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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                On page 5 of the form, the question    entered “XX” on Form 5471, 
Revenue Code unless otherwise noted.                on Schedule G, line 18, has been         Schedule G, line 14, if the answer to 
Contents                                    Page    deleted and replaced with new            question 22 of the table in the 
Future Developments .     . . . . . . . . . . . 1   questions 18a and 18b to better          instructions was “Yes.”
What’s New .  . . . . . . . . . . . . . . . . . 1   reflect Regulations section 1.482-2(a)      Worksheet A, lines 23 and 25, were 
General Instructions .  . . . . . . . . . . . . 1   (2)(iii)(B).                             revised to add a reference to section 
Purpose of Form .   . . . . . . . . . . . . . . 1     On page 5, the question on             961(c).
Who Must File   . . . . . . . . . . . . . . . . 1   Schedule G, line 19a, has been              Worksheet A, lines 28 and 31, were 
When and Where To File .      . . . . . . . . . 2   reworded to better reflect Regulations   amended.
Categories of Filers .  . . . . . . . . . . . . 2   section 1.385-3. As a result, the 
                                                                                                Worksheet A, line 58, was revised 
Additional Filing Requirements .      . . . . . 7   information requested on line 19b(1) 
                                                                                             to more accurately reflect Regulations 
Penalties . . . . . . . . . . . . . . . . . . . . 8 has also been reworded.
Other Reporting Requirements .        . . . . . 8                                            section 1.951-1(b)(1)(ii)(A).
Specific Instructions . . . . . . . . . . . . . 9   Changes to separate Sched-                  The instructions for Worksheet A, 
Schedule B .  . . . . . . . . . . . . . . . .   12  ule G-1. Line 6b was reworded to         line 1a, were clarified by adding a 
Schedule C .  . . . . . . . . . . . . . . . .   13  better reflect Regulations section       reference to the limitation on section 
Schedule F .  . . . . . . . . . . . . . . . .   13  1.482-7A.                                954(c)(6) in Regulations section 
Schedule G .  . . . . . . . . . . . . . . . .   13  Changes to separate Schedule Q.          1.245A-5.
Schedule I . . . . . . . . . . . . . . . . . .  19  On page 1 of the schedule, line 1f now      A new instruction for Worksheet A, 
Instructions for Separate                           requests “Other Foreign Personal         lines 13b, 13d, 13e, 14b, 15b, 16b, 
Schedules .       . . . . . . . . . . . . . .   29  Holding Company Income.” Filers are      18b, and 19b, was added regarding 
Schedule E .  . . . . . . . . . . . . . . . .   29  directed to see the instructions for an  allocation and apportionment of 
Schedule E-1 .  . . . . . . . . . . . . . . .   32  attachment requirement for line 1f.      expenses to better reflect Regulations 
Schedule G-1 .  . . . . . . . . . . . . . . .   34
Schedule H .  . . . . . . . . . . . . . . . .   35    On page 4 of the schedule, the         section 1.954-1(c)(1)(i), (ii), and (iv).
Schedule I-1  . . . . . . . . . . . . . . . .   37  following lines have been shaded            A new Worksheet H-1 has been 
Schedule J   . . . . . . . . . . . . . . . . .  39  under column (xv), Loss Allocation.      added to these instructions. Also, new 
Schedule M .  . . . . . . . . . . . . . . . .   42  • Lines 3, 3(1), and 3(2), pertaining to Worksheet H-1 Instructions have been 
Schedule O .  . . . . . . . . . . . . . . . .   43  the Tested Income Group.                 provided.
Schedule P .  . . . . . . . . . . . . . . . .   43  • Lines 4, 4(1), and 4(2), pertaining to 
                                                                                                In the instructions for separate 
Schedule Q .  . . . . . . . . . . . . . . . .   44  the Residual Income Group.
                                                                                             Schedule Q, line 1, the attachment 
Schedule R .  . . . . . . . . . . . . . . . .   48  Changes to these instructions.           requirement for line 1f has been 
Principal Business Activity Codes .       . .   50  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                    No changes were needed to the 
developments related to Form 5471,                  instructions for separate 
                                                                                             Purpose of Form
its schedules, and its instructions,                Schedule G-1.
such as legislation enacted after they                                                       Form 5471 is used by certain U.S. 
                                                      In addition, the following changes 
were published, go to IRS.gov/                                                               persons who are officers, directors, or 
                                                    have been made.
Form5471.                                                                                    shareholders in certain foreign 
                                                      The table of questions for Form        corporations. The form and schedules 
What’s New                                          5471, Schedule G, line 14, has been      are used to satisfy the reporting 
                                                    amended as follows. If the answer to     requirements of sections 6038 and 
Changes to Form 5471.             On page 1         question 22 of that table is “Yes,” for  6046, and the related regulations.
of the form, new line 1b(3) requests                tax year 2023, affected Form 5471 
the previous reference ID number(s)                 filers will enter code “PRS” on Form     Who Must File
of the foreign corporation, if any.                 5471, Schedule G, line 14. For tax       Generally, all U.S. persons described 
                                                    year 2022, affected Form 5471 filers     in Categories of Filers below must 

Jan 25, 2024                                                     Cat. No. 49959G

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complete the schedules, statements, U.S. shareholder. For purposes of shareholder with respect to a
and/or other information requested in Category 1, a U.S. shareholder is a foreign-controlled section 965 SFC
the chart, Filing Requirements for U.S. person who owns (directly, who:
Categories of Filers, later. Read the indirectly, or constructively, within the 1. Owns, within the meaning of
information for each category carefully meaning of section 958(a) and (b)) section 958(a), stock of a
to determine which schedules, 10% or more of the total combined foreign-controlled section 965 SFC;
statements, and/or information apply. voting power or value of shares of all and
classes of stock of a section 965 SFC.
Note. When a schedule is required 2. Is not related (using principles
See section 951(b).
but all amounts are zero, the schedule of section 954(d)(3)) to the
should still be filed with one or more U.S. person. For purposes of foreign-controlled section 965 SFC.
zero amounts. For schedules that are Category 1, a U.S. person is:
Foreign-controlled section 965
completed by category (that is, 1. A citizen or resident of the SFC. For purposes of Category 1b, a
Schedules E, I-1, J, P, and Q), United States; foreign-controlled section 965 SFC is
inclusion of a single instance of that
2. A domestic partnership; a foreign corporation that is a section
schedule for any separate category
will meet the requirement. 3. A domestic corporation; or 965 SFC that would not be a section
965 SFC if the determination were
4. An estate or trust that is not a
If the filer is described in more than made without applying subparagraphs
foreign estate or trust, as defined in
one filing category, do not duplicate (A), (B), and (C) of section 318(a)(3)
section 7701(a)(31).
information. However, complete all so as to consider a U.S. person as
items that apply. For example, if you See section 957(c) for exceptions. owning stock that is owned by a
are the sole owner of a CFC (that is, Section 965 SFC. For purposes of foreign person.
you are described in Categories 4 and Category 1, a section 965 SFC is:
5a), complete all six pages of Form Category 1c Filer
5471 and separate Schedules E, G-1, 1. A controlled foreign corporation
H, I-1, J, M, P, Q, and R. (CFC) (see Category 5 Filers, later, for
definition); or A Category 1c filer is a person who is
a related constructive U.S.
Note. Complete a separate Form 2. Any foreign corporation with shareholder (defined below) of a
5471 and all applicable schedules for respect to which one or more foreign-controlled section 965 SFC
each applicable foreign corporation. domestic corporations are U.S. (defined below). This type of Category
shareholders. 1 filer extends the relief for certain
When and Where To File Category 5 filers announced in
However, if a passive foreign
Attach Form 5471 to your income tax section 8.03 of Rev. Proc. 2019-40,
investment company (PFIC) (as
return (or, if applicable, partnership or 2019-43 I.R.B. 982, to similarly
defined in section 1297) with respect
exempt organization return) and file situated Category 1 filers.
to the shareholder is not a CFC, then
both by the due date (including
such corporation is not a section 965
extensions) for that return. Related constructive U.S. share-
SFC. holder. For purposes of Category 1c,
Categories of Filers See section 965 and the a related constructive U.S.
regulations thereunder for exceptions. shareholder is a U.S. shareholder with
Category 1 Filers respect to a foreign-controlled section
In general, a Category 1 filer is a Category 1a Filer 965 SFC who:
person who was a U.S. shareholder of 1. Does not own, within the
a foreign corporation that was a A Category 1a filer is a Category 1 meaning of section 958(a), stock of
section 965 specified foreign filer that is not a Category 1b or 1c the foreign-controlled section 965
corporation (SFC) at any time during filer. SFC; and
the foreign corporation’s tax year
2. Is related (using principles of
ending with or within the U.S. Category 1b Filer section 954(d)(3)) to the
shareholder’s tax year, and who
foreign-controlled section 965 SFC.
owned that stock on the last day in A Category 1b filer is a person who is
that year in which the foreign an unrelated section 958(a) U.S. Foreign-controlled section 965
corporation was a section 965 SFC, shareholder (defined below) of a SFC. For purposes of Category 1c,
taking into account the regulations foreign-controlled section 965 SFC the term “foreign-controlled section
under section 965. There are three (defined below). This type of Category 965 SFC” has the same meaning as
different types of Category 1 filers, 1 filer extends the relief for certain provided under Category 1b Filer,
each described below: Category 1a Category 5 filers announced in earlier.
filers, Category 1b filers, and section 8.02 of Rev. Proc. 2019-40,
Category 1c filers. 2019-43 I.R.B. 982, to similarly Additional Information for
Except as otherwise provided in the situated Category 1 filers. Category 1 Filers
instructions for each type of Category Unrelated section 958(a) U.S. When Category 1 reporting is no
1 filer below, the following definitions shareholder. For purposes of longer required. A Category 1 filer
apply for purposes of Category 1. Category 1b, an unrelated section must continue to file all information
958(a) U.S. shareholder is a U.S. required as long as:

2 Instructions for Form 5471 (Rev. 01-2024)

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• The section 965 SFC (or section 5.02 of Notice 2018-13, See Regulations section
foreign-controlled section 965 SFC) 2018-6 I.R.B. 341, to similarly situated 1.6046-1(i) for additional information.
has accumulated earnings and profits Category 1 filers.
U.S. person. For purposes of
(E&P) related to section 965 that is
Unrelated constructive U.S. share- Category 2, a U.S. person is:
reportable on Schedule J (Form
holder. A Category 1 filer does not
5471), or 1. A citizen or resident of the
have to file Form 5471 if all of the
• The Category 1 filer has previously United States;
following conditions are met.
taxed E&P related to section 965 that 2. A domestic partnership;
is reportable on Schedule P (Form 1. The foreign corporation is a
3. A domestic corporation; or
5471). foreign-controlled section 965 SFC.
4. An estate or trust that is not a
2. The Category 1 filer is a U.S.
foreign estate or trust, as defined in
Category 1 Filers—Exceptions shareholder that does not own stock,
section 7701(a)(31).
From Filing within the meaning of section 958(a),
Certain constructive owners. in the foreign-controlled section 965 See Regulations section
• A Category 1 filer does not have to SFC. 1.6046-1(f)(3) for exceptions.
file Form 5471 if all of the following 3. The Category 1 filer is not
conditions are met. related, using principles of section Additional Information for
1. The Category 1 filer does not 954(d)(3), to the foreign-controlled Category 2 Filers
own a direct interest in the foreign section 965 SFC.
Foreign sales corporations (FSCs).
corporation. This exception implements the Category 2 filers who are
2. The Category 1 filer is required relief for certain Category 5 filers shareholders, officers, and directors
to furnish the information requested announced in section 8.04 of Rev. of an FSC (as defined in section 922,
solely because of constructive Proc. 2019-40, 2019-43 I.R.B. 982, as in effect before its repeal) must file
ownership (as determined under and extends it to Category 1 filers. Form 5471 and a separate
Regulations section 1.958-2, Schedule O to report changes in the
Other filing exceptions. Certain
1.6038-2(c), or 1.6046-1(i)) from ownership of the FSC.
other filing exceptions apply to all
another U.S. person.
categories of filers. See Additional Category 2 Filers—Exceptions
3. The U.S. person through which Filing Exceptions, later. From Filing
the Category 1 filer constructively
owns an interest in the foreign Category 2 Filer A Category 2 filer does not have to file
corporation files Form 5471 to report This category includes a U.S. citizen Form 5471 if:
all of the information required of the or resident who is an officer or director 1. Immediately after a reportable
Category 1 filer. of a foreign corporation in which a stock acquisition, three or fewer U.S.
U.S. person (defined below) has persons own 95% or more in value of
• A Category 1 filer does not have to
acquired (in one or more the outstanding stock of the foreign
file Form 5471 if it:
transactions): corporation and the U.S. person
1. Does not own a direct or making the acquisition files a return
1. Stock that meets the 10% stock
indirect interest in the foreign for the acquisition as a Category 3
ownership requirement (defined
corporation, and filer; or
below) with respect to the foreign
2. Is required to file Form 5471 corporation, or 2. The U.S. person(s) for which
solely because of constructive the Category 2 filer is required to file
2. An additional 10% or more (in
ownership from a nonresident alien. Form 5471 does not directly own an
value or voting power) of the
No statement is required to be outstanding stock of the foreign interest in the foreign corporation but
attached to the tax return of a corporation. is required to furnish the information
Category 1 filer claiming either solely because of constructive stock
A U.S. person has acquired stock
constructive ownership exception. ownership from a U.S. person and the
in a foreign corporation when that
See Regulations section 1.6038-2(j) person from whom the stock
person has an unqualified right to
(2) and (3), and Regulations section ownership is attributed furnishes all of
receive the stock, even though the
1.6038-2(l) for additional information. the information required of the
stock is not actually issued. See Category 2 filer.
No section 958(a) U.S. sharehold- Regulations section 1.6046-1(c) and
er. A Category 1 filer does not have to (f)(1) for more details. Other filing exceptions. Certain
file Form 5471 if no U.S. shareholder other filing exceptions apply to all
10% stock ownership requirement.
(including the Category 1 filer) owns, categories of filers. See Additional
For purposes of Category 2, the stock
within the meaning of section 958(a), Filing Exceptions, later.
ownership threshold is met if a U.S.
stock in the section 965 SFC on the
person owns:
last day in the year of the foreign Category 3 Filer
corporation in which it was a section 1. 10% or more of the total value This category includes:
965 SFC and the SFC is a of the foreign corporation's stock, or 1. A U.S. person (defined below)
foreign-controlled section 965 SFC. 2. 10% or more of the total who acquires stock in a foreign
This exception extends the relief for combined voting power of all classes corporation which, when added to any
Category 5 filers announced in of stock with voting rights. stock owned on the date of

Instructions for Form 5471 (Rev. 01-2024) 3

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acquisition, meets the 10% stock 2. The name, address, identifying 6013(h), relating to nonresident aliens
ownership requirement (defined number, and number of shares who become residents of the United
below) with respect to the foreign subscribed to by each suscriber to the States during the tax year and are
corporation; foreign corporation's stock. married at the close of the tax year to
2. A U.S. person who acquires a citizen or resident of the United
Foreign sales corporations (FSCs).
stock which, without regard to stock States;
Category 3 filers who are
already owned on the date of 4. A domestic partnership;
shareholders, officers, and directors
acquisition, meets the 10% stock 5. A domestic corporation; and
of an FSC (as defined in section 922,
ownership requirement with respect to
as in effect before its repeal) must file 6. An estate or trust that is not a
the foreign corporation;
Form 5471 and a separate foreign estate or trust, as defined in
3. A person who is treated as a Schedule O to report changes in the section 7701(a)(31).
U.S. shareholder under section 953(c) ownership of the FSC.
with respect to the foreign corporation; See Regulations section
4. A person who becomes a U.S. Category 3 Filers—Exception 1.6038-2(d) for exceptions.
person while meeting the 10% stock From Filing Control. For purposes of Category 4,
ownership requirement with respect to A Category 3 filer does not have to a U.S. person has control of a foreign
the foreign corporation; or file Form 5471 if all of the following corporation if, at any time during that
5. A U.S. person who disposes of conditions are met. person's tax year, it owns stock
sufficient stock in the foreign 1. The Category 3 filer does not possessing:
corporation to reduce his or her own a direct interest in the foreign 1. More than 50% of the total
interest to less than the 10% stock corporation. combined voting power of all classes
ownership requirement. 2. The Category 3 filer is required of stock of the foreign corporation
For more information, see section to furnish the information requested entitled to vote, or
6046 and Regulations section solely because of constructive 2. More than 50% of the total
1.6046-1. ownership (as determined under value of shares of all classes of stock
Regulations section 1.958-2, of the foreign corporation.
10% stock ownership requirement. 1.6038-2(c), or 1.6046-1(i)) from
For purposes of Category 3, the stock another U.S. person. For purposes of Category 4, a
person in control of a corporation that,
ownership threshold is met if a U.S. 3. The U.S. person through which in turn, owns more than 50% of the
person owns: the Category 3 filer constructively combined voting power, or the value,
1. 10% or more of the total value owns an interest in the foreign of all classes of stock of another
of the foreign corporation's stock, or corporation files Form 5471 to report corporation is also treated as being in
2. 10% or more of the total all of the information required of the control of such other corporation.
combined voting power of all classes Category 3 filer.
Example. Corporation A owns
of stock with voting rights. No statement is required to be 51% of the voting stock in Corporation
See Regulations section attached to tax returns for persons B. Corporation B owns 51% of the
1.6046-1(i) for additional information. claiming this constructive ownership voting stock in Corporation C.
exception.
U.S. person. For purposes of Corporation C owns 51% of the voting
Category 3, a U.S. person is: Other filing exceptions. Certain stock in Corporation D. Therefore,
1. A citizen or resident of the other filing exceptions apply to all Corporation D is controlled by
United States; categories of filers. See Additional Corporation A.
Filing Exceptions, later. For more details on “control” for
2. A domestic partnership;
3. A domestic corporation; or Category 4 Filer purposes of Category 4, see section
6038(e)(2) and Regulations section
4. An estate or trust that is not a This category includes a U.S. person 1.6038-2(b) and (c).
foreign estate or trust, as defined in (defined below) who had control
section 7701(a)(31). (defined below) of a foreign Additional Information for
corporation during the annual Category 4 Filers
See Regulations section accounting period of the foreign
1.6046-1(f)(3) for exceptions. corporation. Foreign sales corporations (FSCs).
• Category 4 filers who are
Additional Information for U.S. person. For purposes of shareholders of an FSC are not
Category 3 Filers Category 4, a U.S. person is: subject to the subpart F rules with
1. A citizen or resident of the respect to the FSC for:
Statement required. Category 3
United States;
filers must attach a statement that 1. Exempt foreign trade income;
includes: 2. A nonresident alien for whom an 2. Deductions that are
election is in effect under section
1. The amount and type of any apportioned or allocated to exempt
6013(g) to be treated as a resident of
indebtedness the foreign corporation foreign trade income;
the United States;
has with the related persons 3. Nonexempt foreign trade
described in Regulations section 3. An individual for whom an income (other than section 923(a)(2)
1.6046-1(b)(11), and election is in effect under section nonexempt income, within the

4 Instructions for Form 5471 (Rev. 01-2024)

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meaning of section 927(d)(6), as in    FSCs. Category 4 filers are not            4. An estate or trust that is not a 
effect before repeal); and             required to file a Form 5471 (in order   foreign estate or trust, as defined in 
  4. Any deductions that are           to satisfy the requirements of section   section 7701(a)(31).
apportioned or allocated to the        6038) if the FSC has filed a Form          See section 957(c) for exceptions.
nonexempt foreign trade income         1120-FSC. See Temporary 
                                                                                  In general, a CFC is a foreign 
described above.                       Regulations section 1.921-1T(b)(3). 
                                                                                corporation that has U.S. 
                                       However, these filers are required to 
• Category 4 filers who are                                                     shareholders that own (directly, 
                                       file Form 5471 for an FSC, regardless 
shareholders of an FSC are subject to                                           indirectly, or constructively, within the 
                                       of whether it has filed Form 
the subpart F rules for:                                                        meaning of section 958(a) and (b)) on 
                                       1120-FSC, if the filer has inclusions 
                                                                                any day of the tax year of the foreign 
  1. All other types of FSC income     with respect to the FSC under section 
                                                                                corporation, more than 50% of:
(including section 923(a)(2)           951(a) (as described above).
nonexempt income within the                                                       1. The total combined voting 
meaning of section 927(d)(6), as in    Other filing exceptions.  Certain        power of all classes of its voting stock, 
effect before its repeal);             other filing exceptions apply to all     or
                                       categories of filers. See Additional 
  2. Investment income and carrying    Filing Exceptions, later.                  2. The total value of the stock of 
charges (as defined in section 927(c)                                           the corporation.
and (d)(1), as in effect before its    Category 5 Filers
                                                                                  For purposes only of taking into 
repeal); and                           In general, a Category 5 filer is a      account income described in section 
  3. All other FSC income that is not  person who was a U.S. shareholder        953(a) (relating to insurance income), 
foreign trade income or investment     (defined below) that owned stock in a    a CFC also includes a foreign 
income or carrying charges.            foreign corporation that was a CFC       corporation that is described in 
                                       (defined below) at any time during the   section 957(b); and for purposes only 
Category 4 Filers—Exceptions           foreign corporation’s tax year ending    of taking into account related person 
From Filing                            with or within the U.S. shareholder’s    insurance income, a CFC includes a 
Certain constructive owners.           tax year, and who owned that stock on    foreign corporation described in 
• A Category 4 filer does not have to  the last day in that year in which the   section 953(c)(1)(B).
file Form 5471 if all of the following foreign corporation was a CFC. There 
conditions are met.                    are three different types of Category 5 
                                                                                Category 5a Filer
                                       filers, each described below: 
  1. The Category 4 filer does not     Category 5a filers, Category 5b filers, 
                                                                                A Category 5a filer is a Category 5 
own a direct interest in the foreign   and Category 5c filers.
corporation.                                                                    filer that is not a Category 5b or 5c 
  2. The Category 4 filer is required     Except as otherwise provided in the  filer.
to furnish the information requested   instructions for each type of Category 
solely because of constructive         5 filer below, the following definitions Category 5b Filer
ownership (as determined under         apply for purposes of Category 5.
Regulations section 1.958-2,           U.S. shareholder. For purposes of        A person is a Category 5b filer if they 
1.6038-2(c), or 1.6046-1(i)) from      Category 5, a U.S. shareholder is a      are an unrelated section 958(a) U.S. 
another U.S. person.                   U.S. person (defined below) who:         shareholder (defined below) of a 
                                                                                foreign-controlled CFC (defined 
  3. The U.S. person through which        1. Owns (directly, indirectly, or     below). This type of Category 5 filer 
the Category 4 filer constructively    constructively, within the meaning of    implements the relief for certain 
owns an interest in the foreign        section 958(a) and (b)) 10% or more      Category 5 filers announced in 
corporation files Form 5471 to report  of the total combined voting power or    section 8.02 of Rev. Proc. 2019-40, 
all of the information required of the value of shares of all classes of stock  2019-43 I.R.B. 982.
Category 4 filer.                      of a CFC; or
                                                                                Unrelated section 958(a) U.S. 
• A Category 4 filer does not have to     2. Owns (either directly or 
                                                                                shareholder. For purposes of 
file Form 5471 if it:                  indirectly, within the meaning of 
                                                                                Category 5b, an unrelated section 
                                       section 958(a)) any stock of a CFC 
  1. Does not own a direct or                                                   958(a) U.S. shareholder is a U.S. 
                                       (as defined in sections 953(c)(1)(B) 
indirect interest in the foreign                                                shareholder with respect to a 
                                       and 957(b)), unless the foreign 
corporation, and                                                                foreign-controlled CFC who:
                                       corporation has an effective section 
  2. Is required to file Form 5471     953(c)(3)(C) election in place for the     1. Owns, within the meaning of 
solely because of constructive         tax year.                                section 958(a), stock of a 
ownership from a nonresident alien.                                             foreign-controlled CFC; and
                                       U.S. person.  For purposes of 
  No statement is required to be                                                  2. Is not related (using principles 
                                       Category 5, a U.S. person is:
attached to the tax return of a                                                 of section 954(d)(3)) to the 
Category 4 filer claiming either          1. A citizen or resident of the       foreign-controlled CFC.
constructive ownership exception.      United States;
                                                                                Foreign-controlled CFC.    For 
See Regulations section 1.6038-2(j)       2. A domestic partnership;
                                                                                purposes of Category 5b, a 
(2) and (3), and Regulations section      3. A domestic corporation; or         foreign-controlled CFC is a foreign 
1.6038-2(l) for additional information.
                                                                                corporation that is a CFC that would 

Instructions for Form 5471 (Rev. 01-2024)                                                                                5

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not be a CFC if the determination 1. All other types of FSC income 5.02 of Notice 2018-13, 2018-6 I.R.B.
were made without applying (including section 923(a)(2) 341, for additional information.
subparagraphs (A), (B), and (C) of nonexempt income, within the
Unrelated constructive U.S. share-
section 318(a)(3) so as to consider a meaning of section 927(d)(6), as in
holder. A Category 5 filer does not
U.S. person as owning stock that is effect before its repeal);
have to file Form 5471 if all of the
owned by a foreign person. 2. Investment income and carrying following conditions are met.
charges (as defined in section 927(c)
1. The foreign corporation is a
Category 5c Filer and (d)(1), as in effect before its
foreign-controlled CFC.
repeal); and
A person is a Category 5c filer if they 2. The filer is a U.S. shareholder
3. All other FSC income that is not
are a related constructive U.S. that does not own stock, within the
foreign trade income or investment
shareholder (defined below) of a meaning of section 958(a), in the
income or carrying charges.
foreign-controlled CFC (defined foreign-controlled CFC.
below). This type of Category 5 filer Category 5 Filers—Exceptions 3. The filer is not related, using
implements the relief for certain From Filing principles of section 954(d)(3), to the
Category 5 filers announced in foreign-controlled CFC.
section 8.03 of Rev. Proc. 2019-40, Certain constructive owners.
2019-43 I.R.B. 982. • A Category 5 filer does not have to See section 8.04 of Rev. Proc.
file Form 5471 if all of the following 2019-40, 2019-43 I.R.B. 982, for
Related constructive U.S. share- conditions are met. additional information.
holder. For purposes of Category 5c,
a related constructive U.S. 1. The Category 5 filer does not FSCs. Category 5 filers are not
shareholder is a U.S. shareholder with own a direct interest in the foreign required to file a Form 5471 (in order
respect to a foreign-controlled CFC corporation. to satisfy the requirements of section
who: 2. The Category 5 filer is required 6038) if the FSC has filed a Form
1. Does not own, within the to furnish the information requested 1120-FSC. See Temporary
meaning of section 958(a), stock of solely because of constructive Regulations section 1.921-1T(b)(3).
the foreign-controlled CFC; and ownership (as determined under However, these filers are required to
Regulations section 1.958-2, file Form 5471 for an FSC, regardless
2. Is related (using principles of 1.6038-2(c), or 1.6046-1(i)) from of whether it has filed Form
section 954(d)(3)) to the another U.S. person. 1120-FSC, if the filer has inclusions
foreign-controlled CFC. with respect to the FSC under section
3. The U.S. person through which
Foreign-controlled CFC. For the Category 5 filer constructively 951(a) (as described above).
purposes of Category 5c, the term owns an interest in the foreign Other filing exceptions. Certain
“foreign-controlled CFC” has the same corporation files Form 5471 to report other filing exceptions apply to all
meaning as defined in Category 5b all of the information required of the categories of filers. See Additional
Filer, earlier. Category 5 filer. Filing Exceptions next.
Additional Information for • A Category 5 filer does not have to
Category 5 Filers file Form 5471 if it: Additional Filing
Exceptions
1. Does not own a direct or
Foreign sales corporations (FSCs). indirect interest in the foreign Multiple filers of same information.
• Category 5 filers who are corporation, and With respect to any category of filer,
shareholders of an FSC are not one person may file Form 5471 and
subject to the subpart F rules with 2. Is required to file Form 5471
respect to the FSC for: solely because of constructive the applicable schedules for other
ownership from a nonresident alien. persons who have the same filing
1. Exempt foreign trade income; requirements. If you and one or more
2. Deductions that are No statement is required to be other persons are required to furnish
apportioned or allocated to exempt attached to the tax return of a information for the same foreign
foreign trade income; Category 5 filer claiming either corporation for the same period, a
constructive ownership exception. joint information return that contains
3. Nonexempt foreign trade See Regulations section 1.6038-2(j) the required information may be filed
income (other than section 923(a)(2) (2) and (3), and Regulations section with your tax return or with the tax
nonexempt income, within the 1.6038-2(l) for additional information. return of any one of the other persons.
meaning of section 927(d)(6), as in
effect before repeal); and No section 958(a) U.S. sharehold- For example, a U.S. person described
4. Any deductions that are er. A Category 5 filer does not have to in Category 5 may file a joint Form
apportioned or allocated to the file Form 5471 if no U.S. shareholder 5471 with a Category 4 filer or another
nonexempt foreign trade income (including the Category 5 filer) owns, Category 5 filer; similarly, a U.S.
described above. within the meaning of section 958(a), person described in Category 5b may
stock in the CFC on the last day in the file a joint Form 5471 with a Category
• Category 5 filers who are year of the foreign corporation in 4 or 5a filer or another Category 5b
shareholders of an FSC are subject to which it was a CFC and the CFC is a filer (but not a Category 5c filer).
the subpart F rules for: foreign-controlled CFC. See section However, for Category 3 filers, the
required information may only be filed

6 Instructions for Form 5471 (Rev. 01-2024)

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by another person having an equal or CFC is considered to have types of transactions that the IRS has
greater interest (measured in terms of participated in a reportable determined to be a tax avoidance
value or voting power of the stock of transaction under the rules of transaction and identified by notice,
the foreign corporation). Regulations section 1.6011-4(c)(3)(i) regulation, or other published
The person that files Form 5471 (G), the shareholder is required to guidance as a listed transaction.
must complete Form 5471 in the disclose information for each 2. Any transaction offered under
manner described in the instructions reportable transaction. Form 8886, conditions of confidentiality for which
for item H. All persons identified in Reportable Transaction Disclosure the corporation (or a related party)
item H must attach a statement to Statement, must be filed for each tax paid an advisor a fee of at least
their income tax return that includes year indicated in Regulations section $250,000.
the information described in the 1.6011-4(c)(3)(i)(G). The following are
3. Certain transactions for which
instructions for item H. See reportable transactions.
the corporation (or a related party)
Regulations section 1.6038-2(j)(1) 1. Any listed transaction, which is has contractual protection against
and (3) for additional information. a transaction that is the same as or disallowance of the tax benefits.
substantially similar to one of the
Domestic corporations.
Shareholders are not required to file
Form 5471 for a foreign insurance Filing Requirements for Categories of Filers
company that has elected (under
section 953(d)) to be treated as a Table of Required Information
domestic corporation and has filed a
U.S. income tax return for its tax year Category of Filer
Required Information*
under that provision. See Rev. Proc. 1a 1b 1c 2 3 4 5a 5b 5c
2003-47, 2003-28 I.R.B. 55, available The identifying information on page
at IRS.gov/irb/ 1 of Form 5471 above Schedule A;
2003-28_IRB#RP-2003-47, for see Specific Instructions
procedural rules regarding the
Schedule A
election under section 953(d).
Schedule B, Part I
Additional Filing Schedule B, Part II
Requirements
Schedules C and F
Section 338 election. If a section
338 election is made with respect to a Separate Schedule E 1 2 1 2
qualified stock purchase of a foreign
target corporation for which a Form Schedule E-1 (included with 1 1
separate Schedule E)
5471 must be filed:
• A purchaser (or its U.S. Schedule G
shareholder) must attach a copy of
Separate Schedule G-1
Form 8883, Asset Allocation
Statement Under Section 338, to the Separate Schedule H
first Form 5471 for the new foreign
target corporation (see the Schedule I
Instructions for Form 8883 for details);
Separate Schedule I-1
• A seller (or its U.S. shareholder)
must attach a copy of Form 8883 to Separate Schedule J
the last Form 5471 for the old foreign
target corporation; Separate Schedule M
• A U.S. shareholder that files a
section 338 election on behalf of a Separate Schedule O, Part I
foreign purchasing corporation that is Separate Schedule O, Part II
a CFC pursuant to Regulations
section 1.338-2(e)(3) must attach a Separate Schedule P
copy of Form 8023, Elections Under
Section 338 for Corporations Making Separate Schedule Q
Qualified Stock Purchases, to the Separate Schedule R
Form 5471 filed with respect to the
purchasing corporation for the tax * See also Additional Filing Requirements.
year that includes the acquisition date 1 Schedules E and E-1 are required for an Unrelated section 958(a) U.S. shareholder. only if the filer claims
(see the Instructions for Form 8023 for deemed paid foreign income taxes of the foreign-controlled section 965 SFC or foreign-controlled CFC
details). under section 960 for the filer’s tax year. See Rev. Proc. 2019-40 for more details.
Reportable transaction disclosure 2 Related constructive U.S. shareholder. only need to complete Schedule E (they can leave Schedule E-1
statement. If a U.S. shareholder of a blank). See Rev. Proc. 2019-40 for more details.

