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Note: The form, instructions, or publication you are looking for 
 begins after this coversheet. 

 Please review the updated information below. 

 Clarification Concerning Instructions for Schedule Q (Form 5471), 
 new columns (xv) and (xvi) 

With respect to the January 2023 revision of the instructions for Form 5471: 

On page 1, middle column, there is a “What’s New” item under the heading “Changes to 
separate Schedule Q” that pertains to new columns (xv) and (xvi).  This “What’s New” item, 
4th paragraph, should read as follows. 

Columns (xv) and (xvi) are added for reporting of loss allocations. These new columns have 
been added to reflect Regulations sections 1.952-1(c) and (e) and 1.951A-6.

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                                                                                                             Department of the Treasury
                                                                                                             Internal Revenue Service
Instructions for Form 5471

(Rev. January 2023)

(Use with the December 2022 revision of Form 5471 and separate Schedule Q; the 
December 2021 revision of separate Schedules E, G-1, H, I-1, and M; the December 
2020 revision of separate Schedules J, P, and R; and the December 2012 revision of 
separate Schedule O.)
Information Return of U.S. Persons
With Respect to Certain Foreign Corporations

Section references are to the Internal Revenue      Changes to separate Schedule Q.      At       Changes to these Instructions.      These 
Code unless otherwise noted.
                                                    the top of page 1 of the schedule, new line   instructions have been updated for the 
Contents                                    Page    C requests that, if code 901j is entered on   aforementioned changes to Form 5471 
Future Developments .     . . . . . . . . . . . 1   line A, filers are to enter the country code  and separate Schedule Q. In addition, the 
What’s New .  . . . . . . . . . . . . . . . . . 1   for the sanctioned country. This new line is  following changes have been made.
General Instructions .  . . . . . . . . . . . . 2   needed because Form 5471 filers are             The “Categories of Filers,” “Exceptions 
                                                    required to complete a separate 
Purpose of Form .   . . . . . . . . . . . . . . 2                                                 From Filing,” and “Additional Filing 
                                                    Schedule Q for each sanctioned country,       Requirements” sections have been 
Who Must File   . . . . . . . . . . . . . . . . 2   and this new line identifies the sanctioned   revised as follows:
When and Where To File        . . . . . . . . . 2   country with respect to which the schedule    • The “Categories of Filers” section now 
Categories of Filers .  . . . . . . . . . . . . 2   is being completed. This new line is          includes a comprehensive summary for 
Additional Filing Requirements .      . . . . . 6   identical to corresponding lines on Form      each category of filer that details what 
Penalties . . . . . . . . . . . . . . . . . . . . 7 1118 (and many separate schedules to          type of person each category of filer is; 
Other Reporting Requirements .        . . . . . 7   Form 1118) as well as many of the             definitions that apply specifically for 
Specific Instructions . . . . . . . . . . . . . 8   separate schedules to Form 5471. As a         purposes of each category of filer; 
Schedule B .  . . . . . . . . . . . . . . . .   11  result of this change, former lines C and D   additional information for each category of 
Schedule C .  . . . . . . . . . . . . . . . .   11  have been re-lettered as new lines D and      filer, including information on required 
Schedule F .  . . . . . . . . . . . . . . . .   11  E.                                            statements and other filings; and what 
Schedule G .  . . . . . . . . . . . . . . . .   11     At the top of page 1 of the schedule, if   exceptions apply specifically to each 
Schedule I . . . . . . . . . . . . . . . . . .  16  a Schedule Q filer enters code “TOTAL”        category of filer. This section also clarifies 
Instructions for Separate                           on line A, the filer must also check one or   exceptions for certain Category 1 and 5 
Schedules .       . . . . . . . . . . . . . .   25  both boxes on line D (former line C) to       filers announced in Notice 2018-13, 
Schedule E .  . . . . . . . . . . . . . . . .   25  indicate whether the total amounts            2018-6 I.R.B. 341, and Rev. Proc. 
Schedule E-1 .  . . . . . . . . . . . . . . .   28  reported on Schedule Q include only           2019-40, 2019-43 IRB 982.
Schedule G-1 .  . . . . . . . . . . . . . . .   29  foreign source income, or both foreign        • The “Exceptions From Filing” section 
Schedule H .  . . . . . . . . . . . . . . . .   30  source income and U.S. source income.         has been renamed “Additional Filing 
                                                    Note that, with respect to line D, a          Exceptions” and now includes only filing 
Schedule I-1  . . . . . . . . . . . . . . . .   31
                                                    Schedule Q filer generally checks either      exceptions that apply to all categories of 
Schedule J   . . . . . . . . . . . . . . . . .  32  the foreign source income box or the U.S.     filers.
Schedule M .  . . . . . . . . . . . . . . . .   35  source income box. However, a taxpayer        • The additional filings required of 
Schedule O .  . . . . . . . . . . . . . . . .   36  may check both boxes only in cases            Category 3 filers and the instructions 
Schedule P .  . . . . . . . . . . . . . . . .   36  where the taxpayer enters code “TOTAL”        related to foreign sales corporations have 
Schedule Q .  . . . . . . . . . . . . . . . .   37  on line A and the total reported on           been removed from the “Additional Filing 
Schedule R .  . . . . . . . . . . . . . . . .   40  Schedule Q includes both foreign source       Requirements” section and are now 
Principal Business Activity Codes .       . .   42  income and U.S. source income.                included in the instructions for Category 2, 
                                                       Lines 1f(1) and 1f(2) are added for        3, 4, and 5 filers, as applicable.
Future Developments                                 reporting of other types of income not          At the very end of the instructions for 
For the latest information about                    reportable on lines 1a through 1e. These      Item 1b(2)—Reference ID Number, 
developments related to Form 5471, its              new lines have been added to reflect          additional clarification has been added to 
schedules, and its instructions, such as            section 954(c)(1) and Regulations section     the note pertaining to the correlation 
legislation enacted after they were                 1.954-1(c)(1)(iii). As a result of these new  requirement. Specifically, if the correlation 
published, go to IRS.gov/Form5471.                  lines, previous lines 1f through 1l have      requirement is applicable with respect to a 
                                                    been re-lettered as lines 1g through 1m.      tax year, it applies only on Form 5471, 
What’s New                                             Columns (xv) and (xvi) are added for       page 1, line 1b(2). It does not apply on any 
                                                    reporting of loss allocations. These new      of the separate schedules for Form 5471. 
Changes to Form 5471.         On page 5 of                                                        On all separate schedules for Form 5471, 
                                                    columns have been added to reflect 
Form 5471, the wording of Schedule G,                                                             please enter only the current reference ID 
                                                    Regulations section 1.861-20(e).
lines 6a through 6d was amended to                                                                number in the applicable entry space.
reflect the final regulations under section            There is no longer a need to enter a 
250 (T.D. 9901, 85 FR 43042, July 15,               total on line 5, column (xiii), Average Asset   In the instructions for Schedule G, later, 
2020, as amended by 85 FR 68249, Oct.               Value. As a result, this entry space has      in the Schedule G, Line 14 table, question 
28, 2020; T.D. 9956, 86 FR 52971, Sept.             been shaded.                                  18 has been revised for clarity. In addition, 
                                                                                                  new question 22 has been added 
24, 2021).

