,  
& Emergency & Other Relief  
Services  
561600 Investigation & Security  
Services  
541219 Other Accounting Services  
Maintenance  
Architectural, Engineering, and  
811410 Home & Garden Equipment &  
561710 Exterminating & Pest Control  
Related Services  
624310 Vocational Rehabilitation  
Appliance Repair &  
Services  
Services  
541310 Architectural Services  
Maintenance  
561720 Janitorial Services  
624410 Childcare Services  
541320 Landscape Architecture  
811420 Reupholstery & Furniture  
561730 Landscaping Services  
Services  
Repair  
Arts, Entertainment, and  
561740 Carpet & Upholstery Cleaning  
541330 Engineering Services  
541340 Drafting Services  
811430 Footwear & Leather Goods  
Repair  
Recreation  
Services  
Performing Arts, Spectator Sports,  
and Related Industries  
561790 Other Services to Buildings &  
Dwellings  
811490 Other Personal & Household  
541350 Building Inspection Services  
Goods Repair & Maintenance  
541360 Geophysical Surveying &  
711100 Performing Arts Companies  
561900 Other Support Services  
(including packaging &  
labeling services, &  
Personal and Laundry Services  
812111 Barber Shops  
Mapping Services  
711210 Spectator Sports (including  
541370 Surveying & Mapping (except  
Geophysical) Services  
sports clubs & racetracks)  
812112 Beauty Salons  
812113 Nail Salons  
convention & trade show  
organizers)  
711300 Promoters of Performing Arts,  
Sports, & Similar Events  
541380 Testing Laboratories &  
Services  
Waste Management and  
812190 Other Personal Care Services  
711410 Agents & Managers for  
Artists, Athletes, Entertainers,  
& Other Public Figures  
Specialized Design Services  
Remediation Services  
(including diet & weight  
reducing centers)  
541400 Specialized Design Services  
(including interior, industrial,  
graphic, & fashion design)  
562000 Waste Management &  
Remediation Services  
812210 Funeral Homes & Funeral  
711510 Independent Artists, Writers,  
Services  
& Performers  
Educational Services  
611000 Educational Services  
(including schools, colleges,  
& universities)  
Computer Systems Design and  
812220 Cemeteries & Crematories  
Museums, Historical Sites, and  
Similar Institutions  
Related Services  
812310 Coin-Operated Laundries &  
541511 Custom Computer  
Programming Services  
Drycleaners  
712100 Museums, Historical Sites, &  
Similar Institutions  
812320 Drycleaning & Laundry  
Services (except  
Health Care and Social  
541512 Computer Systems Design  
Amusement, Gambling, and  
Recreation Industries  
Services  
Assistance  
Coin-Operated)  
541513 Computer Facilities  
Management Services  
812330 Linen & Uniform Supply  
Offices of Physicians and Dentists  
713100 Amusement Parks & Arcades  
713200 Gambling Industries  
812910 Pet Care (except Veterinary)  
621111 Offices of Physicians (except  
541519 Other Computer Related  
Services  
mental health specialists)  
713900 Other Amusement &  
Services  
812920 Photofinishing  
621112 Offices of Physicians, Mental  
Health Specialists  
Recreation Industries  
Other Professional, Scientific, and  
Technical Services  
(including golf courses, skiing  
facilities, marinas, fitness  
centers, & bowling centers)  
812930 Parking Lots & Garages  
812990 All Other Personal Services  
621210 Offices of Dentists  
541600 Management, Scientific, &  
Technical Consulting  
Services  
Offices of Other Health  
Religious, Grantmaking, Civic,  
Professional, and Similar  
Organizations  
Practitioners  
Accommodation and Food  
621310 Offices of Chiropractors  
621320 Offices of Optometrists  
Services  
541700 Scientific Research &  
813000 Religious, Grantmaking,  
Civic, Professional, & Similar  
Organizations (including  
condominium and  
Development Services  
Accommodation  
621330 Offices of Mental Health  
Practitioners (except  
Physicians)  
541800 Advertising, Public Relations,  
& Related Services  
721110 Hotels (except Casino Hotels)  
& Motels  
541910 Marketing Research & Public  
homeowners associations)  
721120 Casino Hotels  
621340 Offices of Physical,  
Occupational & Speech  
Therapists, & Audiologists  
Opinion Polling  
721191 Bed & Breakfast Inns  
Other  
541920 Photographic Services  
721199 All Other Traveler  
999000 Unclassified Establishments  
541930 Translation & Interpretation  
Accommodation  
621391 Offices of Podiatrists  
(unable to classify)  
Services  
721210 RV (Recreational Vehicle)  
Parks & Recreational Camps  
621399 Offices of All Other  
Miscellaneous Health  
Practitioners  
541940 Veterinary Services  
541990 All Other Professional,  
Scientific, & Technical  
Services  
721310 Rooming & Boarding Houses,  
Dormitories & Workers’  
Camps  
Outpatient Care Centers  
621410 Family Planning Centers  
Food Services and Drinking Places  
Management of Companies  
621420 Outpatient Mental Health &  
722300 Special Food Services  
(Holding Companies)  
Substance Abuse Centers  
(including food service  
551111 Offices of Bank Holding  
Companies  
621491 HMO Medical Centers  
621492 Kidney Dialysis Centers  
contractors & caterers)  
722410 Drinking Places (Alcoholic  
551112 Offices of Other Holding  
621493 Freestanding Ambulatory  
Surgical & Emergency  
Centers  
Beverages)  
Companies  
722511 Full Service Restaurants  
Administrative and Support and  
Waste Management and  
Remediation Services  
722513 Limited Service Restaurants  
621498 All Other Outpatient Care  
722514 Cafeterias, Grill buffets, &  
Centers  
Buffets  
Medical and Diagnostic  
Laboratories  
722515 Snack & Nonalcoholic  
Beverage Bars  
Administrative and Support  
Services  
621510 Medical & Diagnostic  
561110 Office Administrative  
Services  
Laboratories  
52