Instructions for Form 5471 (Rev. 01-2024) 7

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4. Certain transactions resulting in section 6038(a) within the time Section 6662(j). Penalties may be
a loss of at least $10 million in any prescribed. If the information is not imposed for undisclosed foreign
single year or $20 million in any filed within 90 days after the IRS has financial asset understatements. No
combination of years. mailed a notice of the failure to the penalty will be imposed with respect
5. Any transaction identified by the U.S. person, an additional $10,000 to any portion of an underpayment if
IRS by notice, regulation, or other penalty (per foreign corporation) is the taxpayer can demonstrate that the
published guidance as a “transaction charged for each 30-day period, or failure to comply was due to
of interest.” See Notice 2009-55, fraction thereof, during which the reasonable cause with respect to
2009-31 I.R.B. 170, available at failure continues after the 90-day such portion of the underpayment and
IRS.gov/irb/ period has expired. The additional the taxpayer acted in good faith with
2009-31_IRB#NOT-2009-55. penalty is limited to a maximum of respect to such portion of the
$50,000 for each failure. underpayment. See sections 6662(j)
For more information, see • Any person who fails to file or report and 6664(c) for additional information.
Regulations section 1.6011-4. Also, all of the information required within
see the Instructions for Form 8886. the time prescribed will be subject to a Inapplicability of certain penalties.
Penalties. The U.S. shareholder reduction of 10% of the foreign taxes Certain penalties under sections 6038
may have to pay a penalty if it is available for credit under sections 901 and 6662 may be waived for certain
required to disclose a reportable and 960. If the failure continues 90 persons under Rev. Proc. 2019-40.
transaction under section 6011 and days or more after the date the IRS See section 7 of Rev. Proc. 2019-40
fails to properly complete and file mails notice of the failure to the U.S. for more details.
Form 8886. Penalties may also apply person, an additional 5% reduction is
under section 6707A if the U.S. made for each 3-month period, or Other Reporting
shareholder fails to file Form 8886 fraction thereof, during which the
with its income tax return, fails to failure continues after the 90-day Requirements
provide a copy of Form 8886 to the period has expired. See section Reporting exchange rates on Form
Office of Tax Shelter Analysis (OTSA), 6038(c)(2) for limits on the amount of 5471. When translating amounts from
or files a form that fails to include all this penalty. functional currency to U.S. dollars,
the information required (or includes See Regulations sections 1.6038-1(j) you must use the method specified in
incorrect information). Other (4) and 1.6038-2(k)(3) for alleviation these instructions. For example, when
penalties, such as an of this penalty in certain cases. translating amounts to be reported on
accuracy-related penalty under Failure to file information required Schedule E, you must generally use
section 6662A, may also apply. See by section 6046 and the related the average exchange rate as defined
the Instructions for Form 8886 for regulations (Form 5471 and in section 986(a). But, regardless of
details on these and other penalties. Schedule O). Any person who fails the specific method required, all
Reportable transactions by materi- to file or report all of the information exchange rates must be reported
al advisors. Material advisors to any requested by section 6046 is subject using a “divide-by convention”
reportable transaction must disclose to a $10,000 penalty for each such rounded to at least four places. That
certain information about the failure for each reportable transaction. is, the exchange rate must be
reportable transaction by filing Form If the failure continues for more than reported in terms of the amount by
8918, Material Advisor Disclosure 90 days after the date the IRS mails which the functional currency amount
Statement, with the IRS. For details, notice of the failure, an additional must be divided in order to reflect an
see the Instructions for Form 8918. $10,000 penalty will apply for each equivalent amount of U.S. dollars. As
30-day period, or fraction thereof, such, the exchange rate must be
Reporting other foreign financial during which the failure continues reported as the units of foreign
assets. If you have other foreign after the 90-day period has expired. currency that equal one U.S. dollar,
financial assets, you may be required The additional penalty is limited to a rounded to at least four places. Do
to file Form 8938, Statement of maximum of $50,000. See section not report the exchange rate as the
Specified Foreign Financial Assets. 6679. number of U.S. dollars that equal one
However, you are not required to unit of foreign currency.
report any items otherwise reported Criminal penalties. Criminal
on Form 5471 on that form. See the penalties under sections 7203, 7206, Note. You must round the result to
Instructions for Form 8938 for more and 7207 may apply for failure to file more than four places if failure to do
information. the information required by sections so would materially distort the
6038 and 6046. exchange rate or the equivalent
amount of U.S. dollars.
Penalties Note. Any person required to file
Example. During its annual
Form 5471 and Schedule J, M, or O
accounting period, the foreign
Failure to file information required who agrees to have another person
corporation paid income taxes of
by section 6038(a) (Form 5471 and file the form and schedules for them
30,255,400 Yen to Japan. The
Schedule M). may be subject to the above penalties
Schedule E instructions specify that
• A $10,000 penalty is imposed for if the other person does not file a
the foreign corporation must translate
each annual accounting period of correct and proper form and schedule.
each foreign corporation for failure to these amounts into U.S. dollars at the
furnish the information required by average exchange rate for the tax year

8 Instructions for Form 5471 (Rev. 01-2024)

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to which the tax relates in accordance Specifications for Substitute Forms 362(e)(2)(C) to limit the transferor's
with the rules of section 986(a). The and Schedules, which reprints the basis in the stock received instead of
average exchange rate is 108.8593 most recent applicable revenue the transferee's basis in the
Japanese Yen to one U.S. dollar or procedure. Pub. 1167 is available at transferred property. The election is
(0.009184) U.S. dollar to one IRS.gov/Pub. 1167. made by a statement as provided in
Japanese Yen. The foreign Regulations section 1.362-4(d)(3).
corporation divides 30,255,400 Yen by Dormant Foreign Corporations
108.8593 to determine the U.S. dollar Rev. Proc. 92-70, 1992-2 C.B. 435, Do not attach the statement
amount to enter in column (l) of provides a summary filing procedure ! described above to Form
Schedule E, Part I, Section 1, line 1. for filing Form 5471 for a dormant CAUTION 5471.
Line 1 of Schedule E, Part I, Section foreign corporation (defined in section
1, is completed in relevant part as 3 of Rev. Proc. 92-70). This summary Corrections to Form 5471
follows. filing procedure will satisfy the If you file a Form 5471 that you later
• Enter the name of the payor entity in reporting requirements of sections determine is incomplete or incorrect,
column (a). 6038 and 6046. file a corrected Form 5471 with an
amended tax return, using the
• Enter the payor entity’s employer If you elect the summary amended return instructions for the
identification number (EIN) or procedure, complete only page 1 of return with which you originally filed
reference ID number in column (b). Form 5471 for each dormant foreign Form 5471. Enter “Corrected” at the
• Enter “JA” in column (d). corporation as follows. top of the form and attach a statement
•
• Enter “JPY” in column (i). The top margin of the summary identifying the changes.
• Enter “30,255,400 Yen” in column return must be labeled “Filed Pursuant
(j). to Rev. Proc. 92-70 for Dormant Foreign Disregarded Entities
• Enter “108.8593” in column (k). Foreign Corporation.” and Branches
•
• Enter “277,931” in column (l). Include filer information such as If the foreign corporation for which you
Computer-Generated Form name and address, items A through are furnishing information is the tax
5471 and Schedules C, and tax year. owner of a foreign disregarded entity
• Include corporate information such
Generally, all computer-generated (FDE) or foreign branch (FB), or a
as the dormant corporation's annual
forms must receive prior approval from partner in a partnership, the amounts
accounting period (below the title of
the IRS and are subject to an annual reported on Form 8858, Schedules
the form) and items 1a, 1b, 1c, and
review. However, see the Exception K-1 and K-3 of Form 1065, or
1d.
below. Requests for approval may be Schedules K-1 and K-3 of Form 8865
For more information, see Rev. Proc.
submitted electronically to must be included in determining the
92-70.
substituteforms@irs.gov, or requests amounts reported on Form 5471. The
may be mailed to: File this summary return in the “tax owner” of an FDE is the person
manner described under When and that is treated as owning the assets
Internal Revenue Service Where To File, earlier. and liabilities of the FDE for purposes
Attention: Substitute Forms of U.S. income tax law.
Program Treaty-Based Return Positions
SE:W:CAR:MP:P:TP You are generally required to file Form Specific Instructions
1111 Constitution Ave. NW 8833, Treaty-Based Return Position
Room 6554 Disclosure Under Section 6114 or Important. If the information required
Washington, DC 20224 7701(b), to disclose a return position in a given section exceeds the space
that any treaty of the United States provided within that section, do not
Exception. If a computer-generated (such as an income tax treaty; an enter “See attached” in the section
Form 5471 and its schedules conform estate and gift tax treaty; or a and then attach all of the information
to and do not deviate from the official friendship, commerce, and navigation on additional sheets. Instead,
form and schedules, they may be filed treaty): complete all entry spaces in the
without prior approval from the IRS. • Overrides or modifies any provision section and attach the remaining
of the Internal Revenue Code; and information on additional sheets. The
Important. Be sure to attach the • Causes, or potentially causes, a additional sheets must conform with
approval letter to Form 5471. reduction of any tax incurred at any the IRS version of that section.
However, if the computer-generated time.
form is identical to the IRS-prescribed Identifying Information
See Form 8833 for exceptions.
form, it does not need to go through
Annual Accounting Period
the approval process, and an Failure to make a required
attachment is not necessary. disclosure may result in a $1,000 Enter, in the space provided below the
penalty ($10,000 for a C corporation). title of Form 5471, the annual
Every year, the IRS issues a See section 6712. accounting period of the foreign
revenue procedure to provide corporation for which you are
guidance for filers of Section 362(e)(2)(C) Elections furnishing information. Except for
computer-generated forms. In The transferor and transferee in information contained on Schedule O,
addition, every year, the IRS issues certain section 351 transactions may report information for the tax year of
Pub. 1167, General Rules and make a joint election under section the foreign corporation that ends with

Instructions for Form 5471 (Rev. 01-2024) 9

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or within your tax year. When filing has a P.O. box, show the box number information, see the Instructions for
Schedule O, report acquisitions, instead. Form 8938, generally, and in
dispositions, and organizations or particular, Duplicative Reporting and
Foreign address. Enter the
reorganizations that occurred during the specific instructions for Part IV,
information in the following order: city,
your tax year. Excepted Specified Foreign Financial
province or state, and country. Follow
Assets.
Section 898 specified foreign cor- the country's practice for entering the
poration (SFC). The annual postal code, if any. Do not abbreviate Item F—Alternative Information
accounting period of an SFC (as the country name. Under Rev. Proc. 2019-40
defined in section 898) is generally
required to be the tax year of the Item A—Identifying Number Check the item F checkbox if Form
corporation's majority U.S. The identifying number of an 5471 has been completed using
shareholder. If there is more than one individual is his or her social security alternative information (as defined in
majority shareholder, the required tax number (SSN). The identifying section 3.01 of Rev. Proc. 2019-40).
year will be the tax year that results in number of all others is their EIN. If a Section 5 of Rev. Proc. 2019-40
the least aggregate deferral of income U.S. corporation that owns stock in a provides a safe harbor for determining
to all U.S. shareholders of the foreign foreign corporation is a member of a certain items, including taxable
corporation. consolidated group, list the common income and E&P, of certain CFCs
parent as the person filing the return
For these purposes, section 898(b) based on alternative information.
and enter its EIN in item A.
defines an SFC as any foreign Specifically, in the case of a
corporation: Item B—Category of Filer foreign-controlled CFC with respect to
which there is no related section
1. That is treated as a CFC for any Complete item B to indicate the 958(a) U.S. shareholder, if information
purpose under subpart F, and category or categories that describe satisfying the requirements of
2. In which more than 50% of the the person filing this return. If more Regulations section 1.952-2(a), (b),
total voting power or value of all than one category applies, check all and (c)(2) and section 964 and the
classes of stock of the corporation is boxes that apply. See Categories of regulations thereunder is not readily
treated as owned by a U.S. Filers, earlier. available to an unrelated section
shareholder. 958(a) U.S. shareholder or an
Note. If you satisfy the requirements
For more information, see section of both Category 4 and Category 5a unrelated constructive U.S.
898 and Rev. Proc. 2006-45, 2006-45 filers, only check the box for Category shareholder with respect to the
I.R.B. 851, available at IRS.gov/irb/ 4 and leave the box for Category 5a foreign-controlled CFC, an amount
2006-45_IRB#RP-2006-45, as blank. reported on a Form 5471 may be
modified by Rev. Proc. 2007-64, determined by the unrelated section
2007-42 I.R.B. 818, available at Item C—Percentage of Voting 958(a) U.S. shareholder or the
IRS.gov/irb/ Stock Owned unrelated constructive U.S.
2007-42_IRB#RP-2007-64. Enter the total percentage of the shareholder, as applicable, on the
foreign corporation's voting power you basis of alternative information
Name of Person Filing This owned directly, indirectly, or (without adjustments other than those
Return constructively at the end of the described in section 3.01(b) and 3.10
The name of the person filing Form corporation's annual accounting of the revenue procedure) with
5471 is generally the name of the U.S. period. respect to the foreign-controlled CFC.
person described in the applicable See section 3 of Rev. Proc. 2019-40
category or categories of filers (see Item D—Final Year for definitions of terms.
Categories of Filers, earlier). However, Check the item D checkbox only if this Section 6 of Rev. Proc. 2019-40
in the case of a consolidated return, is the final year of the foreign provides a safe harbor for determining
enter the name of the U.S. parent in corporation's existence as a certain items of certain SFCs based
the field for “Name of person filing this corporation for federal tax purposes, on alternative information. Specifically,
return.” Be sure to list each U.S. for example, if a reorganization has in the case of an SFC, other than
shareholder of the foreign corporation occurred, a complete liquidation has either a foreign-controlled CFC with
in Schedule B, Part I. occurred, or an election to treat the respect to which there is no related
foreign corporation as a disregarded section 958(a) U.S. shareholder or a
Name change. If the name of either entity has been made. If this item D is U.S. controlled CFC, if information
the person filing the return or the checked, complete Schedule O. satisfying the requirements of section
corporation whose activities are being
reported changed within the past 3 Item E—Excepted Specified 964 and the regulations thereunder is
years, show the prior name(s) in Foreign Financial Assets not readily available to an unrelated
section 958(a) U.S. shareholder or an
parentheses after the current name. Check the item E checkbox if any unrelated constructive U.S.
Address excepted specified foreign financial shareholder with respect to the SFC,
assets are reported on Form 5471. If
Include the suite, room, or other unit an amount reported on a Form 5471
this is the case, you do not have to
number after the street address. If the may be determined by the unrelated
also report these assets on Form
post office does not deliver mail to the section 958(a) U.S. shareholder or the
8938. It is only necessary to complete
street address and the U.S. person unrelated constructive U.S.
Form 8938, Part IV, line 17. For more shareholder, as applicable, on the
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basis of alternative information Item H—Person(s) on Whose Exception. If the person who is filing
(without adjustments other than those Behalf This Information Return Form 5471 on behalf of others is
described in sections 3.01(b) and Is Filed married to a person identified in item
3.10 of the revenue procedure) with H and they are filing Form 1040 jointly,
respect to the SFC. See section 3 of One person may file Form 5471 and
Rev. Proc. 2019-40 for definitions of the applicable schedules for other the statement described above does
terms. persons who have the same filing not have to be attached to the jointly
requirements. See Multiple filers of filed Form 1040.
Item G—Alternative Information same information, earlier. The person All persons identified in item H
Code that files the required information on ! must complete a separate
If the item F checkbox is checked, behalf of other persons must CAUTION Schedule P (Form 5471) if the
enter the applicable code from the list complete a joint Form 5471 according person is a U.S. shareholder
provided below. to the applicable column(s) of the described in Category 1a, 1b, 4, 5a, or
Filing Requirements for Categories of 5b. In such a case, the Schedule P
Audited separate-entity financial Filers, earlier. This includes must be attached to the statement
statements of the foreign corporation that completing item H on page 1 of the described above.
01 are prepared in accordance with U.S. form. When completing item H with
generally accepted accounting principles respect to members of a consolidated Item 1b(2)—Reference ID
(U.S. GAAP). group, identify only the direct owners Number
Audited separate-entity financial in item H (constructive owners are not
A reference ID number (defined
statements of the foreign corporation that required to be listed).
02 below) is required in item 1b(2) only in
are prepared on the basis of international A separate Schedule I must be filed cases where no EIN was entered in
financial reporting standards (IFRS).
for each person described in Category item 1b(1) for the foreign corporation.
Audited separate-entity financial 4, 5a, or 5b. For each Category 4, 5a, However, filers are permitted to enter
statements of the foreign corporation that or 5b filer that is required to file a both an EIN in item 1b(1) and a
are prepared on the basis of the generally Schedule I, send a copy of their reference ID number in item 1b(2). If
03 accepted accounting principles of the
jurisdiction in which the foreign separate Schedule I to them to assist applicable, enter the reference ID
corporation is organized (“local-country them in completing their tax return. number you have assigned to the
foreign corporation identified in item
GAAP”). A separate Worksheet H-1 must be
1a.
Unaudited separate-entity financial attached for each person described in
statements of the foreign corporation that
04 Category 4, 5a, 5b, or 5c. For each A “reference ID number” is a
are prepared in accordance with U.S. Category 4, 5a, 5b, or 5c filer that is number established by or on behalf of
GAAP. required to file Worksheet H-1, send a the U.S. person identified at the top of
Unaudited separate-entity financial copy of their separate Worksheet H-1 page 1 of the form that is assigned to
05 statements of the foreign corporation that to them to assist them in completing a foreign corporation with respect to
are prepared on the basis of IFRS. their tax return. which Form 5471 reporting is
Unaudited separate-entity financial required. These numbers are used to
statements of the foreign corporation that Note. New Worksheet H-1 may be uniquely identify the foreign
are prepared on the basis of local-country
06 found later in these instructions. See corporation in order to keep track of
GAAP. Worksheet H-1 and Worksheet H-1 the corporation from tax year to tax
Separate-entity records used by the Instructions, later. year.
07
foreign corporation for tax reporting. Filing requirements for persons The reference ID number must
Separate-entity records used by the identified in item H. Except for meet the requirements set forth below.
foreign corporation for internal members of the filer's consolidated
08
management controls or regulatory or return group, all persons identified in Note. Because reference ID numbers
other similar purposes. item H must attach a statement to are established by or on behalf of the
their tax returns that includes the U.S. person filing Form 5471, there is
following information. no need to apply to the IRS to request
Information described in a code • The name, address, and EIN (or a reference ID number or for
listed above qualifies as alternative reference ID number) of the foreign permission to use these numbers.
information only if information corporation(s).
described in any preceding code is • A statement that their filing Note. The reference ID number
not “readily available” (as defined in requirements with respect to the assigned to a foreign corporation on
section 3.04 of Rev. Proc. 2019-40). foreign corporation(s) have been or Form 5471 generally has relevance
For example, information described in will be satisfied. only on Form 5471, its schedules, and
code 03 above qualifies as alternative • The name, address, and identifying any other form that is attached to or
information only if information number of the taxpayer on the return associated with Form 5471, and
described in codes 01 and 02 is not with which the information was or will generally should not be used with
readily available. be filed. respect to that foreign corporation on
• The IRS Service Center where the any other IRS forms. However, the
For more information, see Rev. return was or will be filed. If the return foreign corporation’s reference ID
Proc. 2019-40. 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

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listed as a tax owner of an FDE or FB foreign corporation to have an EIN for standard. These codes are available
on Form 8858. See the instructions for this election. For the first year that at six-group.com/en/products-
Form 8858, line 3c(2), for more Form 5471 is filed after an entity services/financial-information/data-
information. Also, if a U.S. shareholder classification election is made on standards.html#scrollTo=currency-
is required to file Schedule A (Form behalf of the foreign corporation on 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)
respect to the CFC, the reference ID entered in item 1b(1) of Form 5471
and 1.6046-1(g) require that certain
number on Form 5471 and the and the old reference ID number must
amounts be reported in U.S. dollars
reference ID number used on be entered in item 1b(2). In
and/or in the foreign corporation's
Schedule A (Form 8992) or subsequent years, the Form 5471 filer
functional currency. The specific
Schedule B (Form 8992) for that CFC may continue to enter both the EIN in
instructions for the affected schedules
must be the same. item 1b(1) and the reference ID
state these requirements.
number in item 1b(2), but must enter
Requirements. The reference ID
at least the EIN in item 1b(1).
number that is entered in item 1b(2) Special rules apply for foreign
must be alphanumeric (defined below) You must correlate the reference ID corporations that use the U.S. dollar
and no special characters or spaces numbers as follows: Enter the new approximate separate transactions
are permitted. The length of a given reference ID number in item 1b(2) and method of accounting (DASTM) under
reference ID number is limited to 50 enter the previous reference ID Regulations section 1.985-3. See
characters. number(s) in item 1b(3). If there is Schedule C Schedule F, , and
more than one old reference ID Schedule H, later.
The same reference ID number
number, you must enter a space
must be used consistently from tax
between each such number. As
year to tax year with respect to a given Schedule B
indicated above, the length of a given
foreign corporation. If for any reason a Note. If any person (including the
reference ID number is limited to 50
reference ID number falls out of use filer) is both a U.S. shareholder and a
characters and each number must be
(for example, the foreign corporation direct shareholder of the foreign
alphanumeric and no special
no longer exists due to disposition or corporation, that person’s information
characters are permitted.
liquidation), the reference ID number should be provided in both
used for that foreign corporation Note. This correlation requirement Schedule B, Part I and Part II.
cannot be used again for another applies only to the first year the new Part I
foreign corporation for purposes of reference ID number is used and it
Category 3 and 4 filers must complete
Form 5471 reporting. applies only on Form 5471, page 1,
Schedule B, Part I, for U.S. persons
For these purposes, the term items 1b(2) and 1b(3). On all separate
that owned (at any time during the
“alphanumeric” means the entry can schedules for Form 5471, please
annual accounting period), directly or
be alphabetical, numeric, or any enter only the current reference ID
indirectly through foreign entities, 10%
combination of the two. number in the applicable entry space.
or more of the total combined voting
Taxpayers no longer have the Item 1b(3)—Previous Reference power of all classes of stock entitled
option of entering “FOREIGNUS” or to vote of the foreign corporation, or
ID Number(s), if Any
“APPLIED FOR” in a column that 10% or more of the total value of
requests an EIN or reference ID See Correlation issues, earlier.
shares of all classes of stock of the
number with respect to a foreign Items 1f and 1g—Principal foreign corporation.
entity. Instead, if the foreign entity
Business Activity
does not have an EIN, the taxpayer A person that is both a category 3
must enter a reference ID number that Enter the principal business activity and category 5 filer because it is
uniquely identifies the foreign entity. code number and the description of treated as a U.S. shareholder under
the activity from the list at the end of section 953(c)(1)(A) with respect to
Correlation issues. There are some these instructions. the foreign corporation must complete
situations that warrant correlation of a Schedule B, Part I, for U.S. persons
new reference ID number with a Effective beginning with tax
that owned (on the last day of the
previous reference ID number when ! year 2022, several changes foreign corporation’s tax year), directly
assigning a new reference ID number CAUTION were made to the principal
to a foreign corporation. For example: business activities and codes listed at or indirectly through foreign entities,
• In the case of a merger or the end of these instructions. See the any of the foreign corporation's
acquisition, a Form 5471 filer must revised list before entering a six-digit outstanding stock.
use a reference ID number that code and the description of the Column (e). Enter each
correlates the previous reference ID activity on page 1, items 1f and 1g. shareholder's allocable percentage of
number with the new reference ID the foreign corporation's subpart F
number assigned to the foreign Item 1h—Functional Currency income.
corporation; or The foreign corporation's functional Part II
• In the case of an entity currency is determined under section
classification election that is made on 985. Enter the applicable Category 1a, 1c, 3, 4, 5a, and 5c filers
behalf of a foreign corporation on three-character alphabet code for the must complete Part II.
Form 8832, Regulations section foreign corporation's functional Report the direct shareholders of
301.6109-1(b)(2)(v) requires the currency using the ISO 4217 the foreign corporation. In the case of
12 Instructions for Form 5471 (Rev. 01-2024)

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a CFC owned by an FDE, please Line 20. The term “unusual or tax expense (benefit) reported on
include the information of the FDE and infrequently occurring items” is line 21 and the amount of taxes that
the regarded entity owner. Indicate the defined by U.S. GAAP (see FASB reduce or increase U.S. E&P should
regarded entity owner's name in Accounting Standards Codification be accounted for on line 2g of
parentheses after the FDE's name. If (ASC) Topic 220 (Income Statement), Schedule H.
there is more than one regarded entity Subtopic 220-20 (Unusual or
owner, use separate lines for each, Infrequently Occurring Items) or Schedule F
listing each regarded entity owner in subsequent guidance). If “prior period
Report all information in U.S. dollars.
column (a) and reporting the adjustments” are not reported
Generally, the foreign corporation's
information requested in columns (b), separately on the income statement,
balance sheet is prepared in
(c), and (d) for each such regarded do not report such amounts on this
functional currency and translated to
entity owner. line item (see ASC 250 (Accounting
U.S. dollars using U.S. GAAP
Category 4 filers should list all Changes and Error Corrections) or
translation rules. If the foreign
direct owners of the CFC. Category subsequent guidance).
corporation uses DASTM, the tax
1a, 3, and 5a filers should list all direct Line 21. Enter income tax expense balance sheet on Schedule F should
owners of the SFC or CFC through (benefit) reported in accordance with be prepared and translated into U.S.
which such filer indirectly owns the U.S. GAAP (ASC 740 (Income dollars according to Regulations
SFC or CFC as described in section Taxes)). Income tax expense (benefit) section 1.985-3(d), rather than U.S.
958(a)(2). Category 1c and 5c filers includes current and deferred income GAAP.
should list all direct owners of the SFC tax expense (benefit). It may also
Lines 3 and 17. Enter the total asset
or CFC from which such filer is reflect uncertain tax positions (ASC
amount of derivatives on line 3 and
attributed ownership in the SFC or 740-10) and would not include taxes
total amount of liability on line 17
CFC as described in section 958(b). If paid in respect of uncertain tax
reported in accordance with ASC 815
the filer is a direct owner, include the positions recorded in prior years.
(Derivatives and Hedging). Do not net
filer's direct ownership. Enter the current income tax expense
positions.
(benefit) on line 21a and deferred
income tax expense (benefit) on Include all derivatives, both
Schedule C short-term and long-term.
line 21b.
Report all information in the foreign
corporation's functional currency in Note. If there is an income tax
accordance with U.S. GAAP and expense amount on line 21a or 21b, Schedule G
translate using U.S. GAAP translation subtract that amount from the line 19 Note. Category 1b and 5b filers are
principles. net income or (loss) amount in arriving not required to file Schedule G for
If the foreign corporation uses the at line 22 current year net income or foreign-controlled section 965 SFCs
DASTM under Regulations section (loss) per the books. If there is an and foreign-controlled CFCs,
1.985-3, the functional currency income tax benefit amount on line 21a respectively.
column should reflect local or 21b, add that amount to the line 19 Question 1
hyperinflationary currency amounts net income or (loss) amount in arriving If the foreign corporation owned at
computed in accordance with U.S. at line 22 current year net income or least a 10% interest, directly or
GAAP. The U.S. dollar column should (loss) per the books. indirectly, in any foreign partnership,
reflect such amounts translated into Lines 23 and 24. Enter amounts attach a statement listing the following
dollars under U.S. GAAP translation defined in ASC 220 (Income information for each foreign
rules. Differences between this U.S. Statement—Reporting partnership.
dollar GAAP column and the U.S. Comprehensive Income). 1. Name and EIN (if any) of the
dollar income or loss figured for tax foreign partnership.
purposes under Regulations section Line 23a. Enter foreign currency
1.985-3(c) should be accounted for on translation adjustments before the 2. Identify which, if any, of the
Schedule H. See Schedule H, Special income tax expense (benefit) is following forms the foreign partnership
rules for DASTM, later. allocated. filed for its tax year ending with or
within the corporation's tax year: Form
Line 8. Enter foreign currency Line 23b. Enter other 1042, 1065, or 8804.
transaction gain or loss reported on comprehensive income such as
the income statement. For amounts foreign currency gains or losses on 3. Name of the partnership
included in Other Comprehensive certain hedging transactions, representative (if any).
Income (OCI), see Lines 23 and 24, pensions and other post-retirement 4. Beginning and ending dates of
later. Enter unrealized gain or loss on benefits, and certain investments the foreign partnership's tax year.
line 8a and realized gain or loss on available-for-sale.
Question 3
line 8b. Line 23c. Enter the income tax Check the “Yes” box if the foreign
Line 16. Enter transactional taxes expense (benefit) allocated to OCI corporation is the tax owner of an FDE
excluding items reportable in income items in the intraperiod allocation. or FB. The “tax owner” of an FDE is
tax expense (benefit). Report income Important. Differences between the the person that is treated as owning
taxes on line 21. functional currency amount of income

Instructions for Form 5471 (Rev. 01-2024) 13

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the assets and liabilities of the FDE for payments also include amounts currency at the average exchange rate
purposes of U.S. income tax law. received or accrued by the foreign for the foreign corporation's tax year
corporation in connection with the (see section 989(b)). See Form 8993
If the foreign corporation is the tax acquisition of depreciable or and its instructions for information on
owner of an FDE or FB and you are a amortizable property (section 59A(d) the section 250 deduction. If no
Category 4, 5a, or 5c filer of Form (2)), reinsurance payments (section deduction is being claimed, check the
5471, you are required to attach Form 59A(d)(3)), and certain payments “No” box on line 6a and go to line 7.
8858 to Form 5471. If you are required relating to expatriated entities (section
to attach Form 8858 to Form 5471, the 59A(d)(4)). Question 9a
amounts reported on certain Under section 367(d), a U.S.
schedules on Form 8858 must be The term “base erosion tax benefit” transferor must report an annual
included in determining the amounts generally means any U.S. deduction income inclusion attributed to the
reported on the equivalent schedules that is allowed under chapter 1 for the intangible property transferred to a
as follows. tax year with respect to any base foreign corporation over the useful life
erosion payment. See section 59A(c) of the property. Check “Yes” if the
IF amounts were reported THEN take those (2)(A) and (B) for further details. foreign corporation received any
on... amounts into account intangible property in a prior year or
(converting from Questions 5a and 5b
the current tax year in an exchange
GAAP to tax as If the foreign corporation paid or under section 351 or section 361 from
necessary) when
determining the accrued any interest or royalty a U.S. transferor that is required to
amounts to be (including in the case of a foreign report a section 367(d) annual income
reported on... corporation that is a partner in a inclusion for the tax year. If “Yes,”
Form 8858, Schedule C Form 5471, partnership, the foreign corporation’s complete line 9b.
Schedule C. allocable share of interest or royalty
Form 8858, Schedule F Form 5471, paid by the partnership) for which a Question 9b
Schedule F. deduction is disallowed under section Enter in functional currency the
Form 8858, Schedule H Schedule H (Form 267A, check “Yes” for question 5a and amount of the E&P reduction made by
5471). enter the total amount for which a the foreign corporation for the current
Form 8858, Schedule J Schedules E and E-1 deduction is not allowed on line 5b. tax year that equals the amount
(Form 5471). The amount reported on line 5b required to be included in the income
Schedule M (Form 8858) Schedule M (Form should not include disallowed of the U.S. transferor. See section
5471). deductions attributable to interest or 367(d). This amount should also be
royalty paid or accrued by a U.S. entered on Schedule H (Form 5471),
taxable branch of the foreign Current Earnings and Profits, as a net
If the foreign corporation is the tax corporation; such amounts are subtraction on line 2i.
owner of an FDE or FB and you are reported on Form 1120-F.
not a Category 1b, 4, or 5 filer of Form Question 10
Interest or royalty paid or accrued
5471, you must attach the statement A foreign corporation may qualify as
by a foreign corporation (including
described below in lieu of Form 8858. an expatriated foreign subsidiary
through a partnership) is subject to under Regulations section
Statement in lieu of Form 8858. section 267A, provided in general that 1.7874-12(a)(9) if such foreign
This statement must list the name of the foreign corporation is a CFC (and corporation is a CFC with respect to
the FDE or FB, country under whose there are one or more U.S. tax which an expatriated entity, as defined
laws the FDE or FB was organized, residents that own directly or indirectly in Regulations section 1.7874-12(a)
and EIN (if any) of the FDE or FB. at least 10% of the stock of the CFC). (8), is a U.S. shareholder. Certain
Section 267A disallows a deduction
Questions 4b and 4c transactions involving an expatriated
for certain interest or royalty paid or foreign subsidiary and/or its U.S.
Complete lines 4b and 4c if: accrued pursuant to a hybrid shareholders may be subject to
1. The foreign corporation is a arrangement, to the extent that, under special rules. If the answer to
related party to the U.S. filer within the the foreign tax law, there is not a Question 10 is “Yes,” attach a
meaning of section 59A(g); and corresponding income inclusion statement providing the name and
2. The U.S. filer made or accrued (including long-term deferral). For EIN of the domestic corporation or
a base erosion payment to, or has a more detailed instructions, see the partnership, as defined in Regulations
base erosion tax benefit with respect instructions for Form 1120, section 1.7874-12(a)(6), and the
to, the foreign corporation. Schedule K, Question 21. relationship of the foreign corporation
The term “base erosion payment” Question 6 to the domestic corporation or
partnership.
generally means any amount paid or Check the “Yes” box on line 6a if the
accrued by the U.S. filer to a foreign filer is claiming a deduction under Question 14
corporation that is a related party to section 250 with respect to Check the “Yes” box on line 14 if you
the U.S. filer within the meaning of foreign-derived intangible income answer “Yes” to any of the 22
section 59A(g) and with respect to (FDII), and enter the amounts questions in the Schedule G, Line 14
which a U.S. deduction is allowed requested on lines 6b, 6c, and 6d. table below. If “Yes,” enter the
under chapter 1 of the Code. See Enter U.S. dollar amounts on lines 6b, corresponding code(s) from the table
section 59A(d)(1). Base erosion 6c, and 6d, translated from functional
14 Instructions for Form 5471 (Rev. 01-2024)

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in the entry space provided on line 14          corresponding code in capital letters.               Also attach the statement described in 
of the form. Enter the applicable               Enter a space between each code.                     the table below.