Mar 9, 2023                                            Cat. No. 49959G

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pertaining to the U.S. person’s pro rata exempt organization return) and file both Category 1b Filer
share of subpart F income or tested items by the due date (including extensions) for
from a CFC. that return. A Category 1b filer is a person who is an
In the instructions for Schedule G-1, unrelated section 958(a) U.S. shareholder
later, if the taxpayer made the election Categories of Filers (defined below) of a foreign-controlled
described in Regulations section section 965 SFC. This type of Category 1
1.482-7(d)(3)(iii)(B) or Notice 2005-99, the Category 1 Filers filer extends the relief for certain Category
taxpayer is required to attach to Form In general, a Category 1 filer is a person 5 filers announced in section 8.02 of Rev.
5471 the statement described in the who was a U.S. shareholder of a foreign Proc. 2019-40, 2019-43 IRB 982 to
instructions for Schedule G-1, questions corporation that was a section 965 similarly situated Category 1 filers.
6b and 6c. specified foreign corporation (SFC) at any
For tax year 2022, several changes time during the foreign corporation’s tax Unrelated section 958(a) U.S. share-
have been made to the principal business year ending with or within the U.S. holder. For purposes of Category 1b, an
activities and codes listed at the end of shareholder’s tax year, and who owned unrelated section 958(a) U.S. shareholder
these instructions. See the revised list that stock on the last day in that year in is a U.S. shareholder with respect to a
before entering a six-digit code and the which the foreign corporation was a foreign-controlled section 965 SFC who:
description of the activity on page 1, items section 965 SFC, taking into account the 1. Owns, within the meaning of
1f and 1g. regulations under section 965. There are section 958(a), stock of a
three different types of Category 1 filers, foreign-controlled section 965 SFC; and
each described below: Category 1a filers, 2. Is not related (using principles of
General Instructions Category 1b filers, and Category 1c filers. section 954(d)(3)) to the foreign-controlled
Except as otherwise provided in the section 965 SFC.
Purpose of Form instructions for each type of Category 1 Foreign-controlled section 965 SFC.
Form 5471 is used by certain U.S. filer below, the following definitions apply For purposes of Category 1b, a
persons who are officers, directors, or for purposes of Category 1: foreign-controlled section 965 SFC is a
shareholders in certain foreign
corporations. The form and schedules are U.S. shareholder. For purposes of foreign corporation that is a section 965
used to satisfy the reporting requirements Category 1, a U.S. shareholder is a U.S. SFC that would not be a section 965 SFC
of sections 6038 and 6046, and the person who owns (directly, indirectly, or if the determination were made without
related regulations. constructively, within the meaning of applying subparagraphs (A), (B), and (C)
section 958(a) and (b)) 10% or more of the of section 318(a)(3) so as to consider a
total combined voting power or value of U.S. person as owning stock that is owned
Who Must File shares of all classes of stock of a section by a foreign person.
Generally, all U.S. persons described in 965 SFC. See section 951(b).
Categories of Filers, below, must
complete the schedules, statements, U.S. person. For purposes of Category 1, Category 1c Filer
and/or other information requested in the a U.S. person is:
chart, Filing Requirements for Categories 1. A citizen or resident of the United A Category 1c filer is a person who is a
of Filers, later. Read the information for States; Related constructive U.S. shareholder. of
a foreign-controlled section 965 SFC. This
each category carefully to determine 2. A domestic partnership; type of Category 1 filer extends the relief
which schedules, statements, and/or
information apply. 3. A domestic corporation; or for certain Category 5 filers announced in
4. An estate or trust that is not a section 8.03 of Rev. Proc. 2019-40,
Note. When a schedule is required but all foreign estate or trust, as defined in 2019-43 IRB 982, to similarly situated
amounts are zero, the schedule should section 7701(a)(31). Category 1 filers.
still be filed with one or more zero Related constructive U.S. shareholder.
amounts. For schedules that are See section 957(c) for exceptions.
For purposes of Category 1c, a related
completed by category (that is, Section 965 SFC. For purposes of constructive U.S. shareholder is a U.S.
Schedule E, I-1, J, P, and Q), inclusion of Category 1, a section 965 SFC is: shareholder with respect to a
a single instance of that schedule for any 1. A CFC (see Category 5 Filers, later, foreign-controlled section 965 SFC who:
separate category will meet the for definition); or 1. Does not own, within the meaning
requirement.
2. Any foreign corporation with of section 958(a), stock of the
If the filer is described in more than one respect to which one or more domestic foreign-controlled section 965 SFC; and
filing category, do not duplicate corporations is a U.S. shareholder. 2. Is related (using principles of
information. However, complete all items However, if a passive foreign section 954(d)(3)) to the foreign-controlled
that apply. For example, if you are the sole investment company (as defined in section 965 SFC.
owner of a CFC (that is, you are described section 1297) with respect to the Foreign-controlled section 965 SFC.
in Categories 4 and 5a), complete all six shareholder is not a CFC, then such For purposes of Category 1c, the term
pages of Form 5471 and separate corporation is not a section 965 SFC. foreign-controlled section 965 SFC has
Schedules E, G-1, H, I-1, J, M, P, Q, and
R. See section 965 and the regulations the same meaning as provided in
thereunder for exceptions. Category 1b Filers, above.
Note. Complete a separate Form 5471
and all applicable schedules for each Additional Information for
applicable foreign corporation. Category 1a Filer Category 1 Filers
A Category 1a filer is a Category 1 filer When Category 1 reporting is no lon-
When and Where To File that is not a Category 1b or 1c filer. ger required. A Category 1 filer must
Attach Form 5471 to your income tax continue to file all information required as
return (or, if applicable, partnership or long as:

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• The section 965 SFC (or 3. The Category 1 filer is not related, Category 2 Filers - Exceptions
foreign-controlled section 965 SFC) has using principles of section 954(d)(3), to
From Filing
accumulated E&P related to section 965 the foreign-controlled section 965 SFC.
that is reportable on Schedule J (Form A Category 2 filer does not have to file
5471); or This exception implements the relief for Form 5471 if:
• The Category 1 filer has previously certain Category 5 filers announced in 1. Immediately after a reportable
taxed E&P related to section 965 that is section 8.04 of Rev. Proc. 2019-40, stock acquisition, three or fewer U.S.
reportable on Schedule P (Form 5471). 2019-43 IRB 982, and extends it to persons own 95% or more in value of the
Category 1 filers. outstanding stock of the foreign
Category 1 Filers - Exceptions Other filing exceptions. Certain other corporation and the U.S. person making
From Filing filing exceptions apply to all categories of the acquisition files a return for the
Certain constructive owners. filers. See Additional Filing Exceptions, acquisition as a Category 3 filer; or
• A Category 1 filer does not have to file later. 2. The U.S. person(s) for which the
Form 5471 if all of the following conditions Category 2 Filer Category 2 filer is required to file Form
are met: 5471 does not directly own an interest in
This category includes a U.S. citizen or the foreign corporation but is required to
1. The Category 1 filer does not own a resident who is an officer or director of a furnish the information solely because of
direct interest in the foreign corporation; foreign corporation in which a U.S. person constructive stock ownership from a U.S.
2. The Category 1 filer is required to has acquired (in one or more person and the person from whom the
furnish the information requested solely transactions): stock ownership is attributed furnishes all
because of constructive ownership (as 1. Stock that meets the 10% stock of the information required of the Category
determined under Regulations section ownership requirement with respect to the 2 filer.
1.958-2, 1.6038-2(c), or 1.6046-1(i)) from foreign corporation; or
another U.S. person; and Other filing exceptions. Certain other
2. An additional 10% or more (in value
3. The U.S. person through which the or voting power) of the outstanding stock filing exceptions apply to all categories of
Category 1 filer constructively owns an of the foreign corporation. filers. See Additional Filing Exceptions,
interest in the foreign corporation files below.
Form 5471 to report all of the information A U.S. person has acquired stock in a
required of the Category 1 filer. foreign corporation when that person has Category 3 Filer
an unqualified right to receive the stock, This category includes:
• A Category 1 filer does not have to file even though the stock is not actually 1. A U.S. person who acquires stock
Form 5471 if it: issued. See Regulations section in a foreign corporation which, when
1. Does not own a direct or indirect 1.6046-1(c) and (f)(1) for more details. added to any stock owned on the date of
interest in the foreign corporation; and 10% stock ownership requirement. For acquisition, meets the 10% stock
2. Is required to file Form 5471 solely purposes of Category 2, the stock ownership requirement with respect to the
because of constructive ownership from a ownership threshold is met if a U.S. foreign corporation;
nonresident alien. person owns: 2. A U.S. person who acquires stock
No statement is required to be attached 1. 10% or more of the total value of which, without regard to stock already
to the tax return of a Category 1 filer the foreign corporation's stock, or owned on the date of acquisition, meets
the 10% stock ownership requirement with
claiming either constructive ownership 2. 10% or more of the total combined respect to the foreign corporation;
exception. See Regulations section voting power of all classes of stock with
1.6038-2(j)(2) and (3) and (l) for additional voting rights. 3. A person who is treated as a U.S.
information. shareholder under section 953(c) with
See Regulations section 1.6046-1(i) for respect to the foreign corporation;
No section 958(a) U.S. shareholder. A additional information. 4. A person who becomes a U.S.
Category 1 filer does not have to file Form
5471 if no U.S. shareholder (including the U.S. person. For purposes of Category 2, person while meeting the 10% stock
Category 1 filer) owns, within the meaning a U.S. person is: ownership requirement with respect to the
of section 958(a), stock in the section 965 1. A citizen or resident of the United foreign corporation; or
SFC on the last day in the year of the States; 5. A U.S. person who disposes of
foreign corporation in which it was a 2. A domestic partnership; sufficient stock in the foreign corporation
section 965 SFC and the SFC is a to reduce his or her interest to less than
foreign-controlled section 965 SFC. This 3. A domestic corporation; or the 10% stock ownership requirement.
exception extends the relief for Category 5 4. An estate or trust that is not a
filers announced in section 5.02 of Notice foreign estate or trust as defined in section For more information, see section 6046
2018-13, 2018-6 IRB 341, to similarly 7701(a)(31). and Regulations section 1.6046-1.
situated Category 1 filers. See Regulations section 1.6046-1(f)(3) 10% stock ownership requirement. For
Unrelated constructive U.S. sharehold- for exceptions. purposes of Category 3, the stock
er. A Category 1 filer does not have to file ownership threshold is met if a U.S.
person owns:
Form 5471 if all of the following conditions Additional Information for
1. 10% or more of the total value of
are met: Category 2 Filers the foreign corporation's stock; or
1. The foreign corporation is a
foreign-controlled section 965 SFC; Foreign sales corporations (FSCs). 2. 10% or more of the total combined
Category 2 filers who are shareholders, voting power of all classes of stock with
2. The Category 1 filer is a U.S. officers, and directors of an FSC (as voting rights.
shareholder that does not own stock, defined in section 922, as in effect before
within the meaning of section 958(a), in its repeal) must file Form 5471 and a See Regulations section 1.6046-1(i) for
the foreign-controlled section 965 SFC; separate Schedule O to report changes in additional information.
and the ownership of the FSC.

Instructions for Form 5471 (Rev. 01-2023) -3-

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U.S. person. For purposes of Category 3, U.S. person. For purposes of 3. Nonexempt foreign trade income
a U.S. person is: Category 4, a U.S. person is: (other than section 923(a)(2) nonexempt
income, within the meaning of section
1. A citizen or resident of the United 1. A citizen or resident of the United 927(d)(6), as in effect before repeal); and
States; States;
4. Any deductions that are
2. A domestic partnership; 2. A nonresident alien for whom an apportioned or allocated to the nonexempt
3. A domestic corporation; or election is in effect under section 6013(g) foreign trade income described above.
to be treated as a resident of the United
4. An estate or trust that is not a States; • Category 4 filers who are shareholders
foreign estate or trust as defined in section of an FSC are subject to the subpart F
7701(a)(31). 3. An individual for whom an election
is in effect under section 6013(h), relating rules for:
See Regulations section 1.6046-1(f)(3) to nonresident aliens who become 1. All other types of FSC income
for exceptions. residents of the United States during the (including section 923(a)(2) nonexempt
tax year and are married at the close of income within the meaning of section
Additional Information for the tax year to a citizen or resident of the 927(d)(6), as in effect before its repeal);
Category 3 Filers United States; 2. Investment income and carrying
Statement required. Category 3 filers 4. A domestic partnership; charges (as defined in sections 927(c) and
must attach a statement that includes: 5. A domestic corporation; and 927(d)(1), as in effect before their repeal);
and
1. The amount and type of any 6. An estate or trust that is not a
indebtedness the foreign corporation has foreign estate or trust as defined in section 3. All other FSC income that is not
with the related persons described in 7701(a)(31). foreign trade income or investment
Regulations section 1.6046-1(b)(11); and income or carrying charges.
2. The name, address, identifying See Regulations section 1.6038-2(d)
number, and number of shares subscribed for exceptions. Category 4 Filers - Exceptions
to by each suscriber to the foreign Control. For purposes of Category 4, a From Filing
corporation's stock. U.S. person has control of a foreign Certain constructive owners.
corporation if, at any time during that • A Category 4 filer does not have to file
Foreign sales corporations (FSCs). person's tax year, it owns stock Form 5471 if all of the following conditions
Category 3 filers who are shareholders, possessing: are met:
officers, and directors of an FSC (as 1. More than 50% of the total 1. The Category 4 filer does not own a
defined in section 922, as in effect before combined voting power of all classes of direct interest in the foreign corporation;
its repeal) must file Form 5471 and a stock of the foreign corporation entitled to
separate Schedule O to report changes in vote; or 2. The Category 4 filer is required to
the ownership of the FSC. furnish the information requested solely
2. More than 50% of the total value of because of constructive ownership (as
Category 3 Filers - Exception shares of all classes of stock of the foreign determined under Regulations section
From Filing corporation. 1.958-2, 1.6038-2(c), or 1.6046-1(i)) from
A Category 3 filer does not have to file For purposes of Category 4, a person another U.S. person; and
Form 5471 if all of the following conditions in control of a corporation that, in turn, 3. The U.S. person through which the
are met: owns more than 50% of the combined Category 4 filer constructively owns an
1. The Category 3 filer does not own a voting power, or the value, of all classes of interest in the foreign corporation files
direct interest in the foreign corporation; stock of another corporation is also Form 5471 to report all of the information
2. The Category 3 filer is required to treated as being in control of such other required of the Category 4 filer.
furnish the information requested solely corporation.
• A Category 4 filer does not have to file
because of constructive ownership (as Example. Corporation A owns 51% of Form 5471 if it:
determined under Regulations section the voting stock in Corporation B. 1. Does not own a direct or indirect
1.958-2, 1.6038-2(c), or 1.6046-1(i)) from Corporation B owns 51% of the voting interest in the foreign corporation; and
another U.S. person; and stock in Corporation C. Corporation C
3. The U.S. person through which the owns 51% of the voting stock in 2. Is required to file Form 5471 solely
Category 3 filer constructively owns an Corporation D. Therefore, Corporation D because of constructive ownership from a
interest in the foreign corporation files is controlled by Corporation A. nonresident alien.
Form 5471 to report all of the information For more details on “control” for No statement is required to be attached
required of the Category 3 filer. purposes of Category 4, see section to the tax return of a Category 4 filer
No statement is required to be attached 6038(e)(2) and Regulations sections claiming either constructive ownership
to tax returns for persons claiming this 1.6038-2(b) and (c). exception. See Regulations section
1.6038-2(j)(2) and (3) and (l) for additional
constructive ownership exception. Additional Information for information.
Other filing exceptions. Certain other Category 4 Filers FSCs. Category 4 filers are not required
filing exceptions apply to all categories of to file a Form 5471 (in order to satisfy the
filers. See Additional Filing Exceptions, Foreign sales corporations (FSCs).
below. • Category 4 filers who are shareholders requirements of section 6038) if the FSC
of an FSC are not subject to the subpart F has filed a Form 1120-FSC. See
Category 4 Filer rules with respect to the FSC for: Temporary Regulations section
This category includes a U.S. person who 1. Exempt foreign trade income; 1.921-1T(b)(3). However, these filers are
required to file Form 5471 for an FSC,
had control (defined below) of a foreign 2. Deductions that are apportioned or regardless of whether it has filed Form
corporation during the annual accounting allocated to exempt foreign trade income; 1120-FSC, if the filer has inclusions with
period of the foreign corporation.

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respect to the FSC under section 951(a) CFC also includes a foreign corporation CFC has the same meaning as defined in
(as described above). that is described in section 957(b); and for Category 5b filers, above.
purposes only of taking into account
Other filing exceptions. Certain other Additional Information for
related person insurance income, a CFC
filing exceptions apply to all categories of Category 5 Filers
includes a foreign corporation described in
filers. See Additional Filing Exceptions,
section 953(c)(1)(B).
below. Foreign sales corporations (FSCs)
• Category 5 filers who are shareholders
Category 5 Filers Category 5a Filer of an FSC are not subject to the subpart F
In general, a Category 5 filer is a person rules with respect to the FSC for:
who was a U.S. shareholder that owned A Category 5a filer is a Category 5 filer 1. Exempt foreign trade income;
stock in a foreign corporation that was a that is not a Category 5b or 5c filer. 2. Deductions that are apportioned or
CFC at any time during the foreign
corporation’s tax year ending with or within allocated to exempt foreign trade income;
the U.S. shareholder’s tax year, and who Category 5b Filer 3. Nonexempt foreign trade income
owned that stock on the last day in that (other than section 923(a)(2) nonexempt
year in which the foreign corporation was A person is a Category 5b filer if they are income, within the meaning of section
a CFC. There are three different types of an unrelated section 958(a) U.S. 927(d)(6), as in effect before repeal); and
Category 5 filers, each described below: shareholder of a foreign-controlled CFC. 4. Any deductions that are
Category 5a filers, Category 5b filers, and This type of Category 5 filer implements apportioned or allocated to the nonexempt
Category 5c filers. the relief for certain Category 5 filers foreign trade income described above.
announced in section 8.02 of Rev. Proc.
Except as otherwise provided in the 2019-40, 2019-43 IRB 982. • Category 5 filers who are shareholders
instructions for each type of Category 5 of an FSC are subject to the subpart F
filer below, the following definitions apply Unrelated section 958(a) U.S. share-
rules for:
for purposes of Category 5: holder. For purposes of Category 5b, an
unrelated section 958(a) U.S. shareholder 1. All other types of FSC income
U.S. shareholder. For purposes of is a U.S. shareholder with respect to a (including section 923(a)(2) nonexempt
Category 5, a U.S. shareholder is a U.S. foreign-controlled CFC who: income within the meaning of section
person who: 927(d)(6), as in effect before its repeal);
1. Owns, within the meaning of
1. Owns (directly, indirectly, or section 958(a), stock of a 2. Investment income and carrying
constructively, within the meaning of foreign-controlled CFC; and charges (as defined in sections 927(c) and
sections 958(a) and (b)) 10% or more of 927(d)(1), as in effect before their repeal);
the total combined voting power or value 2. Is not related (using principles of
and
of shares of all classes of stock of a CFC; section 954(d)(3)) to the foreign-controlled
or CFC. 3. All other FSC income that is not
foreign trade income or investment
2. Owns (either directly or indirectly, Foreign-controlled CFC. For purposes income or carrying charges.
within the meaning of section 958(a)) any of Category 5b, a foreign-controlled CFC
stock of a CFC (as defined in sections is a foreign corporation that is a CFC that Category 5 Filers - Exceptions
953(c)(1)(B) and 957(b)), unless the would not be a CFC if the determination From Filing
foreign corporation has an effective were made without applying
section 953(c)(3)(C) election in place for subparagraphs (A), (B), and (C) of section Certain constructive owners
the tax year. 318(a)(3) so as to consider a U.S. person • A Category 5 filer does not have to file
as owning stock that is owned by a foreign Form 5471 if all of the following conditions
U.S. person. For purposes of person. are met:
Category 5, a U.S. person is: 1. The Category 5 filer does not own a
direct interest in the foreign corporation;
1. A citizen or resident of the United Category 5c Filer
States; 2. The Category 5 filer is required to
furnish the information requested solely
2. A domestic partnership; A person is a Category 5c filer if they are a
because of constructive ownership (as
3. A domestic corporation; or related constructive U.S. shareholder of a
determined under Regulations section
4. An estate or trust that is not a foreign-controlled CFC. This type of
1.958-2, 1.6038-2(c), or 1.6046-1(i)) from
foreign estate or trust, as defined in Category 5 filer implements the relief for
another U.S. person; and
section 7701(a)(31). certain Category 5 filers announced in
section 8.03 of Rev. Proc. 2019-40, 3. The U.S. person through which the
See section 957(c) for exceptions. 2019-43 IRB 982. Category 5 filer constructively owns an
interest in the foreign corporation files
In general, a CFC is a foreign Related constructive U.S. shareholder. Form 5471 to report all of the information
corporation that has U.S. shareholders For purposes of Category 5c, a related required of the Category 5 filer.
that own (directly, indirectly, or constructive U.S. shareholder is a U.S.
constructively, within the meaning of shareholder with respect to a • A Category 5 filer does not have to file
section 958(a) and (b)) on any day of the foreign-controlled CFC who: Form 5471 if it:
tax year of the foreign corporation, more
than 50% of: 1. Does not own, within the meaning 1. Does not own a direct or indirect
of section 958(a), stock of the interest in the foreign corporation; and
1. The total combined voting power of foreign-controlled CFC; and 2. Is required to file Form 5471 solely
all classes of its voting stock, or
2. Is related (using principles of because of constructive ownership from a
2. The total value of the stock of the section 954(d)(3)) to the foreign-controlled nonresident alien.
corporation. CFC. No statement is required to be attached
For purposes only of taking into to the tax return of a Category 5 filer
account income described in section Foreign-controlled CFC. For purposes
953(a) (relating to insurance income), a of Category 5c, the term foreign-controlled claiming either constructive ownership