Form 5471, Schedule G, Line 14

                           Question                                 See Worksheet A in  If “Yes,”            Code          If “Yes,” content of 
                                                                    the Schedule I            corresponding  description   statement to be 
                                                                    instructions              code to enter                attached to Form 
                                                                                              on Schedule G,               5471
                                                                                              line 14
1 During the tax year, was the sum of the CFC’s foreign base        In other words, is        DM             De minimis    Amount excluded by 
  company income (determined without regard to deductions)          line 7 less than line 8                                reason of the de 
  and gross insurance income less than the lesser of 5% of          and less than $1                                       minimis rule (but 
  gross income or $1 million?                                       million?                                               only to the extent not 
                                                                                                                           already included in 
                                                                                                                           amounts below)
2 During the tax year, did the CFC receive any item of income       In other words, is               HT      High tax      Sum of the amounts 
  that was subject to an effective rate of income tax imposed by a  line 13g, 14d, 15d,                                    from lines 13g, 14d, 
  foreign country greater than 90% of the maximum rate of tax       16d, 18d, or 19d of                                    15d, 16d, 18d, and 
  specified in section 11?                                          Worksheet A greater                                    19d
                                                                    than zero?  
3 During the tax year, was the CFC’s foreign personal holding       In other words, is        DED            Deductions    Sum of the amounts 
  company income, foreign base company sales income, or             line 13b, 13d, 13e,                      taken into    from lines 13b, 13d, 
  foreign base company services income reduced so as to take        14b, 15b, or 16b of                      account       13e, 14b, 15b, and 
  into account any deductions (including taxes)?                    Worksheet A greater                                    16b
                                                                    than zero?
4 During the tax year, did the CFC have any gains or losses that    In other words, are       AHC            Active/       Sum of the excluded 
  (a) arise out of commodity hedging transactions; (b) are active  any amounts                               hedging       amounts described 
  business gains or losses from the sale of commodities (and        described in section                     commodities   in section 954(c)(1)
  substantially all of the corporation’s commodities are property   954(c)(1)(C)(i), (ii), or                              (C)(i), (ii), and (iii)
  described in section 1221(a)(1), (2), or (8)); or (c) are foreign (iii) excluded from 
  currency gains or losses (as defined in section 988(b))           line 1c of Worksheet 
  attributable to any section 988 transactions?                     A? 
5 During the tax year, did the CFC have excess foreign currency     In other words, are              BN      Business      Amount excluded
  gains over foreign currency losses (as defined in section         any amounts                              needs
  988(b)) attributable to any section 988 transaction directly      excluded from line 1d 
  related to the business needs of the foreign corporation?         of Worksheet A by 
                                                                    reason of being 
                                                                    attributable to a 
                                                                    transaction(s) directly 
                                                                    related to the 
                                                                    business needs of 
                                                                    the foreign 
                                                                    corporation? 
6 During the tax year, did the CFC receive, from a person other     In other words, are       ARR            Active rents/ Amount excluded
  than a related person within the meaning of section 954(d)(3),   any amounts                               royalties
  rents or royalties that were derived in the active conduct of a   described in section 
  trade or business?                                                954(c)(2)(A) 
                                                                    excluded from line 1a 
                                                                    of Worksheet A? 
7 During the tax year, did the CFC derive, in the conduct of a      In other words, are              EF      Certain       Amount excluded
  banking business, interest that is export financing interest?     any amounts                              export 
                                                                    described in section                     financing
                                                                    954(c)(2)(B) 
                                                                    excluded from line 1a 
                                                                    of Worksheet A? 
8 During the tax year, was the CFC a regular dealer in property     In other words, are              RD      Regular       Amount excluded
  described in section 954(c)(1)(B), forward contracts, option      any amounts                              dealers
  contracts, or similar financial instruments (including notional   described in section 
  principal contracts and all instruments referenced to             954(c)(2)(C)(i) 
  commodities)?  If so, did the foreign corporation derive any      excluded from line 1a 
  item of income, gain, deduction, or loss (other than any item     of Worksheet A? 
  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? 

Instructions for Form 5471 (Rev. 01-2024)                                                                                                         15

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Form 5471, Schedule G, Line 14 (continued)

                          Question                                  See Worksheet A in  If “Yes,”           Code           If “Yes,” content 
                                                                    the Schedule I           corresponding  description    of statement to be 
                                                                    instructions             code to enter                 attached to Form 
                                                                                             on Schedule G,                5471
                                                                                             line 14
9  During the tax year, was the CFC a securities dealer within the  In other words, are             SD      Securities     Amount excluded
   meaning of section 475?  If so, did the foreign corporation      any amounts                             dealers
   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  excluded from line 1a 
   dealer?                                                          of Worksheet A? 
10 During the tax year, did the CFC receive dividends* or           In other words, are      SCDI           Same country  Amount excluded
   interest** from a related person that (a) is a corporation created  any amounts                          dividends/
   or organized under the laws of the same country under the        described in section                    interest
   laws of which the CFC is created or organized, and (b) has a     954(c)(3)(A)(i) 
   substantial part of its assets used in its trade or business     excluded from line 1a 
   located in the same foreign country?                             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     In other words, are      SCRR           Same country  Amount excluded
   that is a related person, rents or royalties* for the use of, or any amounts                             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    of Worksheet A?
   may reduce the subpart F income of the payor or another CFC).
12 During the tax year, did the CFC receive or accrue from a        In other words, are             LT      Look through   Amount excluded
   related CFC dividends, interest (including factoring income      any amounts 
   treated as income equivalent to interest for purposes of section  excluded from line 1a 
   954(c)(1)(E)), rents, or royalties* attributable or properly     of Worksheet A by 
   allocable to income of the related person which is neither       reason of the 
   subpart F income nor income treated as effectively connected     look-through rule 
   with the conduct of a trade or business in the United States?    described in section 
   *Interest, rents, or royalties (other than interest, rents, or   954(c)(6)? 
   royalties that create or increase a deficit that may reduce the 
   subpart F income of the payor or another CFC).
13 During the tax year, did the CFC derive income (either directly  In other words, are             AC      Agricultural   Amount excluded
   or through a branch or similar establishment, for example, a     any amounts                             commodities
   disregarded entity) in connection with the purchase or sale      excluded from line 3 
   from, to, or on behalf of a related person, of agricultural      of Worksheet A by 
   commodities not grown in the United States in commercially       reason of the special 
   marketable quantities?                                           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
   or through a branch or similar establishment, for example, a     any amounts that are                    manufacturing
   disregarded entity) in connection with the purchase or sale      derived in connection 
   from, to, or on behalf of a related person, of personal property 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))? 

16                                                                                           Instructions for Form 5471 (Rev. 01-2024)

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Form 5471, Schedule G, Line 14 (continued)

              Question                                            See Worksheet A in  If “Yes,”         Code         If “Yes,” content 
                                                                  the Schedule I         corresponding  description  of statement to be 
                                                                  instructions           code to enter               attached to Form 
                                                                                         on Schedule G,              5471
                                                                                         line 14
15 During the tax year, did the CFC derive income (either directly  In other words, are  SCSU           Same country  Amount excluded
   or through a branch or similar establishment, for example, a   any amounts that are                  sales/use
   disregarded entity) in connection with the purchase or sale    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     Amount excluded
   or through a branch or similar establishment, for example, a   any amounts                           manufacturing
   disregarded entity) in connection with the purchase or sale    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      reason of 
   section 1.954-3(a)(4)(ii) or (iii)?                            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      Substantial  Amount excluded
   or through a branch or similar establishment, for example, a   any amounts                           contribution
   disregarded entity) in connection with the purchase or sale    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      reason of 
   section 1.954-3(a)(4)(iv)?                                     Regulations section 
                                                                  1.954-3(a)(4)(iv)? 
18 During the tax year, did the CFC derive income through the     In other words, are           BR      Branch       Amount excluded
   conduct of any manufacturing or sales activities (including    any amounts 
   mere passage of title) through a branch or similar             excluded from line 3 
   establishment (such as a disregarded entity of the CFC) that   of Worksheet A by 
   would have been foreign base company sales income              reason of 
   described in section 954(d) except that either (a) the branch  disregarding a 
   or other similar establishment was not treated as a wholly     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 (including a 
   company sales income after the application of Regulations      disregarded entity) of 
   section 1.954-3(b)(2)(ii)(e)?                                  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      Active       Amount excluded
   in section 954(h)(2)) that derived qualified banking or        any amounts                           financing
   financing income (as defined in section 954(h)(3))?            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        In other words, are           AI      Active       Amount excluded
   company (as defined in section 953(e)(3)) that derived         any amounts                           insurance
   qualified insurance income (as defined in section 954(i)(2))?  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       In other words, is            EP      Earnings &   Excess of line 36 
   exceed the earnings and profits of such corporation?           line 36 of Worksheet                  profits      over line 37c
                                                                  A greater than                        limitation
                                                                  line 37c?  

Instructions for Form 5471 (Rev. 01-2024)                                                                                              17

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Form 5471, Schedule G, Line 14 (continued)

              Question                                                See Worksheet A in  If “Yes,”       Code          If “Yes,” content 
                                                                      the Schedule I       corresponding  description   of statement to be 
                                                                      instructions         code to enter                attached to Form 
                                                                                           on Schedule G,               5471
                                                                                           line 14
22 In determining the pro rata share of subpart F income or           In other words, is   PRS            Pro Rata      The amounts from 
   tested items of the U.S. person filing this return, was the        line 58 of Worksheet                Share         lines 58 and 59 of 
   amount of distributions by the CFC during the tax year and         A greater than zero?                              Worksheet A
   described in section 951(a)(2)(B) greater than zero?
23 Is the U.S. person filing this return relying on any exception(s),                             XX      Other         Amount excluded, 
   exclusion(s), or other provision(s) not listed above to reduce                                                       reduction amount, 
   or exclude any amounts reported or reportable as subpart F                                                           or other amount not 
   income (of or with respect to the CFC)?                                                                              reported or 
                                                                                                                        reportable

Question 15                                 of the foreign corporation such that no                 Questions 19a and 19b
For the foreign corporation’s annual        amount is treated as an extraordinary                   Complete lines 19a and 19b only if the 
accounting period with respect to           reduction amount or tiered                              filer is a domestic corporation. In 
which reporting is being made on this       extraordinary reduction amount as to                    completing these lines, do not 
Form 5471, if the foreign corporation       any U.S. shareholder of the foreign                     account for debt instruments that were 
is required to file a U.S. income tax       corporation. See Regulations section                    issued, or distributions or acquisitions 
return (for example, Form 1120-F),          1.245A-5(e)(3)(i) for further guidance                  that occurred, before April 5, 2016. 
check the “Yes” box if the foreign          regarding the election to close the tax                 See Regulations section 1.385-3(g)(3) 
corporation has interest expense            year. If the “Yes” box on line 17b has                  and 1.385-3(b)(3)(viii).
disallowed under section 163(j). If         been checked and the U.S. 
“Yes,” enter the amount from the            shareholder filing the Form 5471 is a                   Question 19a
current year Form 8990, line 31.            controlling section 245A shareholder                    Check the “Yes” box if the filer issued 
                                            of the foreign corporation, the U.S.                    a covered debt instrument in any of 
Question 16                                 shareholder filing this Form 5471 must                  the transactions described in 
For the foreign corporation’s annual        attach an Elective Section 245A                         Regulations section 1.385-3(b)(2) with 
accounting period with respect to           Year-Closing Statement pursuant to                      respect to the foreign corporation 
which reporting is being made on this       Regulations section 1.245A-5(e)(3)(i)                   during the tax year. Also check the 
Form 5471, if the foreign corporation       (C) containing the information                          “Yes” box if the filer issued or 
is required to file a U.S. income tax       required under Regulations section                      refinanced indebtedness owed to a 
return (for example, Form 1120-F),          1.245A-5(e)(3)(i)(D).                                   foreign corporation during the 36 
check the “Yes” box if the foreign          Question 18a                                            months before or after the date of a 
corporation has previously disallowed                                                               distribution or acquisition described in 
interest expense under section 163(j)       Check the “Yes” box if during the tax                   Regulations section 1.385-3(b)(3)(i) 
carried forward to the current tax year.    year the filer had any loans to or from                 made by the filer, and either the 
If “Yes,” enter the amount from the         the foreign corporation to which the                    issuance or refinance of 
prior year Form 8990, line 31.              safe-haven rate rules of Regulations                    indebtedness, or the distribution or 
                                            section 1.482-2(a)(2)(iii)(B) are                       acquisition, occurred during the tax 
Question 17a                                applicable, and for which the filer used                year. Otherwise, check “No.” Apply 
Check the “Yes” box on line 17a if          a rate of interest within the relevant                  Regulations section 1.385-3(b)(3)(iii)
there was an extraordinary reduction        safe-haven range of Regulations                         (E) to determine when a debt 
with respect to any controlling section     section 1.482-2(a)(2)(iii)(B)(1) (100%                  instrument is treated as issued for 
245A shareholder of the foreign             to 130% of the applicable federal rate                  purposes of Regulations section 
corporation, as defined in Regulations      for the relevant term).                                 1.385-3(b)(3)(iii). Apply Regulations 
section 1.245A-5(i)(2), during the tax      Question 18b                                            section 1.385-3(f) in the case of a 
year of the foreign corporation. See                                                                controlled partnership within the 
Regulations section 1.245A-5(e)(2)(i)       Check the “Yes” box if during the tax 
                                                                                                    meaning of Regulations section 
for the definition of extraordinary         year the filer had any loans to or from 
                                                                                                    1.385-1(c)(1).
reduction.                                  the foreign corporation to which the 
                                            safe-haven rate rules of Regulations                     Debt that the filer treats as stock 
Question 17b                                section 1.482-2(a)(2)(iii)(B) are                       pursuant to Regulations section 
If the answer to the question on            applicable, and for which the filer used                1.385-3 should still be included when 
line 17a was “Yes,” complete the            a rate of interest outside the relevant                 completing line 19a.
question on line 17b. Check the “Yes”       safe-haven range of Regulations 
box on line 17b if any controlling          section 1.482-2(a)(2)(iii)(B)(1) (100%                  Question 19b
section 245A shareholder (as defined        to 130% of the applicable federal rate                  Provide the total amount of the 
in Regulations section 1.245A-5(i)(2))      for the relevant term).                                 transactions described in Regulations 
made an election to close the tax year                                                              section 1.385-3(b)(2) (as measured 
                                                                                                    by the fair market value (FMV) of the 
18                                                                                         Instructions for Form 5471 (Rev. 01-2024)

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distribution or, as the case may be, Line 1a Lines 1e Through 1h
the property exchanged for the debt Corporate U.S. shareholders should Enter on lines 1e through 1h the
instrument), and of the distributions enter the foreign-source portion of any amounts from Worksheet A, lines 63,
and/or acquisitions described in subpart F income inclusions 65, 67, and 69, respectively. However,
Regulations section 1.385-3(b)(3)(i) attributable to the sale or exchange by corporate U.S. shareholders should
(as measured by the FMV of the a CFC of stock of another foreign report on line 1e the amount from
property distributed and/or acquired). corporation that is eligible for the Worksheet A, line 63, less the
Provide the total amount (as section 245A dividends received amount, if any, reported on line 1a.
measured by issue price in the case of deduction pursuant to section 964(e)
Use Worksheet A to compute the
an instrument treated as stock upon (4). Include the amount, if any, that is
U.S. shareholder's pro rata share of
issuance, or adjusted issue price in not eligible for the section 245A
subpart F income of the CFC, which is
the case of an instrument deemed dividends received deduction
reportable on lines 1e through 1h. Do
exchanged for stock) of the debt pursuant to section 964(e)(4) on
not include any income includible on
instrument issuances addressed by line 1e. Noncorporate U.S.
Form 5471, Schedule I, lines 1a
line 19a. See Regulations sections shareholders should leave line 1a
through 1d, or any income includible
1.385-1(d)(1) and 1.385-3(d). The blank.
under section 951A (Schedule I-1 is
adjusted issue price of a debt Line 1b used to provide information relating to
instrument is the issue price increased section 951A). Subpart F income
by the amount of original issue Enter the amount of the U.S.
discount previously includible in gross shareholder’s subpart F income reportable on lines 1e through 1h
income of any holder and decreased inclusion attributable to tiered hybrid includes the following.
by payments other than payments of dividends received by the CFC. In • Adjusted net foreign base company
stated interest. See section 1272(a) general, a dividend received by a CFC income (Worksheet A, lines 1 through
(4) and Regulations section from another CFC is a tiered hybrid 17).
1.1275-1(b)(1). dividend to the extent of the sum of • Adjusted net insurance income
the receiving CFC's hybrid deduction (Worksheet A, line 18).
accounts with respect to shares of • Adjusted net related person
Schedule I stock of the CFC that pays the insurance income (Worksheet A,
Use Schedule I to report in U.S. dividend. As to a domestic line 19).
dollars the U.S. shareholder's pro rata corporation that is a U.S. shareholder • International boycott income
share of income from the foreign with respect to both CFCs, the tiered (Worksheet A, line 20).
corporation reportable under subpart hybrid dividend is treated as subpart F • Illegal bribes, kickbacks, and other
F and other income realized from a income of the receiving CFC, and the payments (Worksheet A, line 21).
corporate distribution. U.S. shareholder must include in its • Income described in section 952(a)
gross income its pro rata share of the (5) (Worksheet A, line 22).
Certain filers may be able to use tiered hybrid dividend. See section
alternative information (as defined in 245A(e)(2) and Regulations section Important. If the subpart F income of
section 3.01 of Rev. Proc. 2019-40) to 1.245A(e)-1(c) for additional a CFC for any tax year was reduced
determine certain amounts in this information about tiered hybrid because of the current E&P limitation,
schedule. See Item F—Alternative dividends. any excess of the E&P of the CFC for
Information Under Rev. Proc. any subsequent tax year over the
2019-40, earlier, for more details. Line 1c subpart F income of the CFC for the
Enter the U.S. shareholder's subpart F tax year must be recharacterized as
Note. A separate Schedule I must be income inclusion attributable to tiered subpart F income. As a result, if the
filed by or for each Category 4, 5a, or extraordinary disposition amounts foreign corporation has E&P for the
5b U.S. shareholder of the foreign resulting from distributions from an tax period covered by this return that
corporation with respect to which extraordinary disposition account of is subject to recapture as a result of a
reporting is furnished on this Form the shareholder filing this Form 5471 prior-year E&P limitation, add the U.S.
5471. and received by the foreign shareholder's pro rata share of such
Line 1 corporation. See Regulations section recapture amount to the result from
1.245A-5(d) for further guidance on Worksheet A, line 69, and include the
Subpart F income. U.S. tiered extraordinary disposition combined amount on line 1h (Other
shareholders of CFCs with subpart F amounts. subpart F income). See Line 37.
income must report that income on Current E&P limitation, later, for a
their tax returns. For more information, Line 1d discussion of the current year E&P
see sections 245A, 951, 952, and Enter the U.S. shareholder's subpart F limitation. See also Regulations
964(e). income inclusion attributable to tiered section 1.952-1(f) for further guidance
extraordinary reduction amounts on recharacterization of E&P as
Note. Certain current year deficits of resulting from extraordinary subpart F income.
a member of the same chain of reductions. See Regulations section
corporations may be considered in 1.245A-5(f) for further guidance on Line 2
determining subpart F income. See tiered extraordinary reduction Report on line 2 the section 956
section 952(c)(1)(C). amounts. amount with respect to the U.S.

Instructions for Form 5471 (Rev. 01-2024) 19

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shareholder. See Worksheet B, Line 5b line of other corporate income tax
line 19. Enter the amount of the dividends returns.
Line 3 received by the shareholder from the Line 6
foreign corporation that is an
Reserved for future use. If previously taxed E&P (PTEP) were
extraordinary disposition amount. See
distributed, enter the amount of
Line 4 Regulations section 1.245A-5(c) for
foreign currency gain or (loss)
Enter the U.S. shareholder's pro rata rules for calculating an extraordinary
recognized on the distribution,
share of the factoring income (as disposition amount.
computed under section 986(c). See
defined in section 864(d)(1)) if no Notice 88-71, 1988-2 C.B. 374, for
subpart F income is reported on Note. The corporate U.S.
line 1a of Worksheet A, because of shareholder should include the line 5b rules for computing section 986(c)
the operation of the de minimis rule amount on Form 1120, Schedule C, gain or (loss), and Regulations section
(see lines 1a and 10 of Worksheet A line 14, column (a), or the comparable 1.986(c)-1(a) and (b) for rules for
and the related instructions under line of other corporate income tax computing section 986(c) gain or
Line 1a and Line 10. De minimis rule, returns. (loss) recognized with respect to
distributions of PTEP within the
later). Line 5c reclassified section 965(a) PTEP
Enter the amount of the dividends group and the section 965(a) PTEP
Reporting Amounts on Lines 1 received by the shareholder from the group. Do not include any foreign
Through 4 on Your Income Tax foreign corporation that is an currency gain or loss with respect to
Return extraordinary reduction amount. See PTEP within the reclassified section
Regulations section 1.245A-5(e) for 965(b) PTEP group or the section
For a corporate shareholder, enter the rules for calculating an extraordinary 965(b) PTEP group. See Regulations
result from line 1a on Form 1120, reduction amount. section 1.986(c)-1(c).
Schedule C, line 16a; enter the result
from line 1b on Form 1120, Note. The corporate U.S. For a corporate U.S. shareholder,
Schedule C, line 16b; and enter the shareholder should include the line 5c include the gain or (loss) as “Other
remaining lines 1c through 1h, 2, and amount on Form 1120, Schedule C, income” on Form 1120, line 10, or on
4 on Form 1120, Schedule C, line 16c; line 14, column (a), or the comparable the comparable line of other corporate
or on the comparable line of other line of other corporate income tax tax returns. For a noncorporate U.S.
corporate tax returns. For a returns. shareholder, include the result as
“other income” on Schedule 1 (Form
noncorporate U.S. shareholder, enter Line 5d 1040), line 8z (other income), or on
the results on Schedule 1 (Form
1040), line 8n (other income - section Enter the amount of hybrid dividends the comparable line of other
951(a) inclusion), or on the received by the U.S. shareholder from noncorporate tax returns.
comparable line of other noncorporate the foreign corporation. In general, in
Line 8a
tax returns. the case of a domestic corporation
that is a U.S. shareholder with respect Check the “Yes” box on line 8a if the
Line 5a to a CFC, a dividend received by the U.S. shareholder completing this form
Enter the amount of dividends domestic corporation from the CFC is had an extraordinary disposition
received by the shareholder from the a hybrid dividend to the extent of the account with respect to the foreign
foreign corporation that is eligible for a sum of the U.S. shareholder’s hybrid corporation having a balance greater
deduction under section 245A. This deduction accounts with respect to than zero at any time during the tax
amount does not include the amount shares of stock of the CFC. See year of the foreign corporation. See
of dividends that are not eligible for a section 245A(e) and Regulations Regulations section 1.245A-5(c) for
deduction under section 245A and are section 1.245A(e)-1(b) for additional rules regarding an extraordinary
instead entered on lines 5b, 5c, and information about hybrid dividends. disposition account.
5d. See section 245A for guidance on Line 8b
computing the amount of a dividend Note. The corporate U.S.
eligible for a deduction. shareholder should include the line 5d If “Yes” is checked on line 8a, enter on
amount on Form 1120, Schedule C, line 8b the U.S. shareholder’s
Note. The corporate U.S. line 14, column (a), or the comparable extraordinary disposition account
shareholder should include the line 5a line of other corporate income tax balance at the beginning and end of
amount on Form 1120, Schedule C, returns. the foreign corporation’s tax year.
Attach a statement detailing any
line 13, column (a), or the comparable Line 5e differences between the starting and
line of other corporate income tax
returns. In doing so, the corporate Enter on line 5e dividends not ending balance of the extraordinary
U.S. shareholder must determine reported on line 5a, 5b, 5c, or 5d. disposition account reported on
line 8b.
whether it meets the statutory and Note. The corporate U.S.
regulatory requirements for the shareholder should include the line 5e Line 8c
section 245A dividends received amount on Form 1120, Schedule C, Enter on line 8c the CFC’s total
deduction. line 14, column (a), or the comparable extraordinary disposition account
balance with respect to all U.S
shareholders of the CFC at the
20 Instructions for Form 5471 (Rev. 01-2024)

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beginning of the CFC year and at the    CFC all the stock of which is owned        CFC under a foreign tax law with 
end of the CFC tax year. Attach a       by the filer, then line 9 must reflect the respect to equity (such as a notional 
statement detailing any differences     sum of the filer’s hybrid deduction        interest deduction). See Regulations 
between the starting and ending         accounts with respect to shares of         section 1.245A(e)-1(d) for additional 
balances reported on line 8c.           stock of the upper-tier CFC; if instead    information about hybrid deduction 
                                        the CFC is a lower-tier CFC all the        accounts.
Line 9                                  stock of which is owned by the filer 
                                                                                   A domestic corporation that is a 
If the foreign corporation is a CFC and through an upper-tier CFC, then line 9 
                                                                                   U.S. shareholder with respect to a 
the filer is a domestic corporation,    must reflect the sum of the upper-tier 
                                                                                   CFC must maintain a hybrid deduction 
enter on line 9 the sum of the hybrid   CFC’s hybrid deduction accounts with 
                                                                                   account with respect to each share of 
deduction accounts with respect to      respect to shares of stock of the 
                                                                                   stock of the CFC that the domestic 
each share of stock of the CFC that     lower-tier CFC.
the domestic corporation owns                                                      corporation owns directly or indirectly 
directly or indirectly (within the        A hybrid deduction account with          through a partnership, trust, or estate. 
meaning of section 958(a)(2), and       respect to a share of stock of a CFC       In addition, certain upper-tier CFCs 
determined by treating a domestic       reflects the amount of hybrid              must maintain a hybrid deduction 
partnership as foreign). The reported   deductions of the CFC that has been        account with respect to each share of 
amount should reflect the balance of    allocated to the share. In general, a      the stock of a lower-tier CFC that the 
the hybrid deduction accounts as of     hybrid deduction is a deduction or         upper-tier CFC owns directly or 
the close of the tax year of the CFC,   other tax benefit allowed to the CFC       indirectly through a partnership, trust, 
and after all adjustments to the hybrid (or a related person) under a foreign      or estate. See Regulations section 
deduction accounts for the tax year     tax law for an amount paid, accrued,       1.245A(e)-1(d) for more on 
(for example, to reflect hybrid         or distributed with respect to an          maintenance of hybrid deduction 
deductions of the CFC, or hybrid        instrument of the CFC that is stock for    accounts.
dividends paid by the CFC). For         U.S. tax purposes. A hybrid deduction 
example, if the CFC is an upper-tier    includes a deduction allowed to the 

Instructions for Form 5471 (Rev. 01-2024)                                                                                21