Instructions for Form 5471 (Rev. 01-2023) -5-

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exception. See Regulations section Category 5b filer (but not a Category 5c foreign insurance company that has
1.6038-2(j)(2) and (3) and (l) for additional filer). However, for Category 3 filers, the elected (under section 953(d)) to be
information. required information may only be filed by treated as a domestic corporation and has
another person having an equal or greater filed a U.S. income tax return for its tax
No section 958(a) U.S. shareholder. A
interest (measured in terms of value or year under that provision. See Rev. Proc.
Category 5 filer does not have to file Form
voting power of the stock of the foreign 2003-47, 2003-28 I.R.B. 55, available at
5471 if no U.S. shareholder (including the
corporation). IRS.gov/irb/2003-28_IRB#RP-2003-47, for
Category 5 filer) owns, within the meaning
of section 958(a), stock in the CFC on the The person that files Form 5471 must procedural rules regarding the election
last day in the year of the foreign complete Form 5471 in the manner under section 953(d).
corporation in which it was a CFC and the described in the instructions for Item H. All
CFC is a foreign-controlled CFC. See persons identified in Item H must attach a
section 5.02 of Notice 2018-13, 2018-6 statement to their income tax return that Additional Filing
IRB 341 for additional information. includes the information described in the Requirements
instructions for Item H. See Regulations
Section 338 election. If a section 338
Unrelated constructive U.S. sharehold- section 1.6038-2(j)(1) and (3) for
election is made with respect to a qualified
er. A Category 5 filer does not have to file additional information.
Form 5471 if all of the following conditions stock purchase of a foreign target
are met: Domestic corporations. Shareholders corporation for which a Form 5471 must
are not required to file Form 5471 for a
1. The foreign corporation is a be filed:
foreign-controlled CFC; Filing Requirements for Categories of Filers
2. The filer is a U.S. shareholder that
does not own stock, within the meaning of Table of Required Information
section 958(a), in the foreign-controlled
CFC; and Category of Filer
3. The filer is not related, using Required Information*
1a 1b 1c 2 3 4 5a 5b 5c
principles of section 954(d)(3), to the
foreign-controlled CFC. The identifying information on page 1
of Form 5471 above Schedule A; see
See section 8.04 of Rev. Proc. Specific Instructions
2019-40, 2019-43 IRB 982 for additional Schedule A
information.
FSCs. Category 5 filers are not required Schedule B, Part I
to file a Form 5471 (in order to satisfy the
requirements of section 6038) if the FSC Schedule B, Part II
has filed a Form 1120-FSC. See Schedules C and F
Temporary Regulations section
1.921-1T(b)(3). However, these filers are Separate Schedule E
required to file Form 5471 for an FSC, 1 2 1 2
regardless of whether it has filed Form Schedule E-1 (included with separate
1120-FSC, if the filer has inclusions with Schedule E) 1 1
respect to the FSC under section 951(a) Schedule G
(as described above).
Other filing exceptions. Certain other Separate Schedule G-1
filing exceptions apply to all categories of Separate Schedule H
filers. See Additional Filing Exceptions,
below. Schedule I
Additional Filing Separate Schedule I-1
Exceptions Separate Schedule J
Multiple filers of same information.
With respect to any category of filer, one Separate Schedule M
person may file Form 5471 and the
Separate Schedule O, Part I
applicable schedules for other persons
who have the same filing requirements. If Separate Schedule O, Part II
you and one or more other persons are
required to furnish information for the Separate Schedule P
same foreign corporation for the same
period, a joint information return that Separate Schedule Q
contains the required information may be
filed with your tax return or with the tax Separate Schedule R
return of any one of the other persons. For
example, a U.S. person described in *See also Additional Filing Requirements.
Category 5 may file a joint Form 5471 with 1. Schedules E and E-1 are required for an unrelated section 958(a) U.S. shareholder only if the filer claims deemed
a Category 4 filer or another Category 5 paid foreign income taxes of the foreign-controlled section 965 SFC or foreign-controlled CFC under section 960 for the
filer; similarly, a U.S. person described in filer’s tax year. See Rev. Proc. 2019-40 for more details.
Category 5b may file a joint Form 5471 2. Related constructive U.S. shareholders only need to complete Schedule E (they can leave Schedule E-1 blank). See
with a Category 4 or 5a filer or another Rev. Proc. 2019-40 for more details.

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• A purchaser (or its U.S. shareholder) disclose a reportable transaction under Failure to file information required by
must attach a copy of Form 8883, Asset section 6011 and fails to properly section 6046 and the related regula-
Allocation Statement Under Section 338, complete and file Form 8886. Penalties tions (Form 5471 and
to the first Form 5471 for the new foreign may also apply under section 6707A if the Schedule O). Any person who fails to file
target corporation (see the Instructions for U.S. shareholder fails to file Form 8886 or report all of the information requested
Form 8883 for details); with its income tax return, fails to provide a by section 6046 is subject to a $10,000
• A seller (or its U.S. shareholder) must copy of Form 8886 to the Office of Tax penalty for each such failure for each
attach a copy of Form 8883 to the last Shelter Analysis (OTSA), or files a form reportable transaction. If the failure
Form 5471 for the old foreign target that fails to include all the information continues for more than 90 days after the
corporation; required (or includes incorrect date the IRS mails notice of the failure, an
• A U.S. shareholder that files a section information). Other penalties, such as an additional $10,000 penalty will apply for
338 election on behalf of a foreign accuracy-related penalty under section each 30-day period, or fraction thereof,
purchasing corporation that is a controlled 6662A, may also apply. See the during which the failure continues after the
foreign corporation pursuant to Instructions for Form 8886 for details on 90-day period has expired. The additional
Regulations section 1.338-2(e)(3) must these and other penalties. penalty is limited to a maximum of
attach a copy of Form 8023, Elections $50,000. See section 6679.
Reportable transactions by material
Under Section 338 for Corporations
advisors. Material advisors to any
Making Qualified Stock Purchases, to the Criminal penalties. Criminal penalties
reportable transaction must disclose
Form 5471 filed with respect to the under sections 7203, 7206, and 7207 may
certain information about the reportable
purchasing corporation for the taxable apply for failure to file the information
transaction by filing Form 8918, Material
year that includes the acquisition date required by sections 6038 and 6046.
Advisor Disclosure Statement, with the
(see the Instructions for Form 8023 for
IRS. For details, see the Instructions for
details). Note. Any person required to file
Form 8918. Form 5471 and Schedule J, M, or O who
Reportable transaction disclosure agrees to have another person file the
Reporting other foreign financial as-
statement. If a U.S. shareholder of a form and schedules for them may be
sets. If you have other foreign financial
CFC is considered to have participated in subject to the above penalties if the other
assets, you may be required to file Form
a reportable transaction under the rules of person does not file a correct and proper
8938, Statement of Specified Foreign
Regulations section 1.6011-4(c)(3)(i)(G), form and schedule.
Financial Assets. However, you are not
the shareholder is required to disclose
required to report any items otherwise
information for each reportable Section 6662(j). Penalties may be
reported on Form 5471 on that form. See
transaction. Form 8886, Reportable imposed for undisclosed foreign financial
the Instructions for Form 8938 for more
Transaction Disclosure Statement, must asset understatements. No penalty will be
information.
be filed for each tax year indicated in imposed with respect to any portion of an
Regulations section 1.6011-4(c)(3)(i)(G). underpayment if the taxpayer can
demonstrate that the failure to comply was
The following are reportable transactions. Penalties due to reasonable cause with respect to
1. Any listed transaction, which is a such portion of the underpayment and the
transaction that is the same as or Failure to file information required by
substantially similar to one of the types of section 6038(a) (Form 5471 and taxpayer acted in good faith with respect
transactions that the IRS has determined Schedule M). to such portion of the underpayment. See
to be a tax avoidance transaction and • A $10,000 penalty is imposed for each sections 6662(j) and 6664(c) for additional
identified by notice, regulation, or other annual accounting period of each foreign information.
published guidance as a listed corporation for failure to furnish the Inapplicability of certain penalties.
transaction. information required by section 6038(a) Certain penalties under sections 6038 and
within the time prescribed. If the 6662 may be waived for certain persons
2. Any transaction offered under information is not filed within 90 days after under Rev. Proc. 2019-40. See section 7
conditions of confidentiality for which the the IRS has mailed a notice of the failure of Rev. Proc. 2019-40 for more details.
corporation (or a related party) paid an to the U.S. person, an additional $10,000
advisor a fee of at least $250,000. penalty (per foreign corporation) is
3. Certain transactions for which the charged for each 30-day period, or Other Reporting
corporation (or a related party) has fraction thereof, during which the failure
contractual protection against continues after the 90-day period has Requirements
disallowance of the tax benefits. expired. The additional penalty is limited Reporting exchange rates on Form
4. Certain transactions resulting in a to a maximum of $50,000 for each failure. 5471. When translating amounts from
loss of at least $10 million in any single • Any person who fails to file or report all functional currency to U.S. dollars, you
year or $20 million in any combination of of the information required within the time must use the method specified in these
years. prescribed will be subject to a reduction of instructions. For example, when
10% of the foreign taxes available for translating amounts to be reported on
5. Any transaction identified by the credit under sections 901 and 960. If the Schedule E, you must generally use the
IRS by notice, regulation, or other failure continues 90 days or more after the average exchange rate as defined in
published guidance as a “transaction of date the IRS mails notice of the failure to section 986(a). But, regardless of the
interest.” See Notice 2009-55, 2009-31 the U.S. person, an additional 5% specific method required, all exchange
I.R.B. 170, available at IRS.gov/irb/ reduction is made for each 3-month rates must be reported using a “divide-by
2009-31_IRB#NOT-2009-55. period, or fraction thereof, during which convention” rounded to at least four
For more information, see Regulations the failure continues after the 90-day places. That is, the exchange rate must be
section 1.6011-4. Also, see the period has expired. See section 6038(c) reported in terms of the amount by which
Instructions for Form 8886. (2) for limits on the amount of this penalty. the functional currency amount must be
See Regulations sections 1.6038-1(j) and divided in order to reflect an equivalent
Penalties. The U.S. shareholder may 1.6038-2(k)(3) for alleviation of this amount of U.S. dollars. As such, the
have to pay a penalty if it is required to penalty in certain cases. exchange rate must be reported as the

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units of foreign currency that equal one computer-generated forms. In addition, Corrections to Form 5471
U.S. dollar, rounded to at least four every year the IRS issues Pub. 1167, If you file a Form 5471 that you later
places. Do not report the exchange rate General Rules and Specifications for determine is incomplete or incorrect, file a
as the number of U.S. dollars that equal Substitute Forms and Schedules, which corrected Form 5471 with an amended tax
one unit of foreign currency. reprints the most recent applicable return, using the amended return
revenue procedure. Pub. 1167 is available instructions for the return with which you
Note. You must round the result to more at IRS.gov/Pub. 1167. originally filed Form 5471. Write
than four places if failure to do so would
materially distort the exchange rate or the Dormant Foreign Corporations "Corrected" at the top of the form and
equivalent amount of U.S. dollars. Rev. Proc. 92-70, 1992-2 C.B. 435, attach a statement identifying the
Example. During its annual provides a summary filing procedure for changes.
accounting period, the foreign corporation filing Form 5471 for a dormant foreign
paid income taxes of 30,255,400 Yen to corporation (defined in section 3 of Rev. Specific Instructions
Japan. The Schedule E instructions Proc. 92-70). This summary filing
specify that the foreign corporation must procedure will satisfy the reporting Important. If the information required in a
translate these amounts into U.S. dollars requirements of sections 6038 and 6046. given section exceeds the space provided
within that section, do not write “See
at the average exchange rate for the tax If you elect the summary procedure, attached” in the section and then attach all
year to which the tax relates in complete only page 1 of Form 5471 for of the information on additional sheets.
accordance with the rules of section each dormant foreign corporation as Instead, complete all entry spaces in the
986(a). The average exchange rate is follows. section and attach the remaining
108.8593 Japanese Yen to one U.S. dollar • The top margin of the summary return information on additional sheets. The
or (0.009184) U.S. dollar to one Japanese must be labeled “Filed Pursuant to Rev. additional sheets must conform with the
Yen. The foreign corporation divides Proc. 92-70 for Dormant Foreign IRS version of that section.
30,255,400 Yen by 108.8593 to determine Corporation.”
the U.S. dollar amount to enter in column • Include filer information such as name
(l) of Schedule E, Part I, Section 1, line 1. and address, Items A through C, and tax Identifying Information
Line 1 of Schedule E, Part I, Section 1, is year. Annual Accounting Period
completed in relevant part as follows. • Include corporate information such as
• Enter the name of the payor entity in the dormant corporation's annual Enter, in the space provided below the title
column (a). accounting period (below the title of the of Form 5471, the annual accounting
• Enter the payor entity’s EIN or form) and Items 1a, 1b, 1c, and 1d. period of the foreign corporation for which
reference ID number in column (b). For more information, see Rev. Proc. you are furnishing information. Except for
• Enter "JA" in column (d). 92-70. information contained on Schedule O,
• Enter “JPY” in column (i). report information for the tax year of the
• Enter "30,255,400 Yen" in column (j). File this summary return in the manner foreign corporation that ends with or within
• Enter "108.8593" in column (k). described in When and Where To File, your tax year. When filing Schedule O,
• Enter "277,931" in column (l). earlier. report acquisitions, dispositions, and
organizations or reorganizations that
Computer-Generated Treaty-Based Return Positions occurred during your tax year.
Form 5471 and Schedules You are generally required to file
Generally, all computer-generated forms Form 8833, Treaty-Based Return Position Section 898 specified foreign corpora-
must receive prior approval from the IRS Disclosure Under Section 6114 or tion (SFC). The annual accounting
and are subject to an annual review. 7701(b), to disclose a return position that period of an SFC (as defined in section
However, see the Exception below. any treaty of the United States (such as an 898) is generally required to be the tax
Requests for approval may be submitted income tax treaty, an estate and gift tax year of the corporation's majority U.S.
electronically to substituteforms@irs.gov, treaty, or a friendship, commerce, and shareholder. If there is more than one
or requests may be mailed to: navigation treaty): majority shareholder, the required tax year
• Overrides or modifies any provision of will be the tax year that results in the least
Internal Revenue Service the Internal Revenue Code; and aggregate deferral of income to all U.S.
Attention: Substitute Forms Program • Causes, or potentially causes, a shareholders of the foreign corporation.
SE:W:CAR:MP:P:TP reduction of any tax incurred at any time. For these purposes, section 898(b)
1111 Constitution Ave. NW defines an SFC as any foreign
Room 6554 See Form 8833 for exceptions. corporation:
Washington, DC 20224 Failure to make a required disclosure 1. That is treated as a CFC under
may result in a $1,000 penalty ($10,000 subpart F, and
Exception. If a computer-generated for a C corporation). See section 6712. 2. In which more than 50% of the total
Form 5471 and its schedules conform to voting power or value of all classes of
Section 362(e)(2)(C) Elections
and do not deviate from the official form stock of the corporation is treated as
and schedules, they may be filed without The transferor and transferee in certain owned by a U.S. shareholder.
prior approval from the IRS. section 351 transactions may make a joint
election under section 362(e)(2)(C) to limit For more information, see section 898
Important. Be sure to attach the approval the transferor's basis in the stock received and Rev. Proc. 2006-45, 2006-45 I.R.B.
letter to Form 5471. However, if the instead of the transferee's basis in the 851, available at IRS.gov/irb/
computer-generated form is identical to transferred property. The election is made 2006-45_IRB#2006-45, as modified by
the IRS-prescribed form, it does not need by a statement as provided in Regulations Rev. Proc. 2007-64, 2007-42 I.R.B. 818,
to go through the approval process, and section 1.362-4(d)(3). available at IRS.gov/irb/
2007-42_IRB#RP-2007-64.
an attachment is not necessary. Do not attach the statement
Every year, the IRS issues a revenue ! described above to Form 5471.
procedure to provide guidance for filers of CAUTION