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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
   c  Excess of gains over losses from commodity transactions (section 954(c)(1)(C))       1c
   d  Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D)) 1d
   e  Income equivalent to interest (section 954(c)(1)(E))                                 1e
   f  Net income from a notional principal contract (section 954(c)(1)(F))                 1f
   g  Payments in lieu of dividends (section 954(c)(1)(G))                                 1g
   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  Gross foreign personal holding company income. Add lines 1a through 1i                                      2
   3  Gross foreign base company sales income (see section 954(d))                                                3
   4  Gross foreign base company services income (see section 954(e))                                             4
   5  Gross foreign base company income. Add lines 2 through 4                                                    5
   6  Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 18 and 
      19)                                                                                                         6
   7  Gross foreign base company income and gross insurance income. Add lines 5 and 6                             7
   8  Enter 5% of total gross income (as computed for income tax purposes)                                        8
   9  Enter 70% of total gross income (as computed for income tax purposes)                                       9
   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 10
   11 If line 7 is more than line 9, enter total gross income (as computed for income tax purposes)               11
   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                                                             13a
   b  Expenses directly related to amount on line 2                                        13b
   c  Subtract line 13b from line 13a                                                      13c
   d  Related person interest expense (see section 954(b)(5))                              13d
   e  Other expenses allocated and apportioned to the amount on line 2
      under section 954(b)(5)                                                              13e
   f  Net foreign personal holding company income. Subtract the sum of
      lines 13d and 13e from line 13c                                                      13f
   g  Net  foreign  personal  holding  company  income  excluded  under
      high-tax exception                                                                   13g
   h  Subtract line 13g from line 13f                                                                             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
   c  Net foreign base company sales income. Subtract line 14b from line 14a               14c
   d  Net foreign base company sales income excluded under high-tax exception              14d
   e  Subtract line 14d from line 14c                                                                             14e
   15 Adjusted net foreign base company services income:
   a  Enter amount from line 4                                                             15a
   b  Expenses allocated and apportioned to line 4 under section 954(b)(5)                 15b
   c  Net foreign base company services income. Subtract line 15b from line 15a            15c
   d  Net foreign base company services income excluded under high-tax exception           15d
   e  Subtract line 15d from line 15c                                                                             15e
   16 Adjusted net full inclusion foreign base company income:
   a  Enter the excess, if any, of line 11 over line 7                                     16a
   b  Expenses allocated and apportioned under section 954(b)(5)                           16b
   c  Net full inclusion foreign base company income. Subtract line 16b from line 16a      16c
   d  Net full inclusion foreign base company income excluded under high-tax exception     16d
   e  Subtract line 16d from line 16c                                                                             16e

22                                                                                                                   Instructions for Form 5471

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Worksheet A
Worksheet A (continued) (See instructions.)
17 Adjusted net foreign base company income. Add lines 13h, 14e, 15e, and 16e  .            . . . .  . .  17
18 Adjusted net insurance income (other than related person insurance income):
a  Enter amount from line 6 (other than related person insurance income)    . .          18a
b  Expenses allocated and apportioned to the amount on line 18a under section
   953 .   . . .  .   . . .  . .     .    . . . .    . . .    . . .     . . . .          18b
c  Net insurance income. Subtract line 18b from line 18a .    . . .     . . . .          18c
d  Net insurance income excluded under high-tax exception .     . .     . . . .          18d
e  Subtract line 18d from line 18c . .    . . . .    . . .    . . .     . . . .        . .  . . . .  . .  18e
19 Adjusted net related person insurance income:
a  Enter amount from line 6 that is related person insurance income     . . . .          19a
b  Expenses allocated and apportioned to the amount on line 19a under section
   953 .   . . .  .   . . .  . .     .    . . . .    . . .    . . .     . . . .          19b
c  Net related person insurance income. Subtract line 19b from line 19a .   . .          19c
d  Net related person insurance income excluded under high-tax exception .    .          19d
e  Subtract line 19d from line 19c . .    . . . .    . . .    . . .     . . . .        . .  . . . .  . .  19e
20 International boycott income (section 952(a)(3))  . . .    . . .     . . . .        . .  . . . .  . .  20
21 Illegal bribes, kickbacks, and other payments (section 952(a)(4))  . . . . .        . .  . . . .  . .  21
22 Income described in section 952(a)(5) (see instructions)   . . .     . . . .        . .  . . . .  . .  22
23 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 .  . . .    . . .    . . .     . . . .        . .  . . . .  . .  23
24 Enter the portion of line 13h that is U.S. source income effectively connected
   with a U.S. trade or business (section 952(b)) .  . .    . . . .     . . . .          24
25 Exclusions under section 959(b) and section 961(c) basis that apply to line 13h
   amount    . .  .   . . .  . .     .    . . . .    . . .    . . .     . . . .          25
26 Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract the sum of lines
   24 and 25 from line 13h . . .     .    . . . .    . .    . . . .     . . . .        . .  . . . .  . .  26
27 Enter the portion of line 14e that is U.S. source income effectively connected
   with a U.S. trade or business (section 952(b)) .  . . .    . . .     . . . .          27
28 Exclusions under section 959(b) that apply to line 14e amount  .     . . . .          28       -0-
29 Section 954(d) subpart F Foreign Base Company Sales Income. Subtract the sum of lines 27 and 
   28 from line 14e . . . .  . .     .    . . . .    . . .    . . .     . . . .        . .  . . . .  . .  29
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))  . . . .    . . .     . . . .          30
31 Exclusions under section 959(b) that apply to line 15e amount  .     . . . .          31       -0-
32 Section 954(e) subpart F Foreign Base Company Services Income. Subtract the sum of lines 30 
   and 31 from line 15e . .  . .     .    . . . .    . . .    . . .     . . . .        . .  . . . .  . .  32
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)) . . .  .   . . .  . .     .    . . . .    . . .    . . .     . . . .          33
34 Exclusions under section 959(b) that apply to line 16e, 18e, 19e, 20, 21, and 
   22 amounts  .  .   . . .  . .     .    . . . .    . . .    . . .     . . . .          34
35 Other subpart F income. Subtract the sum of lines 33 and 34 from the sum of lines 16e, 18e, 19e, 
   20, 21, and 22  .  . . .  . .     .    . . . .    . . .    . . .     . . . .        . .  . . . .  . .  35
36 Total subpart F income. Add lines 26, 29, 32, and 35 .     . . .     . . . .        . .  . . . .  . .  36
37 Current E&P limitation computation:
a  Current E&P  . .   . . .  . .     .    . . . .    . . .    . . .     . . . .          37a
b  Tested loss (enter as a positive number—see instructions) .  . .     . . . .          37b
c  Total of line 37a and line 37b  . .    . . . .    . . .    . . .     . . . .          37c
38 Enter the smaller of line 36 or line 37c . . .    . . .    . . .     . . . .        . .  . . . .  . .  38

Instructions for Form 5471 (Rev. 01-2024)                                                                                23

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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 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal  .            . . . . . . .  40
41 Section 954(d) subpart F Foreign Base Company Sales Income subtotal  .      .     .     . . . . . . .  41
42 Section 954(e) subpart F Foreign Base Company Services Income subtotal  .         .     . . . . . . .  42
43 Other subpart F income subtotal  . .      . . . . . . .     . .     .   . . .     .     . . . . . . .  43
44 Shareholder’s pro rata share of line 40   . . . . . . .     . .     .   . . .           44
45 Shareholder’s  pro  rata  share  of  export  trade  income  that  applies  to  line  44 
   amount (see section 970(a)) .  . . .      . . . . . . .     . .     .   . . .           45
46 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 45 from
   line 44  . . . . . . . .       . . .      . . . . . . .     . .     .   . . .     .     . . . . . . .  46
47 Shareholder’s pro rata share of line 41   . . . . . . .     . .     .   . . .           47
48 Shareholder’s  pro  rata  share  of  export  trade  income  that  applies  to  line  47 
   amount (see section 970(a)) .  . . .      . . . . . . .     . .     .   . . .           48
49 Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 48 from line 47     49
50 Shareholder’s pro rata share of line 42   . . . . . . .     . .     .   . . .           50
51 Shareholder’s  pro  rata  share  of  export  trade  income  that  applies  to  line  50 
   amount (see section 970(a)) .  . . .      . . . . . . .     . .     .   . . .           51
52 Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from line
   50  .   .  . . . . . . .       . . .      . . . . . . .     . .     .   . . .     .     . . . . . . .  52
53 Shareholder’s pro rata share of line 43   . . . . . . .     . .     .   . . .           53
54 Shareholder’s  pro  rata  share  of  export  trade  income  that  applies  to  line  53 
   amount (see section 970(a)) .  . . .      . . . . . . .     . .     .   . . .           54
55 Other subpart F income subtotal. Subtract line 54 from line 53  .   .   . . .     .     . . . . . . .  55
56 Add lines 46, 49, 52, and 55 . . . .      . . . . . . .     . .     .   . . .     .     . . . . . . .  56
57 Divide the number of days in the tax year that the corporation was a CFC by
   the number of days in the tax year and multiply the result by line 56 . . . .           57
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  . . . . . . .     . .     .   . . .           58
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 . .   . . .           59
60 Enter the smaller of line 58 or line 59 . . . . . . . .     . .     .   . . .           60
61 Shareholder’s pro rata share of subpart F income. Subtract line 60 from line 57           . . . . . .  61
62 Amount of line 61 that applies to section 954(c) subpart F Foreign Personal Holding Company Income     62
63 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 .       . . . . . . .  63
64 Amount of line 61 that applies to section 954(d) subpart F Foreign Base Company Sales Income  .     .  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  .      . . . . . . .  65
66 Amount of line 61 that applies to section 954(e) subpart F Foreign Base Company Services Income  .     66
67 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 .       . . . . . . .  67
68 Amount of line 61 that applies to other subpart F income  . . .     .   . . .     .     . . . . . . .  68
69 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 .       . . . . . . .  69

24                                                                                           Instructions for Form 5471 (Rev. 01-2024)

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Worksheet A Instructions                applies to tax years of foreign             Line 1g. Include payments in lieu of 
                                        corporations beginning after                dividends that are made as required 
Foreign base company income.            December 31, 2005, and before               under section 1058.
Foreign base company income             January 1, 2026, and to tax years of 
generally does not include the          U.S. shareholders with or within which      Line 1h. Enter amounts received:
following.                              such tax years of the foreign               • Under a contract under which the 
• Foreign base company shipping         corporations end. Continue to exclude       corporation is to furnish personal 
income as defined in former section     the applicable types of income              services if (a) some person other than 
954(f).                                 specified in section 954(c)(6) from         the corporation has a right to 
• Foreign personal holding company      Worksheet A, line 1a, for the period        designate (by name or by description) 
income derived in the active conduct    specified in the previous sentence.         the individual who is to perform the 
of a banking, finance, or similar                                                   services, or (b) the individual who is to 
business (section 954(h)).              Line 1b. Enter the excess of gains          perform the services is designated (by 
• Exempt insurance income under         over losses from the sale or exchange       name or by description) in the 
section 953(e) and certain investment   of:                                         contract; and
income of a qualifying insurance          • Property that produces the type of      • From the sale or other disposition of 
company or a qualifying insurance       income reportable on line 1a;               such a contract.
branch (sections 953(a)(2) and            • An interest in a trust, partnership, or 
954(i)).                                REMIC; however, see Line 1i, later, for     Note. The above rules apply with 
• Certain income derived in the         an exception that provides for              respect to amounts received for 
ordinary course of business of a        look-through treatment for certain          services under a particular contract 
securities dealer (section 954(c)(2)(C) sales of partnership interests; or          only if at some time during the tax 
(i)).                                     • Property that does not produce any      year 25% or more in value of the 
                                        income.                                     outstanding stock of the corporation is 
Line 1a.  Do not include:                                                           owned, directly or indirectly, by or for 
• Interest from conducting a banking        Do not include the following.
business that is “export financing        • Income, gain, deduction, or loss        the individual who has performed, is 
interest” (section 904(d)(2)(G));       from any transaction (including a           to perform, or may be designated (by 
• Rents and royalties from actively     hedging transaction) and transactions       name or by description) as the one to 
conducting a trade or business          involving physical settlement of a          perform, such services.
received from a person other than a     regular dealer in property, forward         Line 1i. For tax years beginning after 
“related person” (as defined in section contracts, option contracts, and            December 31, 2004, in the case of 
954(d)(3)); and                         similar financial instruments (section      any sale by a CFC of an interest in a 
• Dividends, interest, rent, or royalty 954(c)(2)(C)).                              partnership with respect to which the 
income from related corporate payors      • Gains and losses from the sale or       CFC is a 25% owner (defined below), 
described in section 954(c)(3) or (6).  exchange of any property that, in the       such CFC is treated for purposes of 
However, see section 964(e) for an      hands of the CFC, is property               computing its foreign personal holding 
exception to section 954(c)(3), and     described in section 1221(a)(1).            company income as selling the 
see section 964(e)(4) and Regulations   Line 1c. Enter the excess of gains          proportionate share of the assets of 
section 1.245A-5 for an exception to,   over losses from transactions               the partnership attributable to such 
and limitation on, section 954(c)(6),   (including futures, forward, and similar    interest. Thus, the sale of a 
respectively.                           transactions) in any commodities. See       partnership interest by a CFC that 
  Interest income includes factoring    section 954(c)(1)(C) for exceptions.        meets the ownership threshold 
income arising when a person            See section 954(c)(5) for a definition      constitutes subpart F income only to 
acquires a trade or service receivable  and special rules relating to               the extent that a proportionate sale of 
(directly or indirectly) from a related commodity transactions.                     the underlying partnership assets 
                                                                                    attributable to the partnership interest 
person. The income is treated as        Line 1d. Enter the excess of foreign        would constitute subpart F income. 
interest on a loan to the obligor under currency gains over foreign currency        Do not report these amounts on 
section 864(d)(1) and is generally not  losses from section 988 transactions.       line 1b. Instead, report them on line 1i.
eligible for the de minimis, export     An exception applies to transactions 
financing, and related party            directly related to the business needs        25% owner.    For purposes of 
exceptions to the inclusion of subpart  of a CFC.                                   these rules, a 25% shareholder is a 
F income. Also, a trade or service                                                  CFC that owns directly 25% or more 
receivable acquired or treated as       Line 1e. Enter any income equivalent        of the capital or profits interest in a 
acquired by a CFC from a related U.S.   to interest, including income from          partnership. For purposes of the 
person is considered an investment in   commitment fees (or similar amounts)        preceding sentence, if a CFC is a 
U.S. property for purposes of section   for loans actually made.                    shareholder or partner of a 
956 (Worksheet B) if the obligor is a   Line 1f. Include net income from            corporation or partnership, the CFC is 
U.S. person.                            notional principal contracts (except a      treated as owning directly its 
                                        contract entered into to hedge              proportionate share of any such 
Note. Section 111 of the Taxpayer       inventory property).                        capital or profits interest held directly 
Certainty and Disaster Tax Relief Act                                               or indirectly by such corporation or 
of 2020 extended the look-through                                                   partnership. If a CFC is treated as 
rule of section 954(c)(6). The rule now                                             owning a capital or profits interest in a 

Instructions for Form 5471 (Rev. 01-2024)                                                                                   25

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partnership under constructive          deductions attributable to disqualified  determined under the rules of section 
ownership rules similar to the rules of payments (Regulations section            953(c)(5).
section 958(b), the CFC shall be        1.951A-2(c)(5) or (6)) are not 
                                                                                   Exceptions.     The above definition 
treated as owning such interest         allocated and apportioned to gross 
                                                                                 does not apply to any foreign 
directly or indirectly for purposes of  foreign base company income.
                                                                                 corporation if:
this definition.
                                        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 foreign base company income          subject to high foreign taxes.           of the total combined voting power of 
(determined without regard to section   Foreign base company income and          all classes of stock of the corporation 
954(b)(5)) and gross insurance          insurance income do not include any      entitled to vote, and less than 20% of 
income (as defined in section 954(b)    item of income received by a CFC if      the total value of the corporation, is 
(3)(C)) for the tax year is less than   the taxpayer establishes that such       owned (directly or indirectly under the 
the lesser of 5% of gross income for    income was subject to an effective       principles of section 883(c)(4)) by 
income tax purposes, or $1 million,     rate of income tax imposed by a          persons who are (directly or indirectly) 
then no portion of the gross income     foreign country that is greater than     insured under any policy of insurance 
for the tax year is treated as foreign  90% of the maximum rate of tax           or reinsurance issued by the 
base company income or insurance        specified in section 11. For more        corporation or who are related 
income. In this case, enter zero on     information, see section 954(b)(4) and   persons to any such person;
line 10 and skip lines 11 through 19.   Regulations section 1.954-1(d)(1).       • The related person insurance 
Otherwise, go to line 11.                                                        income (determined on a gross basis) 
                                        Line 18. Adjusted net insurance in-
Line 11. Full inclusion rule. If the    come. Insurance income is any            of the corporation for the tax year is 
sum of foreign base company income      income attributable to the issuing (or   less than 20% of its insurance income 
(determined without regard to section   reinsuring) of any insurance or annuity  for the tax year; or
954(b)(5)) and gross insurance          contract that would (subject to the      • The corporation:
income for the tax year exceeds 70%     modifications provided in section          1. Elects to treat its related person 
of gross income for income tax          953(b)) be taxed under subchapter L      insurance income for the tax year as 
purposes, the entire gross income for   (insurance company tax) if such          income effectively connected with the 
the tax year must (subject to the       income were income of a domestic         conduct of a trade or business in the 
high-tax exception described below,     insurance company. However,              United States,
the section 952(b) exclusion, and the   insurance income does not include          2. Elects to waive all treaty 
deductions to be taken into account     exempt insurance income (as defined      benefits (other than from section 884) 
under section 954(b)(5)) be treated as  in section 953(e)).                      for related person insurance income, 
foreign base company income or                                                   and
                                        Line 18b. Expenses. Do not enter 
insurance income, whichever is 
                                        expenses on this line to the extent that   3. Meets any requirement the IRS 
appropriate. In this case, enter total 
                                        their allocation and apportionment       may prescribe to ensure that any tax 
gross income (for income tax 
                                        reduces an item of insurance income      on such income is paid.
purposes) on line 11. Otherwise, enter 
                                        below zero.
zero.                                                                              This election will not be effective if 
                                        Note. In determining the amount of       the corporation was a disqualified 
Lines 13b, 13d, 13e, 14b, 15b, and      a net item of insurance income,          corporation (as defined in section 
16b. Expenses.  Adjusted net foreign    deductions or loss attributable to       953(c)(3)(E)) for the tax year for which 
base company income is calculated       disqualified basis and deductions        the election was made or for any prior 
by first determining the gross amount   attributable to disqualified payments    tax year beginning after 1986. See 
of each item of income and then         (Regulations section 1.951A-2(c)(5)      section 953(c)(3)(D) for special rules 
allocating and apportioning expenses    or (6)) are not allocated and            for this election.
to such items of income. For more       apportioned to gross insurance 
                                                                                 Mutual life insurance companies. 
information, see section 954(b)(5) and  income.
Regulations section 1.954-1(c)(1)(i).                                            The related person insurance income 
Expenses allocated and apportioned      Line 19. Adjusted net related per-       rules also apply to mutual life 
to an item of income may reduce the     son insurance income. Related            insurance companies under 
item of income below zero, and any      person insurance income is any           regulations prescribed by the 
item of income that is less than zero   insurance income (within the meaning     Secretary. For these purposes, 
generally cannot offset other items of  of section 953(a)) attributable to a     policyholders must be treated as 
income. For more information, see       policy of insurance or reinsurance for   shareholders.
Regulations section 1.954-1(c)(1)(ii).  which the person insured (directly or 
                                                                                 Line 19b. Expenses. Do not enter 
Do not enter expenses on these lines    indirectly) is a U.S. shareholder (as 
                                                                                 expenses on this line to the extent that 
of Worksheet A to the extent that their defined in section 953(c)(1)(A)) in a 
                                                                                 their allocation and apportionment 
allocation and apportionment reduces    CFC (as defined in section 953(c)(1)
                                                                                 reduces an item of insurance income 
an item of income below zero.           (B)), or a related person (as defined in 
                                                                                 below zero.
                                        section 953(c)(6)) to such a 
Note. In determining the amount of                                                 Note. In determining the amount of 
                                        shareholder. If a CFC has related 
a net item of foreign base company      person insurance income, the U.S.        a net item of insurance income, 
income, deductions or loss                                                       deductions or loss attributable to 
                                        shareholder’s pro rata share is to be 
attributable to disqualified basis and                                           disqualified basis and deductions 

26                                                                               Instructions for Form 5471 (Rev. 01-2024)

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attributable to disqualified payments participation in or cooperation with an obligation of the United States or the
(Regulations section 1.951A-2(c)(5) international boycott. See Schedule B Code.
or (6)) are not allocated and (Form 5713).
Line 37. Current E&P limitation. A
apportioned to gross insurance
Line 21. Illegal bribes, kickbacks, CFC's subpart F income is limited to
income.
and other payments. Enter the total the sum of the following.
Line 20. International boycott in- of any illegal bribes, kickbacks, or • Its current year E&P, computed
come. If a CFC or a member of a other payments (within the meaning of under the special rule of section
controlled group (within the meaning section 162(c)) paid by or on behalf of 952(c)(1). Enter this amount on
of section 993(a)(3)) that includes the 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 government. 951A(c)(2)(B)(ii). If the total of all lines
company, or a national of a country) 6 of all separate Schedules I-1 (Form
Line 22. Income described in sec-
that requires participation in or 5471) for the CFC is a negative
tion 952(a)(5). The income of a CFC
cooperation with an international number, enter the amount as a
derived from any foreign country
boycott as a condition of doing positive number on line 37b. If the
during any period during which
total of all lines 6 is a positive number
business within such country or with section 901(j) applies to such foreign
or zero, enter -0- on line 37b.
the government, company, or national country will be deemed to be income
of that country, a portion of the CFC's The amount included in the gross
to the U.S. shareholders of such CFC.
income is included in subpart F income of a U.S. shareholder of a
As of the date these instructions were
income. The amount included is CFC under section 951(a)(1)(A) for
revised, section 901(j) applied to Iran,
determined by multiplying the CFC's any tax year and attributable to a
North Korea, Sudan, and Syria.
income (other than income included qualified activity must be reduced by
under section 951 and U.S. source Lines 24, 27, 30, and 33. Exclusion the shareholder's pro rata share of
effectively connected business of U.S. income. Subpart F income any qualified deficit (see section
income described in section 952(b)) does not include any U.S. source 952(c)(1)(B)).
by the international boycott factor. income (which, for these purposes,
This factor is a fraction determined on includes all carrying charges and all Lines 39 through 43. If Worksheet
Schedule A (Form 5713). interest, dividends, royalties, and A, line 37c, is less than the amount on
other investment income received or Worksheet A, line 36, allocate the
Special rule. If the shareholder of accrued by an FSC) that is effectively subpart F income remaining (after
a CFC can clearly demonstrate that connected with a CFC's conduct of a having been limited) (that is, the
the income earned for the tax year is trade or business in the United States line 38 amount) to the four categories
from specific operations, then, instead unless that item is exempt from of subpart F income listed on
of applying the international boycott taxation (or is subject to a reduced Worksheet A, lines 40 through 43,
factor, the addition to subpart F rate of tax) pursuant to a treaty using the rules of Regulations section
income is the amount specifically from 1.952-1(e).
the operations in which there was

Instructions for Form 5471 (Rev. 01-2024) 27

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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 dened in section 956(c) and (d)) held (directly or 
      indirectly) by the CFC as of the close of:
   a  The rst quarter of the tax year . .  .    . . .   . . . .   .   .   . . . .        1a
   b  The second quarter of the tax year    .    . . .   . . . .   .   .   . . . .        1b
   c  The third quarter of the tax year  .  .    . . .   . . . .   .   .   . . . .        1c
   d  The fourth quarter of the tax year  . .    . . .   . . . .   .   .   . . . .        1d
2     Number of quarter-ends the foreign corporation was a CFC during the tax year .      .   . . . .    . .           2
3     Average  amount  of  U.S.  property  held  (directly  or  indirectly)  by  the  CFC  as  of  the  close  of  each
      quarter of the tax year. (Add lines 1a through 1d. Divide this amount by the number on line 2.)  . . .           3
4     U.S. shareholder’s pro rata share of the amount on line 3  . .   .   . . . .      . .   . . . .    . .           4
5     Earnings  and  prots  described  in  section  959(c)(1)(A)  with  respect  to  the  U.S.  shareholder  after 
      reductions (if any) for current year distributions . . . .   .   .   . . . .      . .   . . . .    . .           5
6     Section 956(a)(1) amount. Subtract line 5 from line 4  . .   .   .   . . . .      . .   . . . .    . .           6
7     Applicable earnings:
   a  Current year earnings and prots  .   .    . . .   . . . .   .   .   . . . .        7a
   b  Line 7a plus accumulated earnings and prots       . . . .   .   .   . . . .        7b
8     Enter the greater of line 7a or line 7b  . . . .   . . . .   .   .   . . . .      . .   . . . .    . .           8
9     Distributions made by the CFC during the tax year  .   . .   .   .   . . . .      . .   . . . .    . .           9
10    Subtract line 9 from line 8 . .    .  .    . . .   . . . .   .   .   . . . .      . .   . . . .    . .           10
11    Earnings and prots described in section 959(c)(1) after reductions (if any) for current year distributions      11
12    Applicable earnings. Subtract line 11 from line 10  .  . .   .   .   . . . .      . .   . . . .    . .           12
13    Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12  .     . .    . .           13
14    Section 956(a) amount. Enter the smaller of line 6 or line 13  . .   . . . .      . .   . . . .    . .           14
15    Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder       . . . .    . .           15
16    Tentative section 956 amount. Subtract line 15 from line 14 .    .   . . . .      . . . . . . .    . .           16
17    Amount  of  deduction  under  section  245A,  if  any,  that  the  shareholder  would  be  allowed  if  the
      shareholder received a hypothetical distribution within the meaning of Regulations section 1.956-1(a)(2).
      If the shareholder is not a U.S. corporation, this amount is zero  . . . . .      . .   . . . .    . .           17
18    Section 956 amount. Subtract line 17 from line 16  .   . .   .   .   . . . .      . .   . . . .    . .           18
19    Translate the amount on line 18 from functional currency to U.S. dollars at the year-end spot rate (as 
      provided in section 989(b)). Enter the result here and on line 2 of Schedule I  . . .   . . . .    . .           19

Worksheet B Instructions                             Distributions are also taken into              which the property is subject. See 
                                                   account before the section 956                   section 956(c) and (d) and the 
Use Worksheet B to determine a U.S.                inclusion is determined. Distributions           regulations under section 956 to 
shareholder's pro rata share of                    are generally treated as coming first            determine whether the CFC is treated 
earnings of a CFC invested in U.S.                 from (and thus reducing the balances             as holding U.S. property. The amount 
property that is subject to tax. Only              of) the PTEP accounts. Thus, the U.S.            of U.S. property held (directly or 
earnings of a CFC not distributed or               shareholders must:                               indirectly) by the CFC that was 
otherwise previously taxed are subject               1. Compute the current year                    acquired by the foreign corporation 
to these rules. Thus, the amount of                subpart F income inclusion                       before it became a CFC is 
previously untaxed earnings limits the             (potentially increasing the section              disregarded (that is, not included), but 
section 956 inclusion. A CFC's                     959(c)(2) PTEP within the PTEP                   not in excess of the amount of 
investment in U.S. property in excess              accounts),                                       applicable earnings (as defined in 
of this limit will not be included in the                                                           section 956(b)) accumulated during 
taxable income of the CFC's U.S.                     2. Take into account current 
                                                                                                    periods before it became a CFC.
shareholders. PTEP related to                      distributions (potentially reducing the 
prior-year section 956 inclusions (see             PTEP accounts and untaxed earnings                    If the foreign corporation ceases to 
section 959(c)(1)(A)) and current-year             and profits), and                                be a CFC during the tax year:
or prior-year subpart F inclusions (see              3. Compute the current section                 •    The determination of the U.S. 
section 959(c)(2)) reduce what would               956 inclusion (increasing section                shareholder's pro rata share will be 
otherwise be the current year section              959(c)(1) PTEP and potentially                   made based upon the stock owned 
956 inclusion.                                     decreasing section 959(c)(2) PTEP in             (within the meaning of section 958(a)) 
                                                   the PTEP accounts).                              by the U.S. shareholder on the last 
Note. PTEP resulting from subpart F                                                                 day during the tax year in which the 
inclusions (that is, section 959(c)(2)               U.S. property is measured on a                 foreign corporation was a CFC;
PTEP) that reduced prior-year section              quarterly average basis. For purposes            •    The CFC's U.S. property for the tax 
956 or 956A inclusions (see section                of Worksheet B, the amount taken into            year will be determined only by taking 
959(a) and (c)(1), and Schedule J)                 account with respect to U.S. property            into account quarters ending on or 
should be reclassified as section                  is generally its adjusted basis for E&P          before such last day (and investments 
959(c)(1) PTEP.                                    purposes, reduced by any liability to            in U.S. property as of the close of 

28                                                                                                Instructions for Form 5471 (Rev. 01-2024)

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subsequent quarters should be the field for “Name of person filing Part I—Taxes for Which a
recorded as zero on line 1); and Form 5471.” Foreign Tax Credit Is Allowed
• In determining applicable earnings,
Reference ID number of foreign In Part I, Section 1, list income, war
current year E&P will include only E&P
corporation. If applicable, use the profits, and excess profits taxes
that are allocable (on a pro rata basis)
reference ID number shown on Form (income taxes) paid or accrued to
to the part of the year during which the
5471, page 1, item 1b(2). each foreign country or U.S. territory
foreign corporation was a CFC.
Lines a, b, and c. Complete a for the foreign corporation’s foreign tax
separate Schedule E for each year(s) that ends with or within its U.S.
Instructions for Separate applicable separate category of tax year.
Schedules income. Enter the appropriate code In Part I, Section 2, report taxes
on line a (above Part I). To determine deemed paid under section 960(b)(2)
the appropriate code, see Categories with respect to distributions of PTEP
Schedule E of Income in the Instructions for Form from a lower-tier foreign corporation to
Use Schedule E, Part I, to report taxes 1118, Foreign Tax the foreign corporation with respect to
paid, accrued, or deemed paid under Credit—Corporations. Taxes with which this Schedule E (Form 5471) is
section 960(b)(2) by a foreign respect to all categories of income being completed.
corporation for which a foreign tax listed in the Instructions for Form
credit is allowed, and use Schedule E, 1118, with the exception of foreign Amounts not reported in Part I. Do
Part III, to report taxes for which a branch income, may need to be not report taxes that are not
credit may not be taken. reported. A foreign corporation may creditable, including taxes for which a
accrue or pay taxes properly credit is disallowed under section
Note. Schedule E must be completed attributable to an income group within 245A(d) or section 901(j), (k), (l), or
even for noncorporate U.S. the general category, passive (m); or suspended under section 909.
shareholders. Certain noncorporate category, or section 901(j) category. Such taxes are reported in Part III. A
U.S. shareholders may elect under See Regulations section 1.960-1(d)(2) credit is never allowed for taxes paid
section 962 to be taxed at corporate (ii). A foreign corporation may accrue or accrued to the United States. Do
rates on section 951(a) amounts and or pay taxes properly attributable to a not report such taxes in Part I. Report
the global intangible low-taxed income PTEP group within any of the separate them instead in Part III.
(GILTI) inclusion for the tax year, so as categories of income, with the Adjustments to foreign income tax-
to be able to claim a credit for certain exception of foreign branch category es. Adjustments to foreign income
foreign taxes paid or accrued by the income. See Regulations section taxes paid or accrued in a prior year
CFC. The information reported on 1.960-3(c)(1). should not be reflected on Schedule E
Schedule E is relevant for U.S.
shareholders making this election. If code 901j is entered on line a, in the year of adjustment. Instead,
Also, timely information reporting is enter on line b the country code for they should be reported in the year to
important to the extent the U.S. the sanctioned country using the which such taxes relate. This may
shareholder chooses to amend its two-letter codes (from the list at require an amended return. See
return in a later year to make the IRS.gov/CountryCodes). section 905(c). Adjustments include
additional payments, refunds, and
election under section 962. Schedules If one of the RBT codes is entered
downward adjustments for accrued
E and E-1 are also relevant for on line a, enter on line c the country
foreign taxes that are not paid within 2
noncorporate U.S. shareholders who code for the treaty country using the
years after the close of the tax year to
do not make a section 962 election. two-letter code (from the list at
which such taxes relate.
Taxes paid or accrued with respect to IRS.gov/CountryCodes).
distributions of PTEP by the U.S. Comparison to income tax ex-
shareholder, while not reported on Note. Do not complete a separate pense reported on Form 5471,
Form 5471, are subject to different Schedule E for taxes assigned to the Schedule C. The foreign income
rules regarding creditability and section 951A category. Taxes paid, taxes reported on Schedule E may
foreign currency gain or loss. See, for accrued, or deemed paid with respect differ from the amount reported as
example, sections 965(g) and 986(c). to section 951A PTEP that is in the income tax expense on line 21a of
Therefore, it is important that the U.S. section 951A category are reported Schedule C. This is due in part to
shareholder track the PTEP groups to on the Schedule E completed for the differences in the accounting for
follow the different rules for each general category. foreign tax redeterminations,
group. disallowed taxes, and foreign income
Important. In addition to the taxes reported in Other
Name of person filing Form 5471. separate category codes referred to Comprehensive Income for U.S.
The name of the person filing Form above, if you have more than one of GAAP purposes.
5471 is generally the name of the U.S. the categories of income referred to
person described in the applicable above, you must complete and file a Comparison to income tax ex-
category or categories of filers (see separate Schedule E (including pense reported on Schedule H
Categories of Filers, earlier). However, Schedule E-1) using code “TOTAL” (Form 5471). The taxes added or
in the case of a consolidated return, that aggregates all amounts listed for deducted on line 2g of Schedule H
enter the name of the U.S. parent in each line and column of all other include both foreign income taxes
Schedules E and E-1. 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