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Name of Person Filing This occurred, or an election to treat the foreign 5471 may be determined by the unrelated
corporation as a disregarded entity has section 958(a) U.S. shareholder or the
Return
been made. If this Item D is checked, unrelated constructive U.S. shareholder,
The name of the person filing Form 5471 complete Schedule O. as applicable, on the basis of alternative
is generally the name of the U.S. person information (without adjustments other
described in the applicable category or Item E—Excepted Specified than those described in sections 3.01(b)
categories of filers (see Categories of Foreign Financial Assets and 3.10 of the revenue procedure) with
Filers, earlier). However, in the case of a Check the Item E checkbox if any respect to the SFC. See section 3 of Rev.
consolidated return, enter the name of the excepted specified foreign financial assets Proc. 2019-40 for definitions of terms.
U.S. parent in the field for “Name of are reported on Form 5471. If this is the Item G—Alternative Information
person filing this return.” Be sure to list case, you do not have to also report these
each U.S. shareholder of the foreign assets on Form 8938, Statement of Code
corporation in Schedule B, Part I. Specified Foreign Financial Assets. It is If the box on line F is checked, enter the
Name change. If the name of either the only necessary to complete Form 8938, applicable code from the list provided
person filing the return or the corporation Part IV, line 17. For more information, see below.
whose activities are being reported the Instructions for Form 8938, generally,
changed within the past 3 years, show the and in particular, Duplicative Reporting Audited separate-entity financial statements of
prior name(s) in parentheses after the and the specific instructions for Part IV, the foreign corporation that are prepared in
current name. Excepted Specified Foreign Financial 01 accordance with U.S. generally accepted
Assets. accounting principles (U.S. GAAP).
Address
Include the suite, room, or other unit Item F—Alternative Information Audited separate-entity financial statements of
number after the street address. If the post Under Rev. Proc. 2019-40 02 the foreign corporation that are prepared on
the basis of international financial reporting
office does not deliver mail to the street Check the box on line F if Form 5471 has standards (IFRS).
address and the U.S. person has a P.O. been completed using alternative Audited separate-entity financial statements of
box, show the box number instead. information (as defined in section 3.01 of the foreign corporation that are prepared on
Foreign address. Enter the information Rev. Proc. 2019-40). 03 the basis of the generally accepted accounting
principles of the jurisdiction in which the foreign
in the following order: city, province or Section 5 of Rev. Proc. 2019-40 corporation is organized (“local-country
state, and country. Follow the country's provides a safe harbor for determining GAAP”).
practice for entering the postal code, if certain items, including taxable income
any. Do not abbreviate the country name. and E&P, of certain CFCs based on Unaudited separate-entity financial statements
alternative information. Specifically, in the 04 of the foreign corporation that are prepared in
accordance with U.S. GAAP.
Item A—Identifying Number case of a foreign-controlled CFC with
The identifying number of an individual is respect to which there is no related Unaudited separate-entity financial statements
his or her social security number (SSN). section 958(a) U.S. shareholder, if 05 of the foreign corporation that are prepared on
The identifying number of all others is their information satisfying the requirements of the basis of IFRS.
employer identification number (EIN). If a Regulations section 1.952-2(a), (b), and Unaudited separate-entity financial statements
U.S. corporation that owns stock in a (c)(2) and section 964 and the regulations 06 of the foreign corporation that are prepared on
foreign corporation is a member of a thereunder is not readily available to an the basis of local-country GAAP.
consolidated group, list the common unrelated section 958(a) U.S. shareholder Separate-entity records used by the foreign
parent as the person filing the return and or an unrelated constructive U.S. 07 corporation for tax reporting.
enter its EIN in Item A. shareholder with respect to the Separate-entity records used by the foreign
Item B—Category of Filer foreign-controlled CFC, an amount 08 corporation for internal management controls
reported on a Form 5471 may be or regulatory or other similar purposes.
Complete Item B to indicate the category determined by the unrelated section
or categories that describe the person 958(a) U.S. shareholder or the unrelated
filing this return. If more than one category constructive U.S. shareholder, as
applies, check all boxes that apply. See applicable, on the basis of alternative Information described in a code listed
Categories of Filers, earlier. information (without adjustments other above qualifies as alternative information
than those described in section 3.01(b) only if information described in any
Note. If you satisfy the requirements of and 3.10 of the revenue procedure) with preceding code is not “readily available”
both Category 4 and Category 5a filers, respect to the foreign-controlled CFC. See (as defined in section 3.04 of Rev. Proc.
only check the box for Category 4 and section 3 of Rev. Proc. 2019-40 for 2019-40). For example, information
leave the box for Category 5a blank. definitions of terms. described in code “03” above qualifies as
alternative information only if information
Item C—Percentage of Voting Section 6 of Rev. Proc. 2019-40 described in code “01” and “02” is not
Stock Owned provides a safe harbor for determining readily available.
Enter the total percentage of the foreign certain items of certain SFCs based on
corporation's voting power you owned alternative information. Specifically, in the For more information, see Rev. Proc.
directly, indirectly, or constructively at the case of an SFC, other than either a 2019-40.
end of the corporation's annual accounting foreign-controlled CFC with respect to Item H—Person(s) on Whose
period. which there is no related section 958(a) Behalf This Information Return
U.S. shareholder or a U.S. controlled
Item D—Final Year CFC, if information satisfying the Is Filed
Check the Item D checkbox only if this is requirements of section 964 and the One person may file Form 5471 and the
the final year of the foreign corporation's regulations thereunder is not readily applicable schedules for other persons
existence as a corporation for federal tax available to an unrelated section 958(a) who have the same filing requirements.
purposes, for example, if a reorganization U.S. shareholder or an unrelated See Multiple filers of same information,
has occurred, a complete liquidation has constructive U.S. shareholder with respect earlier. The person that files the required
to the SFC, an amount reported on a Form information on behalf of other persons