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Schedule E that are not creditable or accrued to a different country on 1. The tax is paid before the
foreign income taxes. separate lines. beginning of the year to which the tax
relates.
Section 1—Taxes Paid or
Column (e) 2. Accrued taxes are not paid
Accrued Directly by Foreign
before the date 2 years after the close
Corporation The foreign tax year under foreign tax of the tax year to which such taxes
Column (a) law may not be the same tax year as relate.
the U.S. tax year of the foreign
3. There is an election in effect
Amounts reported on Schedule E may corporation. If the tax is attributable to
under section 986(a)(1)(D) to
include taxes paid or accrued by the a pass-through entity owned by a
translate foreign taxes using the
foreign corporation or a pass-through foreign corporation, the foreign tax
exchange rate in effect on the date of
entity (for example, a partnership or year of the foreign corporation within
payment.
disregarded entity) owned by the which such pass-through entity’s year
foreign corporation. If the tax is paid or ends should be reported on this line. 4. The foreign corporation reports
on the cash basis. See section 986(a).
accrued by the pass-through entity,
enter the name of such entity instead Column (g) 5. The foreign tax is denominated
of the name of the foreign corporation. in an inflationary currency. See
If the tax paid or accrued by the Enter the income reported to the section 986(a)(1)(C).
foreign corporation is attributable to a foreign tax authority under foreign tax
Report the exchange rate using the
branch or qualified business unit law. This should be the foreign taxable
“divide-by convention” specified under
(QBU) of the foreign corporation, income base for determining the tax
Reporting exchange rates on Form
enter the name of the branch or QBU. reported in column (j).
5471, earlier.
Column (b) Column (h)
Column (m)
Enter the EIN or reference ID number Check the box if taxes were paid on
of the payor entity listed in column (a). U.S. source income. Enter the tax in functional currency.
E&P takes into account foreign
A reference ID number is required income taxes paid or accrued by the
only in cases in which no EIN was Column (i)
foreign corporation. The foreign
entered for the foreign corporation or corporation's E&P is determined in the
pass-through entity owned by the Enter the three-letter currency code
foreign corporation. Filers are for the local currency in which the tax foreign corporation's functional
permitted to enter both an EIN and a is payable. Currency codes are currency. See section 986(b).
reference ID number. See Item available at six-group.com/en/ Line 5
1b(2)—Reference ID Number, earlier, products-services/financial- Report the total of the amounts listed
for more information about reference information/data- in column (l) on this line 5. This total
ID numbers. standards.html#scrollTo=currency- should also be reported on
codes. Schedule E-1, line 4.
Column (c)
Column (j) Line 6
Check the box if the foreign income Report the total of the amounts listed
taxes reported in column (j) were paid Enter the tax paid or accrued in the in column (m) on this line 6. This total
or accrued by the foreign corporation local currency in which tax is payable and the amount reported on line 3 of
during prior tax years and were and not the functional currency of the Schedule E, Part III, are the
suspended due to the application of payor or foreign corporation. See appropriate reduction to current year
the rules of section 909 and that are sections 986(a) and 905(c). E&P for income taxes. See
unsuspended in the current year Schedule H, line 2g.
because related income is taken into Columns (k) and (l) Example. CFC1, a foreign
account by the foreign corporation, corporation, with reference ID number
certain U.S. corporate owners of the Enter the exchange rate in column (k) 1000123, pays or accrues tax of 10u =
foreign corporation, or a member of and the translated dollar amount in $10 to Country X on 50u of Country X
such U.S. corporate owner’s column (l). foreign source taxable income with
consolidated group. respect to CFC1’s foreign tax year
Translate the taxes entered in
ending December 31, 2023. CFC1
column (j) into dollars at the average
Column (d) has a December 31 tax year end for
exchange rate for the tax year to
both foreign and U.S. tax purposes.
which the tax relates unless one of the
Enter the two-letter codes (from the Also, CFC1 receives in the tax year
exceptions below applies. See section
list at IRS.gov/CountryCodes) of all ending December 31, 2023, a refund
986(a).
foreign countries and U.S. territories of 3u from Country X on 15u of foreign
to which taxes were paid or accrued. If Exceptions. If one of the following source income with respect to CFC1’s
taxes were paid or accrued to more exceptions applies, use the exchange tax year ending December 31, 2017,
than one country with respect to the rate in effect on the date the foreign translated to equal $5, and on which
same income, include each tax paid corporation paid the tax. the original liability was $7. Therefore,
30 Instructions for Form 5471 (Rev. 01-2024)

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the revised tax liability is $2. All taxes The only foreign taxes of the           in Regulations section 1.960-3(c)(2)). 
relate to general category income.         distributing foreign corporation that   Please enter the applicable PTEP 
Also assume for both years that the        may be treated as deemed paid under     group code from the following list.
local currency in which the tax was        section 960(b) are foreign taxes paid, 
paid was the same as the foreign           accrued, or deemed paid by the          PTEP Group Classification
corporation’s functional currency. The     distributing foreign corporation with 
country code for Country X is XX.          respect to the receipt of a PTEP        Taxes related to     PTEP Group Code
  The following entries should be          distribution from another lower-tier    previously taxed 
made on the 2023 Schedule E (Form          foreign corporation below the           E&P
5471), Part I, Section 1, for CFC1 with    distributing foreign corporation.       Reclassified section R965a
respect to the General Category            Accordingly, there can be no            965(a) PTEP 
Income separate category.                  deemed-paid foreign taxes with          Reclassified section R965b
                                           respect to a PTEP distribution from a 
• Line 1, column (a): CFC1                                                         965(b) PTEP
                                           lower-tier foreign corporation that is 
• Line 1, column (b): 1000123                                                      General section      959c1
                                           the lowest foreign-tier foreign 
• Line 1, column (d): XX                                                           959(c)(1) PTEP 
                                           corporation in a chain, and therefore 
• Line 1, column (e): 2023/12/31                                                   Reclassified section R951A
                                           no such distributions will be reported 
• Line 1, column (f): 2023/12/31                                                   951A PTEP 
                                           in Section 2. See Regulations section 
• Line 1, column (g): 50u
                                           1.960-1(d)(3)(ii)(B).                   Reclassified section R245Ad
• Line 1, column (i): u                                                            245A(d) PTEP 
• Line 1, column (j): 10u                  Any foreign income taxes paid or 
• Line 1, column (k): 1.0000               accrued (but not deemed paid) by the    Section 965(a) PTEP  965a
• Line 1, column (l): $10                  foreign corporation with respect to a   Section 965(b) PTEP  965b
• Line 1, column (m): 10u                  PTEP distribution from a lower-tier     Section 951A PTEP    951A
  An amended 2017 tax return               foreign corporation (whether or not 
should be filed by or for the U.S.         such PTEP distribution is reported in   Section 245A(d)      245Ad
                                                                                   PTEP
person(s) with respect to which Form       Section 2), such as withholding taxes 
5471 was required and that return          imposed on the PTEP distribution, are   Section 951(a)(1)(A) 951a1A
should include an amended Form             reported in Section 1.                  PTEP 
5471. The amended Form 5471 
should include an attachment with a        Column (a)                              Column (e)
schedule that looks like the current 
version of Schedule E, Part I, Section     Enter the name of each lower-tier       Enter the year in which the U.S. 
1, with the following entries for the      foreign corporation that made a PTEP    shareholder included income of the 
general category of income.                distribution with respect to which a    lower-tier foreign corporation under 
• Line 1, column (a): CFC1                 deemed-paid tax is determined in the    section 951(a) or section 951A and 
• Line 1, column (b): 1000123              current year by the foreign corporation established the PTEP account to 
• Line 1, column (d): XX                   with respect to which this Schedule E   which the distribution is attributed. 
• Line 1, column (e): 2017/12/31           (Form 5471) is being completed.         This is the annual PTEP account. See 
• Line 1, column (f): 2017/12/31                                                   Regulations section 1.960-3(c)(1).
• Line 1, column (g): 15u                  Column (b)
• Line 1, column (i): u                                                            Column (f)
• Line 1, column (j): 1.20u                Enter the EIN or reference ID number 
• Line 1, column (k): 1.6667               of the lower-tier foreign corporation   Enter the PTEP distribution with 
• Line 1, column (l): $2                   listed in column (a). A reference ID    respect to the PTEP group within the 
• Line 1, column (m): 1.20u                number is required only in cases in     annual PTEP account identified in 
                                           which no EIN was entered for the        column (d) and column (e) in the 
Section 2—Taxes Deemed Paid                lower-tier foreign corporation. Filers  functional currency of the distributing 
(Section 960(b))                           are permitted to enter both an EIN and  lower-tier foreign corporation. If there 
The purpose of Section 2 is to track       a reference ID number. See Item         is a PTEP distribution related to more 
deemed-paid foreign income taxes           1b(2)—Reference ID Number, earlier,     than one PTEP group within an annual 
with respect to current year PTEP          for more information about reference    PTEP account, complete a separate 
distributions from lower-tier foreign      ID numbers.                             line for each PTEP group within an 
corporations to the foreign corporation                                            annual PTEP account.
with respect to which this Schedule E      Column (c)
(Form 5471) is being completed (“the                                               Column (g)
foreign corporation”).                     Enter the applicable two-letter code 
                                           (from the list at IRS.gov/              Enter the total amount of the lower-tier 
  Report a PTEP distribution by a          CountryCodes).                          foreign corporation’s PTEP in the 
lower-tier foreign corporation in                                                  PTEP group within the annual PTEP 
Section 2 only if foreign income taxes     Column (d)                              account identified in column (d) and 
are deemed paid under section                                                      column (e). Enter such amount in the 
960(b) by the foreign corporation with     Enter the code which describes the 
respect to such PTEP distribution.         PTEP group classification (as set forth 

Instructions for Form 5471 (Rev. 01-2024)                                                                                31

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functional currency of the distributing which generally applies to certain (section 901(f)), certain taxes used to
lower-tier foreign corporation. taxes paid on dividends if the provide subsidies (section 901(i)), and
minimum holding period is not met taxes for which no credit is allowed
Column (h) with respect to the underlying stock, because of the boycott provisions of
or if the corporation is obligated to section 908.
Enter the total amount of the lower-tier make related payments with respect
foreign corporation’s PTEP group to positions in similar or related Column (i)
taxes with respect to the PTEP group property. Also enter foreign income
within the annual PTEP account taxes disallowed under section 901(l), For each line in this column, enter the
identified in column (d) and column which generally applies to certain total amount for each payor in
(e). Enter this amount in U.S. dollars. taxes paid on gain and income other columns (c) through (h).
To determine the appropriate than dividends if the minimum holding
translation rate, see section 986(a). period is not met with respect to the Line 3
underlying property, or if the Total each amount in column (i) and
Column (i) corporation is obligated to make enter on line 3. All amounts should be
related payments with respect to in functional currency.
Enter the U.S. dollar amount of the positions in similar or related property. Line 4
recipient foreign corporation's income
Translate the line 3 amount from
taxes deemed paid that are properly Column (e)
functional currency to U.S. dollars
attributable to the PTEP distribution
using, in general, the average
reported in column (f) and not In the case of a covered asset exchange rate as defined by section
deemed to have been paid by the acquisition (as defined in section 989(b)(3).
domestic corporation for any prior tax 901(m)(2)), enter the disqualified
year. portion of any tax determined with
respect to the income or gain Schedule E-1
Note. With respect to distributions of attributable to the relevant foreign Use Schedule E-1 (on pages 2 and 3
PTEP resulting from inclusions under assets (section 901(m)). of separate Schedule E) to report the
section 965, report the taxes properly cumulative balance of foreign income
attributable to such PTEP without Note. This rule generally applies to taxes paid or accrued by a CFC by
reduction for the foreign tax credit covered asset acquisitions after separate category of income.
disallowance. December 31, 2010. See Regulations
sections 1.901(m)-1 through Enter amounts in U.S. dollars
Part III—Taxes for Which unless otherwise noted.
1.901(m)-8 for additional information.
Foreign Tax Credit Is Note that the rules contained in these Columns (a), (b), and (c)
Disallowed regulations have later effective dates.
Use Part III to report taxes for which In columns (a), (b), and (c), report
only the foreign income taxes the
foreign tax credits are not allowed. Column (f)
While not allowed as a credit, such foreign corporation pays or accrues
attributable to the subpart F income
taxes are taken into account in Enter the amount of taxes paid or group, the tested income group, and
determining the foreign corporation’s accrued by the foreign corporation to the residual income group,
E&P. the United States. No credit is allowed respectively. Use Schedule Q to
Do not enter taxes that do not meet for these taxes because only foreign determine the taxes attributable to
the criteria under Regulations section income taxes paid or accrued to a each income group. Do not include
1.901-2. foreign country or territory of the foreign income taxes paid or accrued
United States are allowed as a credit. by the foreign corporation in its other
See section 901(b).
Columns (a) and (b) tax years beginning after December
31, 2017, or that do not relate to the
See Part I—Taxes for Which a Foreign Column (g) current tax year. Do not include
Tax Credit Is Allowed, earlier, for foreign income taxes that are
instructions regarding these columns. Report foreign income taxes related to disallowed and are reported on
the current tax year that have been Schedule E, Part III. Do not include
Column (c) suspended due to the rules of section taxes paid or accrued by the foreign
909. corporation with respect to its receipt
Enter foreign income taxes that are of a PTEP distribution, even if those
disallowed under section 901(j), Column (h) amounts were included in the total
generally foreign income taxes paid or entered on line 5, column (l), of
accrued to certain sanctioned Enter taxes for which a foreign tax Schedule E, Part I, Section 1. These
countries. credit is disallowed other than those are reported in column (e). Do not
detailed in columns (c) through (g). include taxes deemed paid by the
Column (d) Such taxes may include, but are not foreign corporation with respect to its
limited to, taxes attributable to section receipt of a PTEP distribution. These
Enter foreign income taxes that are 245A(d) income, certain taxes on the are also reported in column (e).
disallowed under section 901(k), purchase or sale of oil and gas
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On line 9, report reductions for the Line 2. Use line 2 to reflect income, after foreign income tax, of
portion of such taxes that are deemed adjustments to a U.S. person’s foreign $100 with respect to which it pays $20
paid by a U.S. shareholder with tax credit as a result of redetermined of foreign income tax. Such tax is
respect to an inclusion under section foreign income taxes. If a U.S. person properly attributable to subpart F
951(a) or 951A. On line 15, report has appropriately amended the income of CFC3 and is reported on
reductions for foreign income taxes immediately prior year return, line 4, column (a), of Schedule E-1 of
attributable to the column (b) tested including its Schedule E-1, to CFC3’s Form 5471. During Year 1,
income group that are not deemed redetermine its U.S. tax liability, no Domestic Corporation reports an
paid as a result of the inclusion adjustment should be included on this inclusion under section 951(a)(1) of
percentage or the 80% limitation. line. This line is only applicable if a $100 and deemed paid taxes of $20
Also, on line 15, report any other U.S. person appropriately amended a under section 960(a) as a result of
reductions to the three income groups prior year return and there were subpart F income of CFC3. During
in columns (a), (b), and (c) necessary intervening years between the Year 2, CFC3 distributes $40 to CFC2.
to achieve a zero balance on line 16. amended year return and the current CFC2 pays withholding tax of $4 on
Attach a statement explaining why year return for which an amended the distribution from CFC3. Such tax
such taxes were not deemed paid return was not filed. If so, an is a tax related to previously taxed
under section 960. The balance of adjustment for the prior year amended earnings and profits that were
foreign income taxes paid or accrued return (and its impact on intervening included as subpart F income and is
with respect to the three income years) should be reflected on line 2. reported on line 4, column (e)(x), of
groups that is entered on line 16 Schedule E-1 of CFC2’s Form 5471.
should equal zero after taking into Line 3a. A tax reported on
account the reductions. Schedule E, Part I, Section 1, line 5, Line 5. Report taxes carried over to a
column (l), for which column (c) was foreign surviving corporation after an
Column (d) checked because such tax was acquisition by a foreign corporation of
Use column (d) to report taxes unsuspended in the current year, the assets of another foreign
suspended under section 909. should be included as a positive corporation in a transaction described
amount in column (a), (b), (c), or (e), in section 381. See Regulations
Columns (e)(i) through (e)(x) as appropriate. Such tax should also section 1.367(b)-7(b)(1) and (d)(1).
Report foreign income taxes paid or be reflected as a negative amount in Line 6. Enter foreign income taxes
accrued with respect to E&P column (d). properly attributable to PTEP and not
described in section 959(c)(1) and (c) previously deemed paid (from
(2). See the instructions for Line 3b. Include as a positive amount
Schedule J, Column (e), later, for in column (d) foreign income taxes Schedule E, Part I, Section 2, line 5,
specific information about the ten related to the current tax year that column (i)). The total reported on
PTEP group columns. Also see have been suspended due to the rules Schedule E, Part I, Section 2, line 5,
Regulations section 1.960-3(c)(2) for of section 909. Such taxes are also column (i), should be broken out on
additional information regarding the reported on Schedule E, Part III, Schedule E-1, line 6, columns (e)(i)
ten PTEP groups. column (g). through (e)(x), based on the type of
PTEP to which such taxes relate.
Line 4. The total reported on
Specific Instructions Related to Schedule E, Part I, Section 1, line 5, Example 2. The facts are the
Lines 1 Through 16 column (l), should be separated into same as in Example 1, except that, in
columns (a) through (e) according to addition, CFC2 distributes $36 to
Line 1a. This amount should equal the type of income or E&P to which CFC1 in Year 3. CFC1 is deemed to
the amount that was reported as the such taxes relate. Therefore, for pay the $4 of withholding tax paid by
balance on line 16 of the prior year example, taxes paid or accrued with CFC2 in Year 2. See section 960(b).
Schedule E-1. respect to the receipt of a PTEP Such tax is attributable to previously
Line 1b. If the balance on line 16 of distribution are reported in column (e), taxed subpart F income and is
prior year Schedule E-1 was adjusted and taxes paid or accrued with reported on line 6, column (e)(x), of
after the filing of the original prior year respect to current year subpart F Schedule E-1 of CFC1’s Form 5471.
Form 5471, such adjustments should income of the foreign corporation are Such tax is also reported as a
be reflected on line 1b. For example, if reported in column (a). negative number on line 10, column
(e)(x), of Schedule E-1 of CFC2’s
there were errors in the original Example 1. Domestic Form 5471.
computation of foreign income taxes, Corporation, a U.S. shareholder,
an adjustment would be included on wholly owns the only class of stock of Line 7. Attach a statement with a
this line. See Corrections to Form CFC1, a foreign corporation. CFC1, in description and the amount of any
5471, earlier. Do not include any turn, wholly owns the only class of adjustments required before taking
adjustments required to be reported stock of CFC2, a foreign corporation. into account taxes deemed paid by
on line 7 or 12. Attach a statement CFC2, in turn, wholly owns the only the foreign corporation. Do not include
that includes an explanation and the class of stock of CFC3, a foreign any adjustments required to be
dollar amount of each such corporation. The functional currency reported on line 1b or 12.
adjustment, along with a total that of Domestic Corporation, CFC1, Line 9. A domestic corporation is
equals the amount entered on line 1b. CFC2, and CFC3 is the U.S. dollar. deemed to pay foreign income taxes
During Year 1, CFC3 has subpart F attributable to inclusions under

Instructions for Form 5471 (Rev. 01-2024) 33

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section 951(a)(1). See section 960(a). Example 4. The facts are the which the foreign corporation was a
Amounts reported on line 9 should be same as in Example 1, except that controlled participant (as defined in
negative numbers. during Year 2, CFC2 invests $40 in Regulations section 1.482-7(j)) during
If a domestic corporation includes U.S. property. At the time of the tax year. All amounts should be
an amount in income under section investment in such property, CFC2 reported in U.S. dollars.
951A, such domestic corporation is continues to maintain a $36 balance
Name of person filing Form 5471.
deemed to pay foreign income taxes in its section 959(c)(2) PTEP account.
The name of the person filing Form
equal to 80% of the product of (a) CFC2 reclassifies such amount as
5471 is generally the name of the U.S.
such domestic corporation’s inclusion section 959(c)(1) PTEP on
person described in the applicable
percentage, multiplied by (b) the Schedule J. Accordingly, $4 of foreign
category or categories of filers (see
aggregate tested foreign income taxes income taxes related to section 959(c)
Categories of Filers, earlier). However,
paid or accrued by the CFC. For the (2) PTEP is reclassified to section
in the case of a consolidated return,
computation of such amount, see 959(c)(1) PTEP on line 11, column (e)
enter the name of the U.S. parent in
Form 1118, Schedule D. Amounts (iii). A negative $4 will be recorded on
the field for “Name of person filing
reported on line 9 should be negative line 11, column (e)(x), and a positive
Form 5471.”
numbers. See line 15 with respect to $4 will be recorded on line 11, column
reporting taxes not deemed paid as a (e)(iii). Reference ID number of foreign
corporation. If applicable, use the
result of the inclusion percentage or Line 12. Attach a statement with a
reference ID number shown on Form
the application of the 80% limitation. description and the amount of any
5471, page 1, item 1b(2).
Line 10. A domestic corporation is required adjustments to taxes of the
deemed to pay foreign income taxes foreign corporation not already taken Question 4. Enter the foreign
with respect to distributions of PTEP. into account on this schedule. An corporation’s share of reasonably
See Section 960(b)(1). Amounts example of amounts reported on anticipated benefits (RAB) for the
reported on line 10 should be negative line 12 is taxes attributable to PTEP CSA during the tax year. See
numbers. distributions to shareholders ineligible Regulations section 1.482-7(e) for
to claim a foreign tax credit under rules on a determining and updating
Taxes are deemed paid by a controlled participant’s RAB share. If
section 960(b)(1) (such as foreign
domestic corporation that is a U.S. the foreign corporation applied more
corporations).
shareholder or a foreign corporation than one RAB share during the tax
that is a CFC with respect to Line 15. Enter the reduction to the
year in determining its share of
distributions of PTEP that it receives. column (b) tested income group for
intangible development costs (IDCs),
Report on line 10, column (e), the tested income taxes not deemed paid.
enter the RAB share that was applied
taxes that relate to PTEP of the See Regulations section 1.960-1. This
to IDCs incurred at the end of the
foreign corporation that are deemed includes taxes attributable to the
year. See Regulations section
paid by a shareholder of the foreign column (b) tested income group that 1.482-7(d) for more information on
corporation, either an upper-tier were not deemed paid as a result of IDCs.
foreign corporation or a U.S. the domestic corporation’s inclusion
shareholder, with respect to a percentage or as a result of the Question 5a. Check the “Yes” box if
distribution of PTEP made by the application of the 80% limit. See the U.S. taxpayer made any platform
foreign corporation. section 960(d). Enter the reduction to contributions as defined in
the three income groups in columns Regulations section 1.482-7(c) to the
Example 3. The facts are the (a), (b), and (c) for other taxes not CSA during the tax year. If “Yes,”
same as in Example 2, except that deemed paid. See Regulations complete lines 5b and 5c.
during Year 4, CFC1 distributes $36 to section 1.960-1. This includes taxes Questions 5b and 5c. Enter the
Domestic Corporation. Domestic that are properly attributable to a foreign corporation's RAB share of the
Corporation is deemed to pay the $4 subpart F income group but were not total present value of all platform
of withholding taxes deemed paid by deemed paid because there was no contributions made by the U.S.
CFC1 in Year 3 and paid by CFC2 in subpart F income with respect to that taxpayer during the tax year with
Year 2. A negative $4 will be recorded income group in the current year. respect to the foreign corporation on
on line 10, column (e)(x), of CFC1’s
line 5b. The total present value of all
Form 5471, Schedule E-1. Note. If necessary, enter negative
platform contributions made by the
See Example 2, earlier, for amounts on line 15 of columns (a),
U.S. taxpayer during the tax year
reporting on line 10, column (e)(x), of (b), and (c) in amounts sufficient to
should be entered even if only a
Schedule E-1 of CFC2's Form 5471 reduce line 16, columns (a), (b), and
portion (or none) of the value of those
with respect to taxes on distributions (c), to zero. Attach a statement
platform contributions was included in
from CFC3 to CFC2. explaining why such taxes were not
the U.S. taxpayer's taxable income as
deemed paid under section 960.
Line 11. Foreign income taxes platform contribution transaction
reclassified from section 959(c)(2) (PCT) payments during the tax year. If
PTEP to section 959(c)(1) PTEP Schedule G-1 possible, include a reasonable
should be reported as negative present value estimate for any PCTs
numbers in columns (e)(vi) through (e) Note. A separate Schedule G-1 must that are priced using a method that
(x) and as positive numbers in be filed for each cost sharing does not involve the calculation of a
columns (e)(i) through (e)(v). arrangement (CSA) as defined in present value. Otherwise, attach a
Regulations section 1.482-7(b) in
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brief statement of the reason(s) it is reasonably allocable to, the IDA as enter on line 1 the dollar GAAP
not possible to include a present value defined in Regulations section income or (loss) from line 22 of
estimate for one or more PCTs (for 1.482-7(d)(1)(i). This would include Schedule C. Enter on lines 2a through
example, no revenue projections for a stock-based compensation granted in 4 the adjustments made in figuring
PCT that is priced based on a earlier years (which could give rise to current E&P for U.S. tax purposes.
sales-based royalty from a 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
If the U.S. taxpayer engaged in reasonably allocable to the IDA. loss figured under Regulations section
1.985-3(d).
multiple PCTs during the tax year with Questions 7a and 7b. For the tax
the foreign corporation and used year, enter the total amount of IDCs Lines 2a through 2i. Certain
different methods to price the PCTs, for the CSA on line 7a. See adjustments (required by Regulations
check the appropriate boxes on Regulations section 1.482-7(d) for section 1.964-1(b) and (c)) must be
line 5c to indicate which methods more information on IDCs. made to the foreign corporation's
were selected as the best method for line 1 net book income or (loss) to
On line 7b, enter the amount of
one or more of the PCTs reported in determine its current year E&P. These
IDCs allocated to the foreign
the tax year. See Regulations section adjustments may include both positive
corporation for the tax year based on
1.482-7(g) for more information on the and negative adjustments to conform
the foreign corporation’s RAB share.
methods applicable to PCTs. the foreign book income to U.S. GAAP
Questions 6b and 6c. See, and to U.S. tax accounting principles.
generally, Regulations section 1.482-7 Schedule H If the foreign corporation's books are
for more information on determining Use Schedule H to report the foreign maintained in functional currency in
whether stock-based compensation is corporation's current year E&P for accordance with U.S. GAAP, enter on
directly identified with, or reasonably U.S. tax purposes. Enter the amounts line 1 the functional currency GAAP
allocable to, the intangible on lines 1 through 5c in the CFC's income or (loss) from line 22 of
development activity (IDA) under the functional currency. Schedule C, rather than starting with
foreign book income, and show
CSA. See Regulations section Certain filers may be able to use
GAAP-to-tax adjustments on lines 2a
1.482-7(d)(3) and Notice 2005-99 for alternative information (as defined in
through 2i.
more information on determining the section 3.01 of Rev. Proc. 2019-40) to
measurement and timing of determine certain amounts in this Lines 2b and 2c. Generally,
stock-based compensation IDCs, schedule. See Item F—Alternative depreciation, depletion, and
including an election available with Information Under Rev. Proc. amortization allowances must be
respect to options on publicly traded 2019-40, earlier, for more details. based on the historical cost of the
stock and certain other stock-based underlying asset, and depreciation
compensation. If the taxpayer made Note. A separate Worksheet H-1 must be figured according to section
the election described in Regulations must be attached for each person 167. However, if 20% or more of the
section 1.482-7(d)(3)(iii)(B) or Notice described in Categories 4, 5a, 5b, and foreign corporation's gross income is
2005-99, the taxpayer should attach a 5c with respect to which reporting is from U.S. sources, depreciation must
statement to Form 5471 explaining furnished on this Form 5471 that is an be figured on a straight line basis
that the taxpayer made such election applicable corporation within the according to Regulations section
and include in such statement the meaning of section 59(k). Worksheet 1.312-15.
total amount of stock-based H-1 and instructions are provided later
compensation taken into account as in these instructions. Line 2f. Inventories must be taken
an IDC for the tax year pursuant to into account according to the rules of
such election. If the taxpayer attaches Note. Category 5b and 5c filers are sections 471 (incorporating the
the statement described in the not required to file Schedule H for provisions of section 263A) and 472
previous sentence, then in the entry foreign-controlled CFCs. and the related regulations.
space provided for line 6b the Name of person filing Form 5471. Line 2g. See the instructions for
taxpayer should include the total The name of the person filing Form Schedule C, Line 21, earlier. Reflect
amount of stock-based compensation 5471 is generally the name of the U.S. differences between the income tax
taken into account as an IDC, person described in the applicable expense (benefit) reported for book
including stock-based compensation category or categories of filers (see purposes and the income taxes
pursuant to the election described Categories of Filers, earlier). However, deducted or added to E&P. Such
above and any not subject to such in the case of a consolidated return, differences include, for example,
election. enter the name of the U.S. parent in deferred income tax expenses,
Check the appropriate box on the field for “Name of person filing uncertain tax positions, intraperiod
line 6c to indicate whether any Form 5471.” allocations, adjustments made after
closing the financial statements
stock-based compensation was Reference ID number of foreign (post-closing adjustments) and not
granted during the term of the CSA to corporation. If applicable, use the reflected in income tax expense
individuals who performed functions reference ID number shown on Form (benefit), and the adjustment for a
in business activities that generate 5471, page 1, item 1b(2). foreign tax redetermination that
cost-shared intangibles that were not
treated as directly identified with, or Special rules for DASTM. If the required a redetermination of the U.S.
foreign corporation uses DASTM, tax liability.

Instructions for Form 5471 (Rev. 01-2024) 35

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Line 2h. Enter the adjustment to corporation. CFC1, in turn, wholly country code for the sanctioned
foreign currency gains or losses. owns the only class of stock of CFC2, country using the two-letter code
Attach a statement with a description a foreign corporation. During Year 1, (from the list at IRS.gov/
of the gain or losses. Domestic Corporation reports an CountryCodes).
inclusion under section 951(a)(1) of
In the case of section 988 losses, Note. The amounts reported on
$100 as a result of subpart F income
determine whether Form 8886 needs line 5c include both foreign source
of CFC2. During Year 2, CFC2
to be completed, as described under and U.S. source income.
distributes $40 to CFC1. CFC1 pays
Additional Filing Requirements,
withholding tax of $4 on the
earlier. Line 5d. Enter the line 5c functional
distribution from CFC2. Such tax is currency amount translated into U.S.
Line 2i. Enter the net amount of any related to previously taxed subpart F dollars at the average exchange rate
additional adjustments not included income. On Domestic Corporation’s for the foreign corporation's tax year.
on lines 2a through 2h. List these financial statements, Domestic See section 989(b). Report the
additional adjustments on a separate Corporation reports the $4 withholding exchange rate using the “divide-by
statement. Attach this statement to tax as current income tax expense. convention” specified under Reporting
Form 5471. Schedule H is only Domestic Corporation reports on Exchange Rates on Form 5471,
prepared for the general, passive, and CFC1’s Form 5471, Schedule H, earlier. If the foreign corporation uses
section 901(j) categories of income. line 2g, a positive adjustment for the DASTM, enter on line 5d the same
For example, if U.S. GAAP income $4 of tax on the PTEP distribution. amount entered on line 5c.
reported on Schedule C contains
Line 5b. DASTM gain or (loss),
items related to PTEP, include the Line 5e. Enter the exchange rate
reflecting unrealized exchange gain or
necessary adjustments on line 2i of used in computing line 5d. Report the
loss, should be entered on line 5b
Schedule H for the appropriate exchange rate using the “divide-by
only for foreign corporations that use
category of income (general or convention” specified under Reporting
DASTM.
passive) and attach a statement that Exchange Rates on Form 5471,
itemizes and explains those Line 5c. The line 5c current year E&P earlier.
adjustments. Report adjustments for amount may include amounts with Blocked income. The E&P of the
foreign taxes related to the PTEP on respect to the general category, foreign corporation, as reflected on
line 2g. This adjustment is necessary passive category, or section 901(j) Schedule H, must not be reduced by
because foreign taxes imposed on category. See Regulations section all or any part of such E&P that could
PTEP distributions do not reduce 1.960-1(d)(2). Enter on lines 5c(i), not have been distributed by the
current year E&P. Foreign taxes 5c(ii), 5c(iii)(A), 5c(iii)(B), 5c(iii)(C), foreign corporation due to currency or
imposed on PTEP distributions and 5c(iii)(D), as applicable, the other restrictions or limitations
reduce PTEP and are reported on portion of the line 5c current year E&P imposed under the laws of any foreign
Schedule J, line 6. amount with respect to each country.
applicable category of income. If
Example. Domestic Corporation, a
applicable for lines 5c(iii)(A), 5c(iii)(B),
U.S. shareholder, wholly owns the
5c(iii)(C), and 5c(iii)(D), also enter the
only class of stock of CFC1, a foreign

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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  . . . . .    . . . . . .  .  1
                                                                              Net            Net  
2  Adjustments made to line 1 (see instructions)                            additions    subtractions
a  Statements covering different taxable years   . .       . . .     2a
b  Consolidated nancial statements .     . . .  . .       . . .     2b
c  Consolidated returns  .      . . .   . . . .  . .       . . .     2c
d  Treatment of dividends and other amounts  .   . .       . . .     2d
e  Treatment of partnerships      . .   . . . .  . .       . . .     2e
f  Effectively connected income  .      . . . .  . .       . . .     2f
g  Adjustments for certain taxes  .     . . . .  . .       . . .     2g
h  Adjustments with respect to disregarded entities  .     . . .     2h
i  Depreciation  .   . .  .     . . .   . . . .  . .       . . .     2i
j  Other adjustments (see instructions)  .  . .  . .       . . .     2j
3  Total net additions  . .     . . .   . . . .  . .       . . .     3
4  Total net subtractions .     . . .   . . . .  . .       . . .     4
5a Adjusted net income or loss (line 1 plus line 3 minus line 4) .   . .  . . . .    . . . . . .  .  5a
b  Filer’s pro rata share of line 5a (see instructions)  . . . . .   . .  . . . .    . . . . . .  .  5b
c  Adjusted net income or loss in U.S. dollars (see instructions)  . . .  . . . .    . . . . . .  .  5c
d  Enter exchange rate used for line 5c  .  . .  . .       . . . .   . .  . . .      5d

Worksheet H-1 Instructions                inclusions by U.S. shareholders under        completed once (for general category 
Use Worksheet H-1 to report the           section 951A. The information in this        income, passive category income, or 
CFC’s adjusted net income or loss for     schedule will be used by the U.S.            both). A Schedule I-1 that includes 
corporate alternative minimum tax         shareholder(s) of the CFC to file Form       passive category income on line 6 
(CAMT) purposes. Enter the amounts        8992, U.S. Shareholder Calculation of        must include the code for passive 
on lines 1 through 5b in the CFC’s        Global Intangible Low-Taxed Income           category income (PAS) in the entry 
functional currency.                      (GILTI), and may assist in the               space for separate category (at the 
                                          completion of Form 1118 or Form              top of Schedule I-1). This is the case 
Lines 2a through 2j. Certain              1116, if applicable.                         even if the Schedule I-1 also includes 
adjustments (required by section                                                       general category income. With 
56A(c)) must be made to the foreign         Enter the amounts on lines 1               respect to a taxpayer completing 
corporation’s line 1 net book income      through 10c in the CFC's functional          Schedule I-1 with respect to a foreign 
or (loss) to determine its adjusted net   currency. The functional currency            corporation with only general category 
income or loss for CAMT purposes.         amounts entered on lines 6 through           income (and no passive category 
These adjustments may include both        10c must be converted to U.S. dollars.       income) on line 6, the taxpayer should 
positive and negative adjustments.          Certain filers may be able to use          enter the code “GEN” in the entry 
Line 2j. Enter the net amount of any      alternative information (as defined in       space for separate category.
additional adjustments not included       section 3.01 of Rev. Proc. 2019-40) to 
on lines 2a through 2i. List these        determine certain amounts in this            Note. The other reporting 
additional adjustments on a separate      schedule. See Item F—Alternative             requirements of a taxpayer that 
statement. Attach this statement to       Information Under Rev. Proc.                 includes passive category income 
Form 5471.                                2019-40, earlier, for more details.          with general category income on a 
                                                                                       Schedule I-1 do not change because 
Line 5b. Enter the filer’s pro rata       Name of person filing Form 5471.             the taxpayer includes passive 
share (determined under rules similar     The name of the person filing Form           category income with general 
to the rules under section 951(a)(2))     5471 is generally the name of the U.S.       category income on a Schedule I-1. 
of the amount on line 5a.                 person described in the applicable           For example, the taxpayer may still be 
                                          category or categories of filers (see 
Line 5c. Enter the line 5b functional                                                  required to complete a Form 1116 or a 
                                          Categories of Filers, earlier). However, 
currency amount translated into U.S.                                                   Form 1118, and/or a Form 5471 
                                          in the case of a consolidated return, 
dollars for the CFC’s tax year.                                                        (including Schedule J and 
                                          enter the name of the U.S. parent in         Schedule P), and separately report 
                                          the field for “Name of person filing         passive category income and section 
Schedule I-1                              Form 5471.”                                  951A category income.
This schedule is used to report           Separate category.         Schedule I-1 is   Line 1. Enter the CFC’s gross 
information determined at the CFC         no longer completed separately for           income. The amount of gross income 
level with respect to amounts used in     each applicable category of income.          entered on line 1 will generally be a 
the determination of income               Therefore, Schedule I-1 is now 

Instructions for Form 5471 (Rev. 01-2024)                                                                                       37

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positive amount. However, if a CFC’s Line 3. Combine lines 2a through 2e. the CFC. See Regulations section
cost of goods sold exceeds its gross The line 3 result can be positive or 1.951A-1(d)(1).
receipts, a negative amount is negative. Qualified business asset
permitted on line 1.
Line 4. Subtract line 3 from line 1 and investment (QBAI). QBAI is the
Line 2. Enter the CFC’s exclusions as enter the result on line 4. The line 4 average of the CFC's aggregate
described in Regulations section result can be positive or negative. For adjusted bases, as of the close of
1.951A-2(c). example: each quarter of its tax year, in
specified tangible property used in its
Line 2a. Enter the amount of the
CFC’s income or loss described in Line 1 trade or business in the production of
gross tested income, and for which a
section 952(b), which is generally income $1,000 $1,000 $(1,000) $(1,000) deduction is allowable under section
income or loss from sources within the Line 3 total 167. Adjusted basis in any property
United States that is effectively exclusions 800 (800) 800 (800) must be determined by using the
connected to the conduct of a trade or Line 4 alternative depreciation system under
business by the CFC in the United (line 1 section 168(g) and allocating
States and not reduced or exempt minus
from tax pursuant to an income tax line 3) $200 $1,800 $(1,800) $(200) depreciation deductions with respect
treaty with the United States. to such property ratably to each day
during the period in the tax year to
Line 2b. Enter the amount, if any, Line 5. Enter the deductions which such depreciation relates.
of the CFC’s gross income or loss (including taxes) properly allocable to Specified tangible property and
taken into account in determining the the amount on line 4 (or to which such dual-use property. Specified
CFC’s subpart F income (as defined in deductions would be allocable if there tangible property means any tangible
section 952). Note that an amount were such gross income). See section property used in the production of
determined under section 956(a) is 951A(c)(2)(A)(ii) and Regulations tested income. If such property was
not considered subpart F income. The section 1.951A-2(c)(3). The amount used in the production of tested
amount to be entered is computed entered on line 5 will generally be a income and income that is not tested
after application of the high-tax positive amount. However, a negative income (that is, dual-use property),
exception in section 954(b)(4), but amount is permitted on line 5. the property is treated as specified
before application of the E&P
limitation in section 952(c)(1)(A). Line 6. Subtract line 5 from 4 and tangible property in the same
enter the result on line 6. The line 6 proportion that the amount of tested
Line 2c. Enter the amount, if any, result can be positive or negative. See income determined before allocable
of the CFC’s gross income excluded the line 4 instructions above for deductions (that is, line 4) produced
from foreign base company income examples. This amount must be with respect to the property bears to
(as defined in section 954) and converted from functional currency to the total amount of gross income
insurance income (as defined in U.S. dollars using the average produced with respect to the property.
section 953) by reason of section exchange rate for the year of the CFC. Partnership property. A CFC
954(b)(4), the high-tax exception See Regulations section 1.951A-1(d) with tested income that is a partner of
(include amounts excluded from (1). a partnership that has depreciable
tested income under Regulations
Report the exchange rate using the tangible property determines its share
section 1.951A-2(c)(7)).
“divide-by convention” specified under of the partnership’s average adjusted
Line 2d. Enter the amount of any Reporting exchange rates on Form basis in the depreciable tangible
dividend income received by the CFC 5471, earlier. property of the partnership based on
from a related person as defined in Line 7. If the CFC has a tested loss the amount of the distributive share of
section 954(d)(3). Do not include the on line 6, enter zero. If the CFC has the gross income produced by the
amounts of any dividend income tested income on line 6, enter only property that is included in the CFC’s
received from a related person that those foreign income taxes that are gross tested income (defined below)
are already included in the amounts properly attributable to the CFC’s relative to the total amount of gross
entered on line 2b or line 2c. tested income group. This amount income produced by the property. The
Line 2e. Enter the amount of the must be converted from functional partnership’s average adjusted basis
CFC’s taxable income or loss from currency to U.S. dollars using the in the depreciable tangible property of
sources outside the United States and average exchange rate for the year of the partnership is generally
its territories from the following. the CFC. See section 986. determined based on the average of
the adjusted basis in the property as
• The extraction (by the corporation Line 8. If the CFC has a tested loss of the close of each quarter of the
or any other person) of minerals from on line 6, enter zero. If the CFC has partnership’s tax year that ends with
oil or gas wells located outside the tested income on line 6, enter the or within the CFC’s tax year. See
United States and its territories. qualified business asset investment Regulations section 1.951A-3(g).
• The sale or exchange of assets (QBAI) (defined below). This amount
used (by the corporation) in the trade must be converted from functional Gross tested income. For these
or business of extracting minerals currency to U.S. dollars using the purposes, a CFC’s gross tested
from oil or gas wells located outside average exchange rate for the year of income is its gross income less total
the United States and its territories. exclusions (Schedule I-1, line 4).

38 Instructions for Form 5471 (Rev. 01-2024)

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Lines 9a through 9d. In general, the field for “Name of person filing PTEP amounts required to be
see Regulations section 1.951A-4(b) Form 5471.” included in column (e). If the person
filing Form 5471 is unable to
(1) to determine how to compute the Reference ID number of foreign
determine whether amounts should
CFC’s tested interest expense. corporation. If applicable, use the
be reported as PTEP, those amounts
Line 9a. Enter the amount of reference ID number shown on Form
should be included in column (a),
interest expense included on line 5. 5471, page 1, item 1b(2).
Post-2017 E&P Not Previously Taxed
See Line 6, earlier, for foreign Lines a and b. Complete a separate (post-2017 section 959(c)(3)
currency translation. Schedule J for each applicable balance). For example, one U.S.
separate category of income. Enter
Line 9b. Enter the CFC’s qualified shareholder might not know the
the appropriate code on line a (at the
interest expense, as defined in amount of the other U.S.
top of page 1 of Schedule J). To
Regulations section 1.951A-4(b)(1) shareholder’s section 951A inclusion
determine the appropriate code, see
(iii). that is allocated to the CFC because
Categories of Income in the the first U.S. shareholder does not
Line 9c. Enter the CFC’s tested Instructions for Form 1118. E&P with have information with respect to the
loss QBAI amount, as defined in respect to all categories of income second U.S. shareholder’s net CFC
Regulations section 1.951A-4(b)(1) listed in the Instructions for Form tested income or pro rata share of
(iv). 1118, except foreign branch category QBAI. See the instructions for
income, may need to be reported. A
Line 9d. Subtract the sum of Schedule P, later, for an example.
foreign corporation may have E&P in
line 9b and line 9c from line 9a and Enter the amounts in this schedule
an income group within the general
enter the result on line 9d. in the functional currency of the
category, passive category, or section
Lines 10a through 10c. In general, 901(j) category. See Regulations foreign corporation as reported on
see Regulations section 1.951A-4(b) section 1.960-1(d)(2)(ii). A foreign Form 5471, page 1, item 1h. If the
(2) to determine how to compute the corporation may have PTEP in a foreign corporation is the owner of a
CFC’s tested interest income. PTEP group within any of the separate qualified business unit(s) (QBU) with a
categories of income, except foreign different functional currency, translate
Line 10a. Enter the amount of the E&P of the QBU(s) to the foreign
branch category income. See
interest income included on line 4. corporation’s functional currency.
Regulations section 1.960-3(c)(1).
See Line 6, earlier, for foreign
currency translation. If code 901j is entered on line a, Columns (a), (b), and (c)
enter on line b the country code for Report the opening balance, current
Line 10b. Enter the CFC’s the sanctioned country using the year additions and subtractions, and
qualified interest income, as defined in two-letter code (from the list at the closing balance in the foreign
Regulations section 1.951A-4(b)(2) IRS.gov/CountryCodes). corporation's E&P described in
(iii). section 959(c)(3). In general, this is
Note. A separate Schedule J should
Line 10c. Subtract line 10b from E&P of the foreign corporation that
not be completed for the section 951A
line 10a and enter the result on has not been included in gross
category. Reclassified section 951A
line 10c. income of a U.S. person under section
PTEP and section 951A PTEP that is 951(a)(1) and section 951A.
in the section 951A category should
Schedule J be reported on the general category In column (a), report E&P
Use Schedule J to report a CFC’s Schedule J. described in section 959(c)(3) and
accumulated E&P in its functional earned after the repeal of section 902,
Note. For purposes of this
currency, computed under sections that is, post-2017 E&P not previously
Schedule J, include in each separate
964(a) and 986(b). Also use this taxed (post-2017 section 959(c)(3)
category of income, foreign source
schedule to report the E&P of balance). The repeal of section 902 is
and U.S. source income.
specified foreign corporations that are effective for tax years of foreign
only treated as CFCs for limited Important. In addition to the corporations beginning after
purposes under section 965(e)(2). separate category codes referred to December 31, 2017, and to tax years
above, if you have more than one of of U.S. shareholders in which or with
Note. Category 1b, 1c, 5b, and 5c the categories of income referred to which such tax years of foreign
filers are not required to file above, you must complete and file a corporations end.
Schedule J for foreign-controlled separate Schedule J using code In column (b), report post-1986
section 965 SFCs or “TOTAL” that aggregates all amounts undistributed earnings, as defined
foreign-controlled CFCs. listed for each line and column in Part under section 902(c)(1), and as in
Name of person filing Form 5471. I of all other Schedules J. effect prior to the repeal of section
902.
The name of the person filing Form Part I—Accumulated E&P of
5471 is generally the name of the U.S. Use column (c) to report the
Controlled Foreign Corporation
person described in the applicable aggregate amount of the foreign
category or categories of filers (see Check the box at the top of Part I if the
Categories of Filers, earlier). However, person filing Form 5471 does not have corporation's pre-1987 section 964(a)
in the case of a consolidated return, all U.S. shareholders’ information E&P accumulated since 1962 and not
enter the name of the U.S. parent in necessary to complete any one of the previously distributed or deemed
distributed. These amounts are

Instructions for Form 5471 (Rev. 01-2024) 39

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figured in U.S. dollars using the rules investments in U.S. property (section   attributable to a distribution of such 
of Regulations section 1.964-1(a)       959(c)(1) amounts).                     PTEP. See section 965(g) and 
through (d), and translated into the    • Column (e)(v) is PTEP described in    Regulations section 1.965-5 for more 
foreign corporation's functional        the following three subgroups (which    information. This is the case for both 
currency according to Notice 88-70,     are aggregated into a single PTEP       direct foreign tax credits (that is, those 
1988-2 C.B. 369.                        group) (section 959(c)(1) amounts).     foreign taxes paid or accrued directly 
Column (d)                                1. PTEP attributable to hybrid        by the shareholder upon receipt of the 
                                        dividends under section 245A(e)(2)      PTEP distribution and allowed as a 
Use column (d) to report hovering                                               credit under section 901 or 903) and 
                                        and reclassified as investments in 
deficits (see section 381(c)(2)(B) and                                          indirect foreign tax credits (that is, 
                                        U.S. property.
Regulations section 1.367(b)-7) and                                             those taxes deemed paid by the 
suspended taxes (see section 909).        2. PTEP attributable to section 
                                                                                shareholder with respect to taxes 
See Specific Instructions Related to    1248 amounts under section 959(e) 
                                                                                originally paid or accrued by the CFC 
Lines 1 Through 13, later, for          and reclassified as investments in 
                                                                                under section 960(b)). With respect to 
additional information pertaining to    U.S. property.
                                                                                direct credits, this reduction applies 
reporting amounts in column (d).          3. PTEP attributable to section       regardless of whether such individual 
                                        1248 amounts from the gain on the 
Column (e)                                                                      made an election under section 962. 
                                        sale of foreign corporation stock by a  Therefore, the reporting on 
Use column (e) to report the running    CFC and reclassified as investments     Schedule J is necessary regardless of 
balance of the foreign corporation's    in U.S. property.                       whether the U.S. shareholder made a 
PTEP, section 964(a) E&P                • Column (e)(vi) is PTEP attributable   section 962 election.
accumulated since 1962 that have        to section 965(a) inclusions (section 
resulted in deemed inclusions under     959(c)(2) amounts). Do not include in   Column (f)
subpart F, or amounts treated as        column (e)(vi) E&P reported in column   Use column (f) to report the opening 
PTEP under section 965(b)(4)(A).        (e)(vii).                               and closing balances of the foreign 
Pre-1987 U.S. dollar PTEP should be     • Column (e)(vii) is E&P treated as     corporation's accumulated E&P. This 
translated into the foreign             PTEP under section 965(b)(4)(A)         amount is the sum of post-2017 E&P 
corporation's functional currency       (section 959(c)(2) amounts).            not previously taxed, post-1986 
using the rules of Notice 88-70 and     • Column (e)(viii) is PTEP attributable undistributed earnings, pre-1987 E&P 
added to post-1986 amounts in the       to section 951A inclusions (section     not previously taxed, and PTEP. Do 
appropriate PTEP group.                 959(c)(2) amounts).                     not include column (d) amounts in the 
• Columns (e)(i) and (e)(ii) are PTEP   • Column (e)(ix) is PTEP described in   total reported in column (f).
originally attributable to inclusions   the following three subgroups (which 
                                                                                Specific Instructions Related to 
under section 965(a) and E&P treated    are aggregated into a single PTEP 
as PTEP under section 965(b)(4)(A),     group) (section 959(c)(2) amounts).     Lines 1 Through 13
respectively, and reclassified as                                               Line 1a. Enter the balances for each 
                                          1. PTEP attributable to hybrid 
investments in U.S. property (section                                           column at the beginning of the tax 
                                        dividends under section 245A(e)(2).
959(c)(1) amounts).                                                             year. These balances should equal 
• Column (e)(iii) is PTEP described in    2. PTEP attributable to section 
the following three subgroups (which    1248 amounts under section 959(e).      the amounts reported as the ending 
                                                                                balances in the prior year Schedule J.
are aggregated into a single PTEP         3. PTEP attributable to section 
group) (section 959(c)(1) amounts).     1248 amounts from the gain on the       Line 1b. If there is a difference 
  1. PTEP attributable to               sale of foreign corporation stock by a  between last year’s ending balance on 
investments in U.S. property and not    CFC.                                    Schedule J and the amount that 
by reason of reclassification.          • Column (x) is PTEP attributable to    should be last year’s ending balance, 
                                        section 951(a)(1)(A) inclusions         taking into account modifications on 
  2. PTEP attributable to inclusions                                            Schedule J, include the difference on 
                                        (section 959(c)(2) amounts) not 
under section 951(a)(1)(A) (other than                                          line 1b and attach an explanation for 
                                        otherwise described in the 
inclusions under section 951(a)(1)(A)                                           the difference. If there are multiple 
                                        instructions for columns (e)(vi) 
described in the instructions for                                               reasons for differences, include the 
                                        through (ix).
columns (e)(vi) through (ix)) and                                               explanation and amount of each such 
reclassified as investments in U.S.       Schedule J reports PTEP by            difference on the attachment. Do not 
property (for example, PTEP             subgroups because those groups may      include adjustments required to be 
attributable to subpart F income        be subject to different rules under     reported on line 6 or 12.
inclusions and reclassified as          sections 960, 965(g), 245A(e)(3), and 
investments in U.S. property).          986(c). The different rules are         Lines 1a through 1c. These lines of 
  3. PTEP attributable to inclusions    applicable for individuals, as well as  column (d) account for the balance of 
under former section 951(a)(1)(C) and   corporations, estates, and trusts. For  prior year hovering deficits and 
subpart F income inclusions             example, an individual U.S.             suspended taxes that have not yet 
reclassified as investments in excess   shareholder who receives a              been deducted. Such amounts are 
passive assets.                         distribution of PTEP originally         reported as negative numbers.
• Column (e)(iv) is PTEP originally     attributable to inclusions under        Line 2a. This line of column (d) is the 
attributable to inclusions under        section 965(a) may only claim a credit  unsuspended taxes under section 909 
section 951A and reclassified as        for a portion of the foreign taxes      as a result of related income taken 

40                                                                              Instructions for Form 5471 (Rev. 01-2024)

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into account by the foreign              nonrecognition transaction. See          (1)(A) or section 951A with respect to 
corporation, certain U.S. corporate      section 381(c)(2)(B) and Regulations     the CFC. Report the inclusion as a 
owners of the foreign corporation, or a  section 1.367(b)-7(d)(2)(i) (post-1986   negative amount in columns (a) 
member of such U.S. corporate            undistributed earnings) and              through (c), as applicable. Report the 
owner’s consolidated group. Report       1.367(b)-7(e)(1) (pre-1987 E&P not       inclusion as a positive amount in 
the unsuspended taxes on line 2a of      previously taxed). An amount equal to    columns (e)(vi) through (e)(x), as 
column (d) as a positive number.         the deficit reported in column (a), (b), applicable. Amounts reported as 
Report the unsuspended taxes as          or (c) of line 5a is included as a       positive numbers on line 8 of column 
negative numbers on line 2a of           positive amount on line 5b of column     (e)(viii) should only be reported with 
column (a), (b), (c), or (e), as         (a), (b), or (c), respectively. An amount  respect to negative amounts on line 8 
applicable.                              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) 
                                         and (c) is included as a negative        Schedule J than the positive amounts 
accounts for foreign income taxes that 
                                         number in column (d) of line 5b.         if such amounts are reclassified from 
are suspended in the current tax year. 
                                                                                  one separate category to another 
Report such amounts as negative          Line 6. Attach a statement detailing 
numbers.                                 the nature and amount of any             separate category.
                                         adjustments not accounted for in the 
Line 3. Enter the current year E&P (or                                            Note. Section 951(a)(1)(A) inclusions 
                                         E&P determined before reduction for 
deficit in E&P) amount from the                                                   are taken into account for the tax year 
                                         distributions and inclusions (that is, 
applicable line 5c of Schedule H                                                  before actual distributions and section 
                                         adjustments other than those listed on 
(Form 5471). For example, if you are                                              951(a)(1)(B) inclusions. See section 
                                         lines 2a through 5b). Do not include 
completing Schedule J for the passive                                             959.
                                         amounts reported on line 1b. An 
category (that is, you have entered 
                                         example of an adjustment entered on 
“PAS” on line a at the top of page 1 of                                           Note. The amount included in gross 
                                         line 6 is the foreign taxes imposed on 
Schedule J), enter the current year                                               income of U.S. shareholders of the 
                                         receipt of a distribution of PTEP from 
E&P (or deficit in E&P) amount from                                               CFC under section 951A might not be 
                                         a lower-tier foreign corporation.
Schedule H (Form 5471), line 5c(ii), in                                           known if there is more than one U.S. 
the applicable column. Line 3 should      Example.    Domestic Corporation, a     shareholder. In that case, see the 
never have an amount entered in          U.S. shareholder, wholly owns the        example in the instructions for 
column (e).                              only class of stock of CFC1, a foreign   Schedule P for reporting information.

Line 4. Report as a positive number      corporation. CFC1, in turn, wholly       Note. The amount reported in column 
E&P attributable to distributions of     owns the only class of stock of CFC2,    (e)(viii) on line 8 will not necessarily 
PTEP from lower-tier foreign             a foreign corporation. CFC2, in turn,    equal the tested income reported on 
corporations. Generally, the E&P of a    wholly owns the only class of stock of   Schedule I-1. For an example of when 
CFC attributable to amounts that are,    CFC3, a foreign corporation. The         this might occur, see Regulations 
or have been, included in the gross      functional currency of Domestic          section 1.951A-5(b)(2)(ii).
income of a U.S. shareholder under       Corporation, CFC1, CFC2, and CFC3 
section 951(a) are not, when             is the U.S. dollar. During Year 1,       Line 9. Report actual distributions as 
distributed through a chain of           Domestic Corporation reports an          negative numbers.
ownership described in section           inclusion under section 951(a)(1) of 
958(a), also included in the gross       $100 as a result of subpart F income     Note. Actual distributions are taken 
income of another CFC in such chain      of CFC3. During Year 2, CFC3             into account for the tax year before 
for purposes of the application of       distributes $40 to CFC2. CFC2 pays       section 951(a)(1)(B) inclusions. See 
section 951(a) to such other CFC with    withholding tax of $4 on the             section 959(f)(2). An actual 
respect to such U.S. shareholder. See    distribution from CFC3. Such tax is      distribution is first out of PTEP, if any, 
section 959(b).                          related to previously taxed subpart F    and then out of the section 959(c)(3) 
                                         income. Domestic Corporation reports     balance. See section 959(c).
Line 5a. Enter earnings carried over     on CFC2’s Form 5471, Schedule J, 
                                                                                  Note. The total of all amounts 
to a foreign surviving corporation after line 4, column (e)(x), as a positive 
                                                                                  entered in Schedule R (Form 5471), 
an acquisition by a foreign corporation  number, the $40 PTEP distribution. 
                                                                                  column (d), must equal the amount on 
of the assets of another foreign         Domestic Corporation reports on 
                                                                                  line 9, column (f), of the Schedule J 
corporation in a transaction described   line 6, column (e)(x), as a negative 
                                                                                  (Form 5471) that is filed, or if more 
in section 381. See Regulations          number, the $4 of tax on the PTEP 
                                                                                  than one Schedule J (Form 5471) is 
section 1.367(b)-7. The amounts          distribution.
entered on line 5a may be negative or                                             filed, the Schedule J (Form 5471) with 
positive. Negative amounts are           Line 7. Enter on line 7 E&P as of the    code “TOTAL” entered on line a of that 
hovering deficits reported in column     close of the tax year before actual      Schedule J.
(d) of line 5a.                          distributions or inclusions under 
                                                                                  Line 10. Use line 10 to report 
                                         section 951(a)(1) or section 951A 
                                                                                  reclassifications of section 959(c)(2) 
Line 5b. If the foreign surviving        during the year.
corporation had a deficit in E&P prior                                            PTEP in columns (e)(vi) through (e)(x) 
to a transaction described in section    Line 8. Enter amounts included in        to section 959(c)(1) PTEP in columns 
381, such deficit is recharacterized as  gross income of the U.S.                 (e)(i) through (e)(v). A potential 
a hovering deficit after such            shareholder(s) under section 951(a)      section 951(a)(1)(B) inclusion results 

Instructions for Form 5471 (Rev. 01-2024)                                                                                41

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in a reclassification of section 959(c) category or categories of filers (see specified other amounts received
(2) PTEP, if any, to section 959(c)(1) 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
section 959(c)(3) E&P balance. See enter the name of the U.S. parent in persons listed in the headings for
section 959(a)(2) and (f)(1). The the field for “Name of person filing columns (b) through (f). These
amounts reclassified are reported as Form 5471.” headings must comport to those used
negative numbers in columns (e)(vi) on the Schedule M (Form 5471) to
Reference ID number of foreign
through (e)(x) and positive numbers in which this statement is attached. The
corporation. Use the reference ID
columns (e)(i) through (e)(v), as attached statement must include a
number shown on Form 5471, page 1,
applicable. “totals” line that ties into the amounts
item 1b(2).
reported in each column of line 14.
Line 11. Use this line to report E&P
Lines 4 and 19. Report on these
not previously taxed, which is treated If an amount is entered on line 29,
lines platform contribution transaction
as earnings invested in U.S. property you must attach a statement that
payments received and paid by the
and, therefore, reclassified to section includes the following information.
foreign corporation (without giving
959(c)(1) PTEP (column (e)(iii)). The Column (a) of the attached statement
effect to any netting of payments).
amounts reclassified are reported as should provide a description of the
See Regulations section 1.482-7(b)(1)
negative numbers in columns (a) type of other amount paid during the
(ii).
through (c) and positive numbers in annual accounting period. Columns
column (e)(iii), as applicable. Lines 5 and 20. Report on these (b) through (f) should provide dollar
lines cost sharing transaction amounts of the specified other
Line 12. Attach a statement detailing amounts paid during the annual
payments received and paid by the
the nature and amount of any accounting period by the foreign
foreign corporation (without giving
adjustments in E&P not accounted for corporation to the persons listed in the
effect to any netting of payments).
on lines 8 through 11. Do not include headings for columns (b) through (f).
See Regulations section 1.482-7(b)(1)
adjustments required to be reported These headings must comport to
(i). The corporation is required to
on line 1b or line 6. those used on the Schedule M (Form
complete line 5 only if the corporation
Line 13. The hovering deficit offset itself incurred intangible development 5471) to which this statement is
included in column (d) is reported as a costs. If the corporation does not itself attached. The attached statement
positive number. The same amount incur intangible development costs, must include a “totals” line that ties
entered in column (d) is reported as a then it should only report cost sharing into the amounts reported in each
negative number on line 13 of column transaction payments made on column of line 29.
(a) or (b), as appropriate. See section line 20. Lines 31 and 33. Report on these
381(c)(2)(B) and Regulations section lines the largest aggregate
Lines 9 and 24. Report on line 9 the
1.367(b)-7(d)(2)(ii). outstanding accounts receivable and
sum of tiered hybrid dividends
received by the foreign corporation payable balances during the year with
Schedule M during its tax year. Report on line 24 the related parties described in
Every U.S. person described in the sum of hybrid dividends or tiered columns (b) through (f). Report only
Category 4 must file Schedule M to hybrid dividends paid by the foreign accounts receivable or payable arising
report the transactions that occurred corporation during its tax year. in connection with the provision of
services or the sale or processing of
during the foreign corporation's Lines 10 and 25. Report on these
property. Only net accounts receivable
annual accounting period ending with lines dividends received and paid by
and payable to the extent that the
or within the U.S. person's tax year. the foreign corporation not previously
CFC’s books net the accounts
If a U.S. corporation that owns taxed under subpart F in the current
payable against the receivable as
stock in a foreign corporation is a year or in any prior year.
payment of the accounts receivable.
member of a consolidated group, list Lines 13 and 28. Report on these
Lines 32 and 34. Report on these
the common parent as the U.S. lines loan guarantee fees received
lines the largest outstanding balances
person filing Schedule M. (line 13) and loan guarantee fees paid
during the year of gross amounts
(line 28). See section 482.
Important. In translating the amounts borrowed from, and gross amounts
from functional currency to U.S. Lines 14 and 29. Report on these loaned to, the related parties
dollars, use the average exchange lines “other amounts received” described in columns (b) through (f).
rate for the foreign corporation's tax (line 14) and “other amounts paid” Do not enter aggregate cash flows,
year. See section 989(b). Report the (line 29). year-end loan balances, average
exchange rate in the entry space If an amount is entered on line 14, balances, or net balances. Do not
provided at the top of Schedule M you must attach a statement that include an account receivable or
using the “divide-by convention” includes the following information. payable balance arising in connection
specified under Reporting exchange Column (a) of the attached statement with the provision of services or the
rates on Form 5471, earlier. should provide a description of the sale or processing of property if the
type of other amounts received during amount of such balance does not, at
Name of person filing Form 5471. any time during the tax year, exceed
the annual accounting period.
The name of the person filing Form what is ordinary and necessary to
Columns (b) through (f) should
5471 is generally the name of the U.S. carry on the trade or business. Any
provide dollar amounts of the
person described in the applicable
42 Instructions for Form 5471 (Rev. 01-2024)

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outstanding balance from these Part II • Enters “5,000” in column (e)(1).
transactions should be reported on • Enters “-0-” in column (f) because
Section A—General Shareholder
the Balance Sheet (Form 5471, the disposition was by gift.
Schedule F, page 4) and possibly also Information • Enters the name and address of his
on Schedule M, lines 31 and 33. son, John, in column (g).
If the shareholder's latest tax return
Accrued payments and receipts. A was filed electronically, enter “e-filed” Section F—Additional Information
corporation that uses an accrual in column (b)(3) instead of a service
method of accounting must use center. Item (b). List the date of any
accrued payments and accrued reorganization of the foreign
receipts for purposes of computing corporation that occurred during the
Section C—Acquisition of Stock
the total amount to enter on each line last 4 years while any U.S. person
of Schedule M. held 10% or more in value or vote
Section C is completed by
shareholders who are completing (directly or indirectly) of the
Schedule O Schedule O because they have corporation's stock. If there is more
Schedule O is used to report the acquired sufficient stock in a foreign than one such date, use the most
organization or reorganization of a corporation. If the shareholder recent date. However, do not enter a
foreign corporation and the acquisition acquired the stock in more than one date for which information was
or disposition of its stock. transaction, use a separate line to reported in Section E. Instead, enter
report each transaction. the date (if any) of any reorganization
Every U.S. citizen or resident prior to that date (if it is within the last
described in Category 2 must Column (d). Enter the method of 4 years).
complete Part I. Every U.S. person acquisition (for example, purchase,
described in Category 3 must gift, bequest, trade). Example for item (c). Mr. Lyons,
a U.S. person, acquires a 10%
complete Part II. Column (e)(2). Enter the number of ownership in foreign corporation F. F
See Regulations section shares acquired indirectly (within the is the 100% owner of two foreign
1.6046-1(i) for rules on determining meaning of section 958(a)(2)) by the corporations, FI and FJ. F is also a
when U.S. persons constructively own shareholder listed in column (a). 50% owner of foreign corporation FK.
stock of a foreign corporation and are Column (e)(3). Enter the number of In addition, F is 90% owned by foreign
therefore subject to the section 6046 shares constructively owned (within corporation W. Mr. Lyons does not
filing requirements. the meaning of section 958(b)) by the own any of the stock of corporation W.
Name of person filing Form 5471. shareholder listed in column (a). Mr. Lyons completes and files Form
The name of the person filing Form 5471 and Schedule O for the
5471 is generally the name of the U.S. Section D—Disposition of Stock corporations in which he is a
person described in the applicable 10%-or-more shareholder. Mr. Lyons
category or categories of filers (see Section D must be completed by is also required to submit a chart if the
Categories of Filers, earlier). However, shareholders who dispose of their foreign corporation is a member of a
in the case of a consolidated return, interest (in whole or in part) in a chain of corporations, and to indicate
enter the name of the U.S. parent in foreign corporation. if he is a 10%-or-more shareholder in
any of those corporations.
the field for “Name of person filing Column (d). Enter the method of
Form 5471.” disposition (for example, sale, Mr. Lyons would prepare a list
Reference ID number of foreign bequest, gift, trade). showing the corporations as follows.
• Corporation W.
corporation. Use the reference ID Example. In 1999, Mr. Jackson, a • Corporation F.
number shown on Form 5471, page 1, U.S. citizen, purchased 10,000 shares • Corporation FI.
item 1b(2). of common stock of foreign • Corporation FJ.
Part I corporation X. The purchase • Corporation FK.
represented 10% ownership of the
Then Mr. Lyons is required to
Column (d). Enter the date the foreign corporation.
shareholder first acquired 10% or indicate that he is a 10%-or-more
more (in value or voting power) of the On July 1, 2023, Mr. Jackson made shareholder in corporations F, FI, and
outstanding stock of the foreign a gift of 5,000 shares of foreign FJ.
corporation. corporation X to his son, John.
Because Mr. Jackson has reduced his
Column (e). Enter the date the holding in the foreign corporation, he Schedule P
shareholder acquired (whether in one is required to complete Form 5471 Use Schedule P to report the PTEP in
or more transactions) an additional and Schedule O. To show the required the U.S. shareholder’s annual PTEP
10% or more (in value or voting information about the disposition, Mr. accounts with respect to a CFC in the
power) of the outstanding stock of the Jackson completes Section D as CFC’s functional currency (Part I) and
foreign corporation. follows. the U.S. shareholder’s U.S. dollar
• Enters his name in column (a). basis in that PTEP (Part II). For
• Enters “common” in column (b). purposes of the preceding sentence,
• Enters “July 1, 2023” in column (c). a CFC includes an SFC that is only
• Enters “gift” in column (d).

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treated as a CFC for limited purposes respect to its PTEP of $50x on line 8, “TOTAL” that aggregates all amounts
under section 965(e)(2). column (e)(viii). In the following year, listed for each line and column of all
Corporation A and Corporation B other Schedules P.
Note. A separate Schedule P must should each report the other
be completed by each Category 1a, corporation’s PTEP on Schedule J, Part I
1b, 4, 5a, or 5b filer. Part I, line 1b, column (e)(viii), and the Enter amounts in the functional
If a U.S. shareholder wholly owns corresponding reduction to CFC1’s currency of the foreign corporation as
the CFC, Schedule P should include E&P described in section 959(c)(3) on reported on Form 5471, page 1, item
the same information reported on Schedule J, Part I, line 1b, column (a). 1h.

Schedule J, Part I, column (e). If there Name of person filing Form 5471. Pre-1987 U.S. dollar PTEP should
is more than one U.S. shareholder, the The name of the person filing Form be translated into the foreign
amounts reported on Schedule P with 5471 is generally the name of the U.S. corporation's functional currency
respect to each U.S. shareholder person described in the applicable using the rules of Notice 88-70 and
might be different from the amounts category or categories of filers (see added to post-1986 amounts in the
reported on Schedule J. Categories of Filers, earlier). However, appropriate PTEP category.
Example. Corporation A, a in the case of a consolidated return,
domestic corporation, owns 50% of enter the name of the U.S. parent in Part II
the only class of stock of CFC1, and the field for “Name of person filing Dollar basis. Enter amounts in U.S.
Corporation B, a domestic Form 5471.” dollars. The U.S. shareholder’s U.S.
corporation, owns the remaining 50% Reference ID number of foreign dollar basis in PTEP is generally equal
of the stock of CFC1. Corporation A corporation. If applicable, use the to the U.S. dollar amount of E&P that
wholly owns the only class of stock of reference ID number shown on Form the U.S. shareholder previously
CFC2. The functional currency of all 5471, page 1, item 1b(2). included in gross income. See section
corporations is the U.S. dollar. CFC1 989(b)(1) and (3); and Regulations
Lines a and b. Complete a separate
has tested income of $100x and sections 1.951A-1(d)(1) and
Schedule P for each applicable
CFC2 has tested loss of $30x. See 1.965-1(b)(1) and (2).
separate category of income. Enter
section 951A(c)(2). Neither The U.S. shareholder’s U.S. dollar
the appropriate code on line a (at the
Corporation A nor Corporation B has basis is used by the U.S. shareholder
top of page 1 of Schedule P). To
any net deemed tangible income to determine the amount of foreign
determine the appropriate code, see
return that would reduce the GILTI currency gain or loss on the PTEP that
Categories of Income in the
inclusion of Corporation A or B. the U.S. shareholder is required to
Instructions for Form 1118.
Corporation A has a section 951A recognize under section 986(c).
inclusion of $20 because its pro rata A foreign corporation may have
share of CFC1’s tested income ($50x) PTEP in a PTEP group within any of Columns (a) through (k). Use
is offset by its pro rata share of the separate categories of income, columns (a) through (k) to report the
CFC2’s tested loss ($30x). with the exception of foreign branch opening balance of, current year
Corporation B has a section 951A category income. See Regulations additions and subtractions to, and the
inclusion of $50x. On Schedule P of section 1.960-3(c)(1). closing balance of, the PTEP in the
U.S. shareholder’s annual PTEP
the Form 5471 with respect to CFC1 If code 901j is entered on line a,
accounts with respect to a CFC.
filed by Corporation B, Corporation B enter on line b the country code for
will report on line 7, column (h), $50x the sanctioned country using the Columns (a) through (j) of
of PTEP as a result of its section 951A two-letter code (from the list at Schedule P correspond to
inclusion with respect to CFC1. IRS.gov/CountryCodes). Schedule J, columns (e)(i) through (e)
Corporation A will report $20x of (x). See Schedule J, earlier, for
PTEP as a result of its section 951A Note. A separate Schedule P should specific line instructions.
inclusion on its Form 5471, not be completed for the section 951A Line 1b. If there is a difference
Schedule P, line 7, column (h), with category. Reclassified section 951A between last year’s ending balance on
respect to CFC1. PTEP and section 951A PTEP that is Schedule P and the amount that
in the section 951A category should
The Form 5471, Schedule J, for should be last year’s ending balance,
be reported on the Schedule P
CFC1 should include PTEP of $70x taking into account modifications on
completed for the general category.
with respect to the aggregate section Schedule P, include the difference on
951A inclusions of Corporation A and Note. For purposes of this line 1b and attach an explanation for
Corporation B. However, if Schedule P, include in each separate the difference. If there are multiple
Corporation A does not know category of income, foreign source differences, include the explanation
Corporation B’s section 951A and U.S. source income. and amount of each such difference
inclusion at the time Corporation A on the attachment.
files its Form 5471, Corporation A will Important. In addition to the
only be able to complete Schedule J, separate category codes referred to
Schedule Q
Part I, with respect to its PTEP of $20x above, if you have more than one of
on line 8, column (e)(viii). Similarly, the categories of income referred to Use Schedule Q to report the CFC’s
Corporation B will only be able to above, you must complete and file a income, deductions, taxes, and assets
complete Schedule J, Part I, with separate Schedule P using code by CFC income groups for purposes
of section 960(a) and (d).
44 Instructions for Form 5471 (Rev. 01-2024)

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In general, a taxpayer that is category or categories of filers (see Codes for Passive Groups
subject to tax as a domestic Categories of Filers, earlier). However,
corporation that is a U.S. shareholder in the case of a consolidated return, Code Passive Group
(“corporate U.S. shareholder”) of a enter the name of the U.S. parent in i All passive income received during
CFC is deemed to pay all or a portion the field for “Name of person filing the tax year that is subject to a
of the foreign income taxes paid or Form 5471.” withholding tax of 15% or greater
accrued by the CFC that are properly must be treated as one item of
Reference ID number of foreign
attributable to subpart F income or income. See Regulations section
corporation. If applicable, use the
tested income included in gross 1.904-4(c)(3)(i).
reference ID number shown on Form
income by the corporate U.S. ii All passive income received during
5471, page 1, item 1b(2).
shareholder. See section 960(a) and the tax year that is subject to a
(d). A corporate U.S. shareholder may Line A. Complete a separate withholding tax of less than 15% (but
claim a credit for such foreign taxes, Schedule Q for each applicable greater than zero) must be treated as
subject to certain limitations. separate category of income. Enter one item of income. See Regulations
the appropriate code from the table section 1.904-4(c)(3)(ii).
Note. If an individual, estate, or trust below for the separate category of iii All passive income received during
that is a U.S. shareholder of a CFC income with respect to which the the tax year that is subject to no
makes an election under section 962 Schedule Q is being completed. withholding tax or other foreign tax
(“962 electing shareholder”), any must be treated as one item of
income. See Regulations section
inclusions under section 951 or 951A Codes for Categories of Income 1.904-4(c)(3)(iii).
of the U.S. shareholder will be treated
as received by a corporate U.S. Code Category of Income iv All passive income received during
the tax year that is subject to no
shareholder for purposes of section PAS Passive category income withholding tax but is subject to
960. See section 962(b) and
Regulations section 1.962-2(b). As a 901j Section 901(j) income foreign tax other than a withholding
tax must be treated as one item of
result, these U.S. shareholders may GEN General category income income. See Regulations section
also claim a foreign tax credit for 1.904-4(c)(3)(iv).
foreign income taxes deemed paid If code 901j is entered on line A,
with respect to such inclusions. See enter on line 1m, column (i), the
Note. The grouping rules of
sections 962(a)(1) and 951A(f)(1)(A). country code for the sanctioned
Regulations section 1.904-4(c)(3)(i)
country using the two-letter code
through (iv) apply separately to
Note. See also section 1293(f) for (from the list at IRS.gov/
income attributable to each tested unit
inclusions with respect to a PFIC. CountryCodes).
of a CFC. See Regulations section
To calculate the foreign taxes Important. In addition to the 1.904-4(c)(4). This is one reason that,
deemed paid by the corporate U.S. separate category codes referred to in the case of a CFC,
shareholder (including a 962 electing above, if you have more than one of tested-unit-by-tested-unit reporting is
shareholder), determine for each of its the categories of income referred to required with respect to the income
CFCs the income, deductions, and above, you must complete and file a groups on lines 1a through 1j and
taxes that are assigned to each separate Schedule Q using code lines 3 and 4. A foreign corporation
separate category of income and “TOTAL” that aggregates all amounts that is not a CFC but that is a
each income group within each listed for each line and column in all noncontrolled 10%-owned foreign
separate category. See Regulations other Schedules Q. corporation must report this
section 1.960-1(c)(1). The income information on a
groups include the subpart F income Line B. If category code “PAS” is foreign-QBU-by-foreign-QBU basis.
groups, the tested income group, and entered on line A, a separate This would be the case, for example, if
the residual income group. Schedule Q must be completed for you are completing Schedule Q for
each applicable grouping under purposes of attaching it to Schedules
Computer-Generated Regulations section 1.904-4(c)(3). K-2 and K-3 for purposes of section
Schedule Q See Regulations sections 1.954-1(c) 1293(f).
Expand the Schedule Q if you are (1)(iii)(B) and 1.904-4(c)(3) through
To figure the amounts to enter on
reporting with respect to more than (5). Enter on line B the appropriate
lines 1a through 1j, on lines (1), (2),
two units. Specifically, if you are code from the table below for each of
etc., under each line 1a through 1j,
reporting with respect to more than the following groups under
enter the name of each unit of the
two units, add to pages 1 to 4, as Regulations section 1.904-4(c)(3).
foreign corporation (the relevant unit
appropriate, new lines (3), (4), (5), being each tested unit in the case of a
etc., in all necessary locations. CFC and each QBU in the case of a
Specific Instructions for 10%-owned foreign corporation),
Schedule Q including the foreign corporation itself,
and the information required in each
Name of person filing Form 5471. column (i) through (xvi) with respect to
The name of the person filing Form the amount in each subpart F income
5471 is generally the name of the U.S. group within each category for each
person described in the applicable unit.

Instructions for Form 5471 (Rev. 01-2024) 45

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On lines (1), (2), etc., under line 4,    income described in each of              QBU. On lines 1a through 1j, enter the 
enter the name of each unit and enter     Regulations section 1.954-1(c)(1)(iii)   total for each column by adding the 
the information required for columns      (A)(2)(i) through (v). For example, with amounts on lines (1), (2), etc., 
(i) through (xvi) for each unit, but do   respect to line 1g, there is a single    excluding from such total any amounts 
not enter amounts excluded from           subpart F income group within the        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   income.                                  section 954(b)(4) (“subpart F high-tax 
lines 1a through 1j) or tested income                                              exception”). These amounts are 
under the GILTI high-tax exclusion          Use lines 1a through 1f to enter the   included in the total amount of 
(those amounts are reported on lines      passive category foreign personal        residual income, which is reported on 
(1), (2), etc., under line 3).            holding company income of the CFC        line 4. As a result, the amounts 
                                          under the appropriate income group       included on lines 1a through 1j for 
Line C. If code 901j is entered on line   (dividends, interest, rents, royalties,  each column may not equal the sum 
A, enter the country code for the         and annuities; net gain from certain     of the amounts reported on lines (1), 
sanctioned country using the              property transactions; net gain from     (2), etc., for each column because any 
two-letter code from the list at          commodities transactions; net foreign    item excluded from subpart F income 
IRS.gov/CountryCodes.                     currency gain; income equivalent to      by reason of the high-tax election is 
Line D. Taxpayers are generally           interest; and other passive category     included in the summation on line 4 
required to complete a separate           foreign personal holding company         instead of the summations on lines 1a 
Schedule Q for foreign source income      income of the CFC), each of which is     through 1j. See the instructions for 
in each separate category and U.S.        also treated as a separate subpart F     column (xiv) and line 4.
source income in each separate            income group under Regulations 
category. On a given Schedule Q,          section 1.960-1. See Regulations         Example.   For line 1a(1), gross 
taxpayers are generally required to       section 1.954-1(c)(1)(iii)(B).           income of $50 is reported in column 
                                                                                   (ii), foreign tax of $20 is reported in 
check the box for either foreign source 
                                          Note. Enter the following passive        each of columns (x) and (xii), and the 
income or U.S. source income, as 
                                          category foreign personal holding        checkbox in column (xiv) is checked. 
applicable. However, if a taxpayer has 
                                          company income of the CFC on line 1f     For line 1a(2), gross income of $100 is 
entered code “TOTAL” on line A and 
                                          (other foreign personal holding          reported in column (ii), $5 of foreign 
the total reported on that Schedule Q 
                                          company income).                         tax is reported in each of columns (x) 
includes both foreign source income 
and U.S. source income, the taxpayer      • Income from notional principal         and (xii), and the checkbox in column 
                                          contracts.                               (xiv) is not checked. For line 1a(3), 
may check both boxes on line D.
                                          • Payments in lieu of dividends.         gross income of $75 is reported in 
Line E. A separate Schedule Q is          • Personal service contracts.            column (ii), $3 of foreign tax is 
required for foreign oil and gas          See section 954(c)(1)(F) through (H).    reported in each of columns (x) and 
extraction income (FOGEI) and               Attach a statement that includes all   (xii), and the checkbox in column (xiv) 
foreign oil related income (FORI). If     of the information requested by          is not checked. As a result, the 
the Schedule Q is being prepared to       Schedule Q, line 1f, delineating the     amount reported in column (ii) on 
report the FOGEI or FORI of a CFC,        amount on line 1f for each of the three  line 1a is the sum of the amounts 
check the box for line E. Indicate the    groups reporting on line 1f. For         reported in column (ii) on lines 1a(2) 
amount of FOGEI and FORI in each          example, if both payments in lieu of     and 1a(3), which is equal to $175 
income group.                             dividends and income from notional       ($100 + $75). The amounts reported 
Line 1. Subpart F Income                  principal contracts are included on      in columns (x) and (xii) on line 1a are 
Groups                                    line 1f, on the statement, identify the  the sum of the amounts reported in 
                                          amount related to each of those          each column on lines 1a(2) and 1a(3), 
The separate subpart F income             income groups for each column of         which is equal to $8 ($5 + $3). The 
groups within each applicable section     line 1f.                                 items reported on line 1a(1), gross 
904 category of a CFC are on line 1                                                income of $50 and $20 of foreign tax, 
(“subpart F income groups”). See            Use lines 1g through 1j to enter the   are not included in the totals reported 
Regulations section 1.960-1(d)(2)(ii)     foreign base company sales income,       on line 1a. These amounts are 
(B). Each single item of foreign base     foreign base company services            included in the totals for each 
company income (as defined in             income, full inclusion income, and       respective column on line 4. As a 
Regulations section 1.954-1(c)(1)(iii))   insurance income described in            result, the amount reported on line 4, 
is a separate subpart F income group.     section 952(a)(1) of the CFC.            column (ii), is increased by $50 and 
With respect to a CFC, Regulations                                                 the amount reported in column (x) on 
section 1.954-1(c)(1)(iii)(A)(2)            To figure the amounts to enter on 
                                                                                   line 4 is increased by $20. No amount 
identifies as a single item of income all lines 1a through 1j, on lines (1), (2), 
                                                                                   is reported on line 4, column (xii), 
foreign base company income (other        etc., under each line 1a through 1j, 
                                                                                   because foreign income taxes 
than foreign personal holding             enter the name of each QBU of the 
                                                                                   attributable to high-tax exception or 
company income) that falls within both    CFC, including the CFC itself, and the 
                                                                                   high-tax exclusion income are not 
a single separate category (typically,    information required in each column 
                                                                                   creditable.
general category income) and a single     (i) through (xvi) with respect to the 
category of foreign base company          amount in each subpart F income          On lines 1k through 1m, enter 
                                          group within each category for each      international boycott income 

46                                                                                 Instructions for Form 5471 (Rev. 01-2024)

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described in section 952(a)(3); illegal     Line 4. Residual Income Group             amount should be reported in column 
bribes, kickbacks, and other                Use line 4 to report the information      (xii) of line 4 as foreign tax on residual 
payments described in section 952(a)        required in columns (i) through (xvi)     amounts are not creditable. The 
(4); and income included in a section       that is in a section 904 category but     amounts reported on line 1a(1) would 
901(j) separate category described in       that is not of a type that is included in not be included in the total for line 1a, 
section 952(a)(5). See Regulations          one of the subpart F income groups or     but the amount reported on line 1a(2) 
section 1.960-1(d)(2)(ii)(B)(2).            a tested income group and is              would be included in the total reported 
Line 2. Recaptured Subpart F                therefore assigned to the residual        on line 1a. Similarly, the amounts 
Income                                      income group. See Regulations             reported on line 3(1) would not be 
                                            section 1.960-1(d)(2)(ii)(D). Enter the   included in the total reported on line 3, 
Enter income that is recaptured as          name of each QBU and enter the            but the amounts reported on line 3(2) 
subpart F income in the current year.       information required for columns (i)      would be reported in the total reported 
See section 952(c)(2).                      through (xvi) for each QBU on lines       on line 3.
Line 3. Tested Income Group                 4(1), 4(2), etc., but do not enter        Column (i). Consistent with the 
Use line 3 to report tested income in       amounts excluded from subpart F           reporting requirement on Form 1118, 
the tested income group of the CFC (a       income under the subpart F high-tax       enter the two-letter code (from the list 
“tested income group”). See                 exception (those amounts are              at IRS.gov/CountryCodes) of each 
Regulations section 1.960-1(d)(2)(ii)       reported on lines (1), (2), etc., under   foreign country and U.S. territory 
(C). On lines (1), (2), etc., under         lines 1a through 1j) or tested income     within which income is sourced and/or 
line 3, enter the name of each tested       under the GILTI high-tax exclusion        to which taxes were paid or accrued.
unit of the CFC (including the CFC          (those amounts are reported on lines 
                                                                                      Column (ii). Enter the amount of 
tested unit itself) and enter for each      3(1), 3(2), etc.,). Enter the sum of the 
                                                                                      gross income of the CFC that is 
tested unit the information required in     amounts reported on lines 4(1), 4(2), 
                                                                                      assigned to each income group within 
columns (ii) through (xvi), based on        etc., plus the sum of amounts 
                                                                                      each section 904 category.
the tentative gross tested income           excluded from subpart F income 
attributable to each tested unit            under the subpart F high-tax              Columns (iii) through (vii). Expen-
(without regard to any amounts              exception and tested income under         ses. Deductions of the CFC, 
excluded under the GILTI high-tax           the GILTI high-tax exclusion, in the      including for current year taxes, are 
exclusion in Regulations section            appropriate column on line 4.             allocated and apportioned to the 
1.951A-2(c)(7) (“GILTI high-tax             Example. For line 1a(1), $100 of          income groups to determine net 
exclusion”)). If the GILTI high-tax         gross income is reported in column        income (or loss) in each income group 
exclusion applies with respect to any       (ii), $35 of foreign tax is reported in   and to identify the current year foreign 
tested unit of the CFC, include the         each of columns (x) and (xii), and the    income taxes that relate to the income 
amounts reported for columns (ii)           checkbox in column (xiv) is checked.      in each income group for section 960 
through (xiii) and (xvi) in the total       For line 1a(2), $75 of gross income is    purposes. See Regulations section 
reported on line 4. See the                 reported in column (ii), $5 of foreign    1.960-1(c)(1) and 1.960-1(d)(3)(ii). 
instructions for line 4. As a result, the   tax is reported in each of columns (x)    Enter the expenses allocated and 
total amount entered on line 3 may not      and (xii), and the checkbox in column     apportioned to the item of gross 
equal the sum of the amounts                (xiv) is not checked. For line 3(1),      income reported for each QBU or 
reported in columns (ii) through (xiii)     $200 of gross income is reported in       tested unit as well as the aggregate 
and (xvi) on lines 3(1), 3(2), etc., if any column (ii), $70 of foreign tax is        amount of such expenses allocated 
tested unit’s tentative tested income is    reported in each of columns (x) and       and apportioned to each group. See 
excluded under the GILTI high-tax           (xii), and the checkbox in column (xiv)   the instructions for lines 1 through 4.
exclusion (these amounts are                is checked. For line 3(2), $150 of        Column (viii). Current year tax on 
included in the total amounts reported      gross income is reported in column        reattributed income from disregar-
on line 4). In general, tested income       (ii), $10 of foreign tax is reported in   ded payments. This column is used 
will be in a single tested income group     each of columns (x) and (xii), and the    to report current year tax imposed 
within the general category. Because        checkbox in column (xiv) is not           solely by reason of the receipt of a 
a CFC cannot earn section 951A              checked. For line 4(1), $300 of gross     disregarded payment that is a 
category income or foreign branch           income is reported in column (ii) and     reattribution payment. The current 
category income at the CFC level,           $105 of foreign tax is reported in        year tax is allocated and apportioned 
there is no tested income group within      column (x). On line 4(1), both columns    to the income group to which an 
either section 904 category. With           (xii) and (xiv) should be blank in all    amount of gross income is assigned 
respect to the general category tested      cases. As a result, the amount            by reason of the receipt of the 
income group of a CFC, GILTI                reported on line 4 for column (ii) is the reattribution payment. See 
inclusion amounts and taxes with            sum of the amounts reported in            Regulations sections 1.960-1(d)(3)(ii)
respect to the tested income group          column (ii) on lines 1a(1), 3(1), and     (A) and 1.861-20(d)(3)(v)(B). Report 
will generally be treated as income         4(1), which equals $600 ($100 + $200      current year taxes allocated and 
and deemed paid taxes in the section        + $300). The amount reported in           apportioned to the item of gross 
951A category. See Regulations              column (x) of line 4 is the sum of the    income reported for each QBU or 
sections 1.904-4(g) and 1.904-6(e).         amounts reported in column (x) on         tested unit as well as the aggregate 
                                            lines 1a(1), 3(1), and 4(1), which        amount of such foreign taxes in each 
                                            equals $210 ($35 + $70 + $105). No 

Instructions for Form 5471 (Rev. 01-2024)                                                                                   47

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group. See the instructions for lines 1 and (l); and taxes paid or accrued to corporation's subpart F income
through 4. the United States. exceeds current year E&P. See
Regulations sections 1.952-1(c) and
Column (ix). Current year tax on all Column (xiii). Average asset value.
(e) and 1.951A-6.
other disregarded payments. This Foreign gross income that arises from
column is used to report current tax a disregarded payment that is treated
imposed solely by reason of the as a remittance for U.S. tax purposes Schedule R
receipt of a disregarded payment is assigned to an income group by Schedule R is used to report basic
other than a reattribution payment, reference to the income groups to information pertaining to distributions
and which is therefore either a which the assets of the payor taxable from foreign corporations. This
remittance or a contribution. See unit are assigned (or would be information is required by sections
Regulations section 1.861-20(d)(3)(v) assigned if the taxable unit were a 245A, 959, and 986(c).
(C). Foreign tax imposed by reason of U.S. person) under the rules of
a disregarded payment that is a Regulations section 1.861-9 for Name of Person Filing Form
remittance is assigned to the income purposes of apportioning interest 5471
groups based upon the assets of the expense. This rule uses the payor’s The name of the person filing Form
payor. See Regulations section asset apportionment percentages as 5471 is generally the name of the U.S.
1.861-20(d)(3)(v)(C)(1). Foreign tax a proxy for the accumulated earnings person described in the category or
imposed by reason of a disregarded of the payor taxable unit from which categories of filers (see Categories of
payment that is a contribution is the remittance is made. For this Filers, earlier). However, in the case of
assigned to the residual grouping. purpose, the assets of the taxable unit a consolidated return, enter the name
See Regulations section 1.861-20(d) making the remittance are determined of the U.S. parent in the field for
(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 Regulations section 1.987-6(b) that
of gross income reported for each apply in determining the source and Reference ID Number of
QBU or tested unit as well as the separate category of exchange gain Foreign Corporation
aggregate amount of such foreign or loss on a section 987 remittance, If applicable, use the reference ID
taxes allocated and apportioned to as modified in two respects. See number shown on Form 5471, page 1,
each group. See the instructions for Regulations section 1.861-20(d)(3)(v) item 1b(2).
lines 1 through 4. (C)(1). Report asset values for each
QBU or tested unit as well as the Column (a). Description of distri-
Column (x). Other current year tax- bution. The description should
aggregate amount of assets in each
es. Any other current year tax is include whether the distribution was
group. See the instructions for lines 1
allocated and apportioned among the cash or noncash and taxable or
through 4.
section 904 categories under the rules nontaxable to shareholders. Use code
of Regulations section 1.904-6(a) Column (xiv). High-tax election. sections to properly identify the
based on the portion of the foreign Check the box in column (xiv) of the taxable or nontaxable consequences
taxable income (as characterized line corresponding to any item of of the distribution. For example,
under federal income tax principles) income with respect to which the “taxable cash dividend eligible for a
that is assigned to a particular section subpart F high-tax exception applies. dividends received deduction under
904 category. Any other current year If any amount is excluded under the section 245A” or “nontaxable cash
foreign tax is allocated to the CFC subpart F high-tax exception, do not distribution of PTEP.” Report parts of a
income group to which the items of include it in the total for lines 1a distribution on separate rows if the
foreign gross income are assigned through 1j, but instead add the distribution is partially taxable and
under the rules of Regulations section amount to the total for line 4. See the partially nontaxable, or if the
1.861-20. Report current year taxes instructions for lines 1 and 4. If a GILTI distribution is either taxable or
allocated and apportioned to the item high-tax exclusion under Regulations nontaxable by reason of different
of gross income reported for each section 1.951A-2(c)(7)(viii) is effective Code sections. For example, a cash
QBU or tested unit as well as the with respect to the CFC for the CFC distribution of $100 that is a
aggregate amount of such foreign inclusion year, check the box in nontaxable distribution of PTEP under
taxes allocated and apportioned to column (xiv) that corresponds to the section 959(a) of $30, a taxable
each group. See the instructions for item(s) of income to which the dividend eligible for a dividends
lines 1 through 4. exception applies. If an amount received deduction under section
reported on line 3(1), 3(2), etc., is
Column (xii). Foreign taxes for 245A of $15, a taxable dividend under
excluded from gross income under the
which credit is allowed (U.S. dol- section 301(c)(1) of $25, a nontaxable
GILTI high-tax exclusion, do not
lars). The amount reported in column distribution applied against basis
include it in the total amount for line 3.
(xii) may not be the same as the sum under section 301(c)(2) of $10, and a
Instead, include the amounts in the
of the amounts in columns (viii) taxable distribution treated as gain
total for line 4. See the instructions for
through (x) if columns (viii) through (x) from the sale or exchange of property
lines 3 and 4.
include taxes that are not creditable, under section 301(c)(3) of $20 would
including taxes paid or accrued to Column (xv). Loss allocation. This be reported on five rows.
sanctioned countries; foreign taxes column is used to report a reduction to If noncash distributions were made,
disallowed under section 901(k), (m), subpart F income in each applicable attach a statement and show both the
income group when the foreign tax bases and FMVs.

48 Instructions for Form 5471 (Rev. 01-2024)

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Column (b). Date of distribution. generally treated as a distribution of on the comparable line of other
Enter the month, day, and year using E&P. Report distributions from current noncorporate tax returns.
the following format: MM-DD-YYYY. and accumulated E&P. Do not report
For example, June 30, 2023, would be any part of a distribution that is not Note. E&P described in section
entered as “06-30-2023.” from E&P in column (d). 959(c)(3) is generally E&P of the
foreign corporation that has not been
An actual distribution is first out of
Column (c). Amount of distribution included in gross income of a U.S.
PTEP, if any, and then out of the
in foreign corporation's functional shareholder under section 951(a)(1)
section 959(c)(3) balance. See
currency. The amount of a or section 951A.
section 959(c).
distribution is generally the amount of
any money paid to the shareholder If PTEP were distributed, include Note. Amounts entered in
plus the FMV of any property on Form 5471, Schedule I, line 6, any Schedule R (Form 5471), column (d),
transferred to the shareholder. foreign currency gain or loss on the are also included on line 9, column (f),
However, this amount is reduced (but distribution that is recognized under of Schedule J (Form 5471) and Part I,
not below zero) by the following section 986(c). See the instructions line 8, of Schedule P (Form 5471),
liabilities. for Schedule I, Line 6, earlier, for both of which are completed by
• Any liability of the corporation the details. With respect to foreign separate category of income. If the
shareholder assumes in connection currency gain or loss on a distribution filer is required to complete
with the distribution. of PTEP, for a corporate U.S. Schedule J (Form 5471) with respect
• Any liability to which the property is shareholder, include the gain or (loss) to more than one category of income,
subject immediately before, and as “Other income” on Form 1120, the total of all amounts entered in
immediately after, the distribution. line 10, or on the comparable line of Schedule R (Form 5471), column (d),
other corporate tax returns. For a should equal the amount entered on
Column (d). Amount of E&P distri- noncorporate U.S. shareholder, line 9, column (f), of the Schedule J
bution in foreign corporation's include the result as “Other income” (Form 5471) that is filed with code
functional currency. A corporate on Schedule 1 (Form 1040), line 8z, or “TOTAL” entered on line a of that
distribution to a shareholder is
Schedule J.

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the
United States. You are required to give us the information. We need it to ensure that you are complying with these laws
and to allow us to figure and collect the right amount of tax.
You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act
unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be
retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax
returns and return information are confidential, as required by section 6103.
The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden
for individual and business taxpayers filing this form is approved under OMB control number 1545-0074 and 1545-0123
and is included in the estimates shown in the instructions for their individual and business income tax return.

Instructions for Form 5471 (Rev. 01-2024) 49

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Principal Business Activity Codes                            Using the list of activities and codes below,        use one of the manufacturing codes 
                                                           determine from which activity the company derives      (311110-339900).
This list of principal business activities and their       the largest percentage of its “total receipts.” If the    Enter on page 1, Item 1f, the six-digit code 
associated codes is designed to classify an                company purchases raw materials and supplies           selected from the list below. In item 1g, enter a 
enterprise by the type of activity in which it is          them to a subcontractor to produce the finished        brief description of the company's business 
engaged to facilitate the administration of the            product, but retains title to the product, the         activity.
Internal Revenue Code. These principal business            company is considered a manufacturer and must 
activity codes are based on the North American 
Industry Classification System.
Agriculture, Forestry, Fishing,       237990 Other Heavy & Civil                     Printing and Related Support           333510 Metalworking Machinery Mfg
and Hunting                                          Engineering Construction        Activities                             333610 Engine, Turbine & Power 
                                      Specialty Trade Contractors                    323100 Printing & Related Support            Transmission Equipment Mfg
Crop Production                       238100 Foundation, Structure, &                Activities                             333900 Other General Purpose 
111100 Oilseed & Grain Farming                       Building Exterior Contractors   Petroleum and Coal Products                  Machinery Mfg
111210 Vegetable & Melon Farming                     (including framing carpentry,   Manufacturing                          Computer and Electronic Product 
       (including potatoes & yams)                   masonry, glass, roofing, &      324110 Petroleum Refineries            Manufacturing
111300 Fruit & Tree Nut Farming                      siding)                         (including integrated)                 334110 Computer & Peripheral 
111400 Greenhouse, Nursery, &         238210 Electrical Contractors                  324120 Asphalt Paving, Roofing, &            Equipment Mfg
       Floriculture Production        238220 Plumbing, Heating, &                    Saturated Materials Mfg                334200 Communications Equipment 
111900 Other Crop Farming                            Air-Conditioning Contractors    324190 Other Petroleum & Coal                Mfg
       (including tobacco, cotton,    238290 Other Building Equipment                Products Mfg                           334310 Audio & Video Equipment 
       sugarcane, hay, peanut,                       Contractors                     Chemical Manufacturing                       Mfg
       sugar beet & all other crop    238300 Building Finishing                      325100 Basic Chemical Mfg              334410 Semiconductor & Other 
       farming)                                      Contractors (including          325200 Resin, Synthetic Rubber, &            Electronic Component Mfg
Animal Production                                    drywall, insulation, painting,  Artificial & Synthetic Fibers &        334500 Navigational, Measuring, 
112111 Beef Cattle Ranching &                        wallcovering, flooring, tile, & Filaments Mfg                                Electromedical, & Control 
       Farming                                       finish carpentry)                                                            Instruments Mfg
112112 Cattle Feedlots                238900 Other Specialty Trade                   325300 Pesticide, Fertilizer, & Other 
112120 Dairy Cattle & Milk Production                Contractors (including site     Agricultural Chemical Mfg              334610 Manufacturing & Reproducing 
                                                     preparation)                    325410 Pharmaceutical & Medicine             Magnetic & Optical Media
                                                                                     Mfg                                    Electrical Equipment, Appliance, 
112210 Hog & Pig Farming              Manufacturing                                  325500 Paint, Coating, & Adhesive      and Component Manufacturing
112300 Poultry & Egg Production
112400 Sheep & Goat Farming           Food Manufacturing                             Mfg                                    335100 Electric Lighting Equipment 
112510 Aquaculture (including         311110 Animal Food Mfg                         325600 Soap, Cleaning Compound, &            Mfg
       shellfish & finfish farms &    311200 Grain & Oilseed Milling                 Toilet Preparation Mfg                 335200 Household Appliance Mfg
       hatcheries)                    311300 Sugar & Confectionery                   325900 Other Chemical Product &        335310 Electrical Equipment Mfg
112900 Other Animal Production                       Product Mfg                     Preparation Mfg                        335900 Other Electrical Equipment & 
Forestry and Logging                  311400 Fruit & Vegetable Preserving            Plastics and Rubber Products                 Component Mfg
113110 Timber Tract Operations                       & Specialty Food Mfg            Manufacturing                          Transportation Equipment 
113210 Forest Nurseries & Gathering   311500 Dairy Product Mfg                       326100 Plastics Product Mfg            Manufacturing
       of Forest Products             311610 Animal Slaughtering and                 326200 Rubber Product Mfg              336100 Motor Vehicle Mfg
113310 Logging                                       Processing                      Nonmetallic Mineral Product            336210 Motor Vehicle Body & Trailer 
Fishing, Hunting, and Trapping        311710 Seafood Product Preparation             Manufacturing                                Mfg
                                                     & Packaging                     327100 Clay Product & Refractory       336300 Motor Vehicle Parts Mfg
114110 Fishing                        311800 Bakeries, Tortilla & Dry Pasta          Mfg                                    336410 Aerospace Product & Parts 
114210 Hunting & Trapping                            Mfg                             327210 Glass & Glass Product Mfg             Mfg
Support Activities for Agriculture    311900 Other Food Mfg (including               327300 Cement & Concrete Product       336510 Railroad Rolling Stock Mfg
and Forestry                                         coffee, tea, flavorings, &      Mfg                                    336610 Ship & Boat Building
115110 Support Activities for Crop                   seasonings)                     327400 Lime & Gypsum Product Mfg       336990 Other Transportation 
       Production (including cotton   Beverage and Tobacco Product                   327900 Other Nonmetallic Mineral             Equipment Mfg
       ginning, soil preparation,     Manufacturing                                  Product Mfg                            Furniture and Related Product 
       planting, & cultivating)       312110 Soft Drink & Ice Mfg                    Primary Metal Manufacturing            Manufacturing
115210 Support Activities for Animal  312120 Breweries                               331110 Iron & Steel Mills & Ferroalloy 337000 Furniture & Related Product 
       Production (including farriers)
115310 Support Activities For         312130 Wineries                                Mfg                                          Manufacturing
       Forestry                       312140 Distilleries                            331200 Steel Product Mfg from          Miscellaneous Manufacturing
Mining                                312200 Tobacco Manufacturing                   Purchased Steel                        339110 Medical Equipment & 
211120 Crude Petroleum Extraction     Textile Mills and Textile Product              331310 Alumina & Aluminum                    Supplies Mfg
                                      Mills                                          Production & Processing                339900 Other Miscellaneous 
211130 Natural Gas Extraction         313000 Textile Mills                           331400 Nonferrous Metal (except              Manufacturing
212110 Coal Mining                    314000 Textile Product Mills                   Aluminum) Production &                 Wholesale Trade
                                                                                     Processing
212200 Metal Ore Mining               Apparel Manufacturing                          331500 Foundries                       Merchant Wholesalers, Durable 
212310 Stone Mining & Quarrying       315100 Apparel Knitting Mills                  Fabricated Metal Product               Goods
212320 Sand, Gravel, Clay, &          315210 Cut & Sew Apparel                       Manufacturing                          423100 Motor Vehicle & Motor Vehicle 
       Ceramic & Refractory                          Contractors                     332110 Forging & Stamping                    Parts & Supplies
       Minerals Mining & Quarrying    315250 Cut & Sew Apparel Mfg                   332210 Cutlery & Handtool Mfg          423200 Furniture & Home Furnishings
212390 Other Nonmetallic Mineral                     (except Contractors)                                                   423300 Lumber & Other Construction 
       Mining & Quarrying             315990 Apparel Accessories & Other             332300 Architectural & Structural            Materials
213110 Support Activities for Mining                 Apparel Mfg                     Metals Mfg
Utilities                             Leather and Allied Product                     332400 Boiler, Tank, & Shipping        423400 Professional & Commercial 
221100 Electric Power Generation,     Manufacturing                                  Container Mfg                                Equipment & Supplies
       Transmission & Distribution    316110 Leather & Hide Tanning &                332510 Hardware Mfg                    423500 Metal & Mineral (except 
                                                                                                                                  Petroleum)
221210 Natural Gas Distribution                      Finishing                       332610 Spring & Wire Product Mfg       423600 Household Appliances & 
221300 Water, Sewage & Other          316210 Footwear Mfg (including                 332700 Machine Shops; Turned                 Electrical & Electronic Goods
       Systems                                       rubber & plastics)              Product; & Screw, Nut, & Bolt          423700 Hardware & Plumbing & 
221500 Combination Gas & Electric     316990 Other Leather & Allied                  Mfg                                          Heating Equipment & 
                                                     Product Mfg                     332810 Coating, Engraving, Heat              Supplies
Construction                          Wood Product Manufacturing                     Treating, & Allied Activities          423800 Machinery, Equipment, & 
Construction of Buildings             321110 Sawmills & Wood                         332900 Other Fabricated Metal                Supplies
236110 Residential Building                          Preservation                    Product Mfg                            423910 Sporting & Recreational 
       Construction                   321210 Veneer, Plywood, &                      Machinery Manufacturing                      Goods & Supplies
236200 Nonresidential Building                       Engineered Wood Product         333100 Agriculture, Construction, &    423920 Toy & Hobby Goods & 
       Construction                                  Mfg                             Mining Machinery Mfg                         Supplies
Heavy and Civil Engineering           321900 Other Wood Product Mfg                  333200 Industrial Machinery Mfg        423930 Recyclable Materials
Construction                          Paper Manufacturing                            333310 Commercial & Service            423940 Jewelry, Watch, Precious 
237100 Utility System Construction    322100 Pulp, Paper, & Paperboard               Industry Machinery Mfg                       Stone, & Precious Metals
237210 Land Subdivision                              Mills                           333410 Ventilation, Heating,           423990 Other Miscellaneous Durable 
237310 Highway, Street, & Bridge      322200 Converted Paper Product Mfg             Air-Conditioning, &                          Goods
       Construction                                                                  Commercial Refrigeration 
                                                                                     Equipment Mfg

          50

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Principal Business Activity Codes (Continued)
Merchant Wholesalers, Nondurable     Gasoline Stations & Fuel Dealers    488210 Support Activities for Rail   Securities, Commodity Contracts, 
Goods                                457100 Gasoline Stations (including Transportation                       and Other Financial Investments 
424100 Paper & Paper Products        convenience stores with gas)        488300 Support Activities for Water  and Related Activities
424210 Drugs & Druggists' Sundries   457210 Fuel Dealers (including      Transportation                       523150 Investment Banking & 
424300 Apparel, Piece Goods, &       Heating Oil & Liquefied             488410 Motor Vehicle Towing                  Securities Intermediation
      Notions                        Petroleum)                          488490 Other Support Activities for  523160 Commodity Contracts 
424400 Grocery & Related Products    Clothing and Accessories Retailers  Road Transportation                          Intermediation
424500 Farm Product Raw Materials    458110 Clothing & Clothing          488510 Freight Transportation        523210 Securities & Commodity 
424600 Chemical & Allied Products    Accessories Retailers               Arrangement                                  Exchanges
424700 Petroleum & Petroleum         458210 Shoe Retailers               488990 Other Support Activities for  523900 Other Financial Investment 
      Products                       458310 Jewelry Retaileres           Transportation                               Activities (including portfolio 
424800 Beer, Wine, & Distilled       458320 Luggage & Leather Goods      Couriers and Messengers                      management & investment 
                                                                                                                      advice)
      Alcoholic Beverages            Retailers                           492110 Couriers & Express Delivery   Insurance Carriers and Related 
424910 Farm Supplies                 Sporting, Hobby, Book, Musical      Services                             Activities
424920 Book, Periodical, &           Instrument & Miscellaneous          492210 Local Messengers & Local      524110 Direct Life, Health, & Medical 
      Newspapers                     Retailers                           Delivery                                     Insurance Carriers
424930 Flower, Nursery Stock, &      459110 Sporting Goods Retailers     Warehousing and Storage              524120 Direct Insurance (except Life, 
      Florists' Supplies             459120 Hobby, Toy, & Game Retailers 493100 Warehousing & Storage                 Health & Medical) Carriers
424940 Tobacco Products &            459130 Sewing, Needlework, & Piece  (except lessors of                   524210 Insurance Agencies & 
      Electronic Cigarettes          Goods Retailers                     mini-warehouses &                            Brokerages
424950 Paint, Varnish, & Supplies    459140 Musical Instrument &         self-storage units)                  524290 Other Insurance Related 
424990 Other Miscellaneous           Supplies Retailers                  Information                                  Activities (including 
      Nondurable Goods               459210 Book Retailers & News        Motion Picture and Sound                     third-party administration of 
Wholesale Trade Agents and           Dealers (including                  Recording Industries                         insurance and pension funds)
Brokers                              newsstands)                         512100 Motion Picture & Video        Funds, Trusts, and Other Financial 
425120 Wholesale Trade Agents &      459310 Florists                     Industries (except video             Vehicles
      Brokers                        459410 Office Supplies & Stationery rental)                              525100 Insurance & Employee 
                                     Retailers                           512200 Sound Recording Industries            Benefit Funds
Retail Trade                         459420 Gift, Novelty, & Souvenir    Publishing Industries                525910 Open-End Investment Funds 
Motor Vehicle and Parts Dealers      Retailers                           513110 Newspaper Publishers                  (Form 1120-RIC, U.S. Income 
                                                                                                                      Tax Return for Regulated 
441110 New Car Dealers               459510 Used Merchandise Retailers   513120 Periodical Publishers                 Investment Companies)
441120 Used Car Dealers              459910 Pet & Pet Supplies Retailers 513130 Book Publishers               525920 Trusts, Estates, & Agency 
441210 Recreational Vehicle Dealers  459920 Art Dealers                  513140 Directory & Mailing List              Accounts
441222 Boat Dealers                  459930 Manufactured (Mobile) Home   Publishers                           525990 Other Financial Vehicles 
441227 Motorcycle, ATV, & All other  Dealers                             513190 Other Publishers                      (including mortgage REITs 
      Motor Vehicle Dealers          459990 All Other Miscellaneous      513210 Software Publishers                   and closed-end investment 
441300 Automotive Parts,             Retailers (including tobacco,                                                    funds)“Offices of Bank 
      Accessories, & Tire Retailers  candle, & trophy retailers)         Broadcasting & Content Providers             Holding Companies” and 
Building Material and Garden         Nonstore Retailers                  & Telecommunications                         “Offices of Other Holding 
Equipment and Supplies Dealers       various Nonstore retailers sell all 516100 Radio & Television                    Companies” are located 
444110 Home Centers                  types of merchandise using          Broadcasting Stations                        under Management of 
444120 Paint & Wallpaper Retailers   such methods as Internet,           516210 Media Streaming, Social               Companies (Holding 
                                     mail-order catalogs,                Networks, & Other Content                    Companies) below.
444140 Hardware Retailers            interactive television, or direct   Providers                            Real Estate and Rental and 
444180 Other Building Material       sales. These types of               517000 Telecommunications            Leasing
      Dealers                        Retailers should select the         (including Wired, Wireless, 
444200 Lawn & Garden Equipment &     PBA associated with their           Satellite, Cable & Other             Real Estate
      Supplies Retailers             primary line of products sold.      Program Distribution,                531110 Lessors of Residential 
                                     For example, establishments         Resellers, Agents & Other                    Buildings & Dwellings 
Food and Beverage Retailers          primarily selling prescription      Telecommunications, &                        (including equity REITs)
445110 Supermarkets and Other        and non-prescription drugs,         Internet Service Providers)          531120 Lessors of Nonresidential 
      Grocery Retailers (except      select PBA code 456110              Data Processing, Web Search                  Buildings (except 
      Convenience)                   Pharmacies & Drug Retailers.        Portals, & Other Information                 Mini-warehouses) (including 
445131 Convenience Retailers         Transportation and                  Services                                     equity REITs)
445132 Vending Machine Operators     Warehousing                         518210 Computing Infrastructure      531130 Lessors of Mini-warehouses 
                                                                         Providers, Data Processing,                  & Self-Storage Units 
445230 Fruit & Vegetable Retailers   Air, Rail, and Water Transportation Web Hosting & Related                        (including equity REITs)
445240 Meat Retailers                481000 Air Transportation           Services                             531190 Lessors of Other Real Estate 
445250 Fish & Seafood Retailers      482110 Rail Transportation          519200 Web Search Portals,                   Property (including equity 
445291 Baked Goods Retailers         483000 Water Transportation         Libraries, Archives, & Other                 REITs)
445292 Confectionery & Nut Retailers Truck Transportation                Info. Services                       531210 Offices of Real Estate Agents 
445298 All Other Specialty Food      484110 General Freight Trucking,    Finance and Insurance                        & Brokers
      Retialers                      Local                               Depository Credit Intermediation     531310 Real Estate Property 
445320 Beer, Wine, & Liquor          484120 General Freight Trucking,    522110 Commercial Banking                    Managers
      Retailers                      Long-distance                       522130 Credit Unions                 531320 Offices of Real Estate 
                                                                                                                      Appraisers
Retailers
Furniture and Home Furnishings       484200 Specialized Freight Trucking 522180 Savings Institutions & Other  531390 Other Activities Related to 
449110 Furniture Retailers           Transit and Ground Passenger        Depository Credit                            Real Estate
                                     Transportation                      Intermediation
449121 Floor Covering Retailers      485110 Urban Transit Systems        Nondepository Credit                 Rental and Leasing Services
449122 Window Treatment Retailers    485210 Interurban & Rural Bus       Intermediation                       532100 Automotive Equipment Rental 
449129 All Other Home Furnishings    Transportation                      522210 Credit Card Issuing                   & Leasing
      Retailers                      485310 Taxi Service                 522220 Sales Financing               532210 Consumer Electronics & 
                                                                                                                      Appliances Rental
Electronics and Appliance Retailers  485320 Limousine Service            522291 Consumer Lending              532281 Formal Wear & Costume 
449210 Electronic & Appliance        485410 School & Employee Bus        522292 Real Estate Credit (including         Rental
      Retailers (including           Transportation                      mortgage bankers &                   532282 Video Tape & Disc Rental
General Merchandise Retailers        485510 Charter Bus Industry
      computers)                                                         originators)                         532283 Home Health Equipment 
455110 Department Stores             485990 Other Transit & Ground       522299 Intl, Secondary Market, &             Rental
                                     Passenger Transportation            Other Nondepos. Credit 
455210 Warehouse Clubs,              Pipeline Transportation             Intermediation                       532284 Recreational Goods Rental
      Supercenters,& Other                                               Activities Related to Credit         532289 All Other Consumer Goods 
      General Merch. Retailers       486000 Pipeline Transportation      Intermediation                               Rental
Health and Personal Care Retailers   Scenic & Sightseeing                522300 Activities Related to Credit  532310 General Rental Centers
456110 Pharmacies & Drug Retailers   Transportation                      Intermediation (including loan       532400 Commercial & Industrial 
456120 Cosmetics, Beauty Supplies,   487000 Scenic & Sightseeing         brokers, check clearing, &                   Machinery & Equipment 
      & Perfume Retailers            Transportation                      money transmitting)                          Rental & Leasing
456130 Optical Goods Retailers       Support Activities for 
                                     Transportation
456190 Other Health & Personal Care  488100 Support Activities for Air 
      Retailers                      Transportation

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Principal Business Activity Codes (Continued)
Lessors of Nonfinancial Intangible    561210 Facilities Support Services   Home Health Care Services            Other Services
Assets (except copyrighted works)     561300 Employment Services           621610 Home Health Care Services     Repair and Maintenance
533110 Lessors of Nonfinancial        561410 Document Preparation          Other Ambulatory Health Care         811110 Automotive Mechanical & 
Intangible Assets (except             Services                             Services                                  Electrical Repair & 
copyrighted works)                    561420 Telephone Call Centers        621900 Other Ambulatory Health            Maintenance
Professional, Scientific, and         561430 Business Service Centers      Care Services (including             811120 Automotive Body, Paint, 
Technical Services                    (including private mail centers      ambulance services & blood                Interior, & Glass Repair
Legal Services                        & copy shops)                        & organ banks)                       811190 Other Automotive Repair & 
541110 Offices of Lawyers             561440 Collection Agencies           Hospitals                                 Maintenance (including oil 
541190 Other Legal Services           561450 Credit Bureaus                622000 Hospitals                          change & lubrication shops & 
Accounting, Tax Preparation,          561490 Other Business Support        Nursing and Residential Care              car washes)
Bookkeeping, and Payroll Services     Services (including                  Facilities                           811210 Electronic & Precision 
                                      repossession services, court         623000 Nursing & Residential Care         Equipment Repair & 
541211 Offices of Certified Public    reporting, & stenotype               Facilities                                Maintenance
Accountants                           services)                            Social Assistance                    811310 Commercial & Industrial 
541213 Tax Preparation Services       561500 Travel Arrangement &          624100 Individual & Family Services       Machinery & Equipment 
                                                                                                                     (except Automotive & 
541214 Payroll Services               Reservation Services                 624200 Community Food & Housing,          Electronic) Repair & 
541219 Other Accounting Services      561600 Investigation & Security      & Emergency & Other Relief                Maintenance
Architectural, Engineering, and       Services                             Services                             811410 Home & Garden Equipment & 
Related Services                      561710 Exterminating & Pest Control  624310 Vocational Rehabilitation          Appliance Repair & 
541310 Architectural Services         Services                             Services                                  Maintenance
541320 Landscape Architecture         561720 Janitorial Services           624410 Childcare Services            811420 Reupholstery & Furniture 
Services                              561730 Landscaping Services          Arts, Entertainment, and                  Repair
541330 Engineering Services           561740 Carpet & Upholstery Cleaning  Recreation                           811430 Footwear & Leather Goods 
541340 Drafting Services              Services                                                                       Repair
541350 Building Inspection Services   561790 Other Services to Buildings & Performing Arts, Spectator Sports,   811490 Other Personal & Household 
541360 Geophysical Surveying &        Dwellings                            and Related Industries                    Goods Repair & Maintenance
Mapping Services                      561900 Other Support Services        711100 Performing Arts Companies     Personal and Laundry Services
541370 Surveying & Mapping (except    (including packaging &               711210 Spectator Sports (including   812111 Barber Shops
Geophysical) Services                 labeling services, &                 sports clubs & racetracks)
541380 Testing Laboratories &         organizers)                          711300 Promoters of Performing Arts, 812112 Beauty Salons
                                      convention & trade show 
                                                                           Sports, & Similar Events             812113 Nail Salons
Services                              Waste Management and                 711410 Agents & Managers for         812190 Other Personal Care Services 
Specialized Design Services           Remediation Services                 Artists, Athletes, Entertainers,          (including diet & weight 
541400 Specialized Design Services    562000 Waste Management &            & Other Public Figures                    reducing centers)
(including interior, industrial,      Remediation Services                 711510 Independent Artists, Writers, 812210 Funeral Homes & Funeral 
graphic, & fashion design)            Educational Services                 & Performers                              Services
Computer Systems Design and                                                Museums, Historical Sites, and       812220 Cemeteries & Crematories
Related Services                      611000 Educational Services          Similar Institutions                 812310 Coin-Operated Laundries & 
541511 Custom Computer                (including schools, colleges,                                                  Drycleaners
Programming Services                  & universities)                      712100 Museums, Historical Sites, & 
541512 Computer Systems Design        Health Care and Social               Similar Institutions                 812320 Drycleaning & Laundry 
                                                                           Amusement, Gambling, and                  Services (except 
Services                              Assistance                           Recreation Industries                     Coin-Operated)
541513 Computer Facilities            Offices of Physicians and Dentists   713100 Amusement Parks & Arcades     812330 Linen & Uniform Supply
Management Services                   621111 Offices of Physicians (except 713200 Gambling Industries           812910 Pet Care (except Veterinary) 
541519 Other Computer Related         mental health specialists)           713900 Other Amusement &                  Services
Services                              621112 Offices of Physicians, Mental Recreation Industries                812920 Photofinishing
Other Professional, Scientific, and   Health Specialists                   (including golf courses, skiing      812930 Parking Lots & Garages
Technical Services                    621210 Offices of Dentists           facilities, marinas, fitness         812990 All Other Personal Services
541600 Management, Scientific, &      Offices of Other Health              centers, & bowling centers)          Religious, Grantmaking, Civic, 
Technical Consulting                  Practitioners                        Accommodation and Food               Professional, and Similar 
Services
541700 Scientific Research &          621310 Offices of Chiropractors      Services                             Organizations
Development Services                  621320 Offices of Optometrists       Accommodation                        813000 Religious, Grantmaking, 
                                                                                                                     Civic, Professional, & Similar 
541800 Advertising, Public Relations, 621330 Offices of Mental Health      721110 Hotels (except Casino Hotels)      Organizations (including 
& Related Services                    Practitioners (except                & Motels                                  condominium and 
541910 Marketing Research & Public    Physicians)                          721120 Casino Hotels                      homeowners associations)
Opinion Polling                       621340 Offices of Physical,          721191 Bed & Breakfast Inns          Other
541920 Photographic Services          Occupational & Speech 
541930 Translation & Interpretation   Therapists, & Audiologists           721199 All Other Traveler            999000 Unclassified Establishments 
Services                              621391 Offices of Podiatrists        Accommodation                             (unable to classify)
541940 Veterinary Services            621399 Offices of All Other          721210 RV (Recreational Vehicle) 
541990 All Other Professional,        Miscellaneous Health                 Parks & Recreational Camps
Scientific, & Technical               Practitioners                        721310 Rooming & Boarding Houses, 
Services                              Outpatient Care Centers              Dormitories & Workers’ 
                                      621410 Family Planning Centers       Camps
Management of Companies               621420 Outpatient Mental Health &    Food Services and Drinking Places
(Holding Companies)                   Substance Abuse Centers              722300 Special Food Services 
551111 Offices of Bank Holding        621491 HMO Medical Centers           (including food service 
                                                                           contractors & caterers)
Companies                             621492 Kidney Dialysis Centers       722410 Drinking Places (Alcoholic 
551112 Offices of Other Holding       621493 Freestanding Ambulatory       Beverages)
Companies                             Surgical & Emergency                 722511 Full Service Restaurants
Administrative and Support and        Centers                              722513 Limited Service Restaurants
Waste Management and                  621498 All Other Outpatient Care     722514 Cafeterias, Grill buffets, & 
Remediation Services                  Centers                              Buffets
                                      Medical and Diagnostic 
Administrative and Support            Laboratories                         722515 Snack & Nonalcoholic 
Services                              621510 Medical & Diagnostic          Beverage Bars
561110 Office Administrative          Laboratories
Services

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