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must complete a joint Form 5471 5471 reporting is required. These with a previous reference ID number when
according to the applicable column(s) of numbers are used to uniquely identify the assigning a new reference ID number to a
the Filing Requirements for Categories of foreign corporation in order to keep track foreign corporation. For example:
Filers, earlier. This includes completing of the corporation from tax year to tax • In the case of a merger or acquisition, a
Item H on page 1 of the form. When year. Form 5471 filer must use a reference ID
completing Item H with respect to number that correlates the previous
members of a consolidated group, identify The reference ID number must meet reference ID number with the new
only the direct owners in Item H the requirements set forth below. reference ID number assigned to the
(constructive owners are not required to foreign corporation; or
be listed). Note. Because reference ID numbers are In the case of an entity classification
established by or on behalf of the U.S. •
election that is made on behalf of a foreign
A separate Schedule I must be filed for person filing Form 5471, there is no need corporation on Form 8832, Regulations
each person described in Category 4, 5a, to apply to the IRS to request a reference section 301.6109-1(b)(2)(v) requires the
or 5b. For each Category 4, 5a, or 5b filer ID number or for permission to use these foreign corporation to have an EIN for this
that is required to file a Schedule I, send a numbers. election. For the first year that Form 5471
copy of their separate Schedule I to them
to assist them in completing their tax Note. The reference ID number assigned is filed after an entity classification election
return. to a foreign corporation on Form 5471 is made on behalf of the foreign
generally has relevance only on Form corporation on Form 8832, the new EIN
Filing requirements for persons identi- 5471, its schedules, and any other form must be entered on line 1b(1) of Form
fied in Item H. Except for members of that is attached to or associated with Form 5471 and the old reference ID number
the filer's consolidated return group, all 5471, and generally should not be used must be entered on line 1b(2). In
persons identified in Item H must attach a with respect to that foreign corporation on subsequent years, the Form 5471 filer
statement to their tax returns that includes any other IRS forms. However, the foreign may continue to enter both the EIN on
the following information. corporation’s reference ID number should line 1b(1) and the reference ID number on
• The name, address, and EIN (or also be entered on Form 8858 if the line 1b(2), but must enter at least the EIN
reference ID number) of the foreign foreign corporation is listed as a tax owner on line 1b(1).
corporation(s). of a foreign disregarded entity (FDE) or You must correlate the reference ID
• A statement that their filing foreign branch (FB) on Form 8858. See numbers as follows: New reference ID
requirements with respect to the foreign the instructions for Form 8858, line 3c(2), number [space] Old reference ID number.
corporation(s) have been or will be for more information. Also, if a U.S. If there is more than one old reference ID
satisfied. shareholder is required to file Schedule A number, you must enter a space between
• The name, address, and identifying (Form 8992) or Schedule B (Form 8992) each such number. As indicated above,
number of the taxpayer on the return with with respect to the CFC, the reference ID the length of a given reference ID number
which the information was or will be filed. number on Form 5471 and the reference is limited to 50 characters and each
• The IRS Service Center where the ID number used on Schedule A (Form number must be alphanumeric and no
return was or will be filed. If the return was 8992) or Schedule B (Form 8992) for that special characters are permitted.
or will be filed electronically, enter “e-file.” CFC must be the same.
Note. This correlation requirement
Exception. If the person who is filing Requirements. The reference ID number applies only to the first year the new
Form 5471 on behalf of others is married that is entered in Item 1b(2) must be reference ID number is used and it applies
to a person identified in Item H and they alphanumeric (defined later) and no only on Form 5471, page 1, line 1b(2). On
are filing Form 1040 jointly, the statement special characters or spaces are all separate schedules for Form 5471,
described above does not have to be permitted. The length of a given reference please enter only the current reference ID
attached to the jointly filed Form 1040. ID number is limited to 50 characters. number in the applicable entry space.
All persons identified in Item H The same reference ID number must
! must complete a separate be used consistently from tax year to tax Items 1f and 1g—Principal
CAUTION Schedule P (Form 5471) if the year with respect to a given foreign Business Activity
person is a U.S. shareholder described in corporation. If for any reason a reference Enter the principal business activity code
Category 1a, 1b, 4, 5a, or 5b. In such a ID number falls out of use (for example, number and the description of the activity
case, the Schedule P must be attached to the foreign corporation no longer exists from the list at the end of these
the statement described above. due to disposition or liquidation), the instructions.
reference ID number used for that foreign
Item 1b(2)—Reference ID corporation cannot be used again for For tax year 2022, several
Number another foreign corporation for purposes ! changes have been made to the
A reference ID number (defined below) is of Form 5471 reporting. CAUTION principal business activities and
codes listed at the end of these
required on line 1b(2) only in cases where For these purposes, the term instructions. See the revised list before
no EIN was entered on line 1b(1) for the “alphanumeric” means the entry can be entering a six-digit code and the
foreign corporation. However, filers are alphabetical, numeric, or any combination description of the activity on page 1, items
permitted to enter both an EIN on of the two. 1f and 1g.
line 1b(1) and a reference ID number on Taxpayers no longer have the option of
line 1b(2). If applicable, enter the entering “FOREIGNUS” or “APPLIED Item 1h—Functional Currency
reference ID number you have assigned to FOR” in a column that requests an EIN or The foreign corporation's functional
the foreign corporation identified on reference ID number with respect to a currency is determined under section 985.
line 1a. foreign entity. Instead, if the foreign entity Enter the applicable three-character
A "reference ID number" is a number does not have an EIN, the taxpayer must alphabet code for the foreign corporation's
established by or on behalf of the U.S. enter a reference ID number that uniquely functional currency using the ISO 4217
person identified at the top of page 1 of identifies the foreign entity. standard. These codes are available at
the form that is assigned to a foreign There are some situations that warrant www.six-group.com/en/products-services/
corporation with respect to which Form correlation of a new reference ID number

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financial-information/data- Category 4 filers should list all direct and deferred income tax expense (benefit)
standards.html#scrollTo=currency-codes. owners of the CFC. Category 1a, 3, and on line 21b.
Click on List One (XLS). 5a filers should list all direct owners of the
SFC or CFC through which such filer Note. If there is an income tax expense
Regulations sections 1.6038-2(h) and indirectly owns the SFC or CFC as amount on line 21a or 21b, subtract that
1.6046-1(g) require that certain amounts described in section 958(a)(2). Category amount from the line 19 net income or
be reported in U.S. dollars and/or in the 1c and 5c filers should list all direct (loss) amount in arriving at line 22 current
foreign corporation's functional currency. owners of the SFC or CFC from which year net income or (loss) per the books. If
The specific instructions for the affected such filer is attributed ownership in the there is an income tax benefit amount on
schedules state these requirements. SFC or CFC as described in section line 21a or 21b, add that amount to the
Special rules apply for foreign 958(b). If the filer is a direct owner, include line 19 net income or (loss) amount in
corporations that use the U.S. dollar the filer's direct ownership. arriving at line 22 current year net income
or (loss) per the books.
approximate separate transactions
method of accounting (DASTM) under Lines 23 and 24. Enter amounts defined
Regulations section 1.985-3. See the Schedule C in ASC 220 (Income Statement -
instructions for Schedule C and Report all information in the foreign Reporting Comprehensive Income).
Schedule H. corporation's functional currency in
accordance with U.S. GAAP and translate Line 23a. Enter foreign currency
using U.S. GAAP translation principles. translation adjustments before the income
Schedule B tax expense (benefit) is allocated.
Note. If any person (including the filer) is If the foreign corporation uses the
both a U.S. shareholder and a direct DASTM under Regulations section Line 23b. Enter other comprehensive
shareholder of the foreign corporation, 1.985-3, the functional currency column income such as foreign currency gains or
that person’s information should be should reflect local hyperinflationary losses on certain hedging transactions,
provided in both Schedule B, Part I and currency amounts computed in pensions and other post-retirement
Part II. accordance with U.S. GAAP. The U.S. benefits, and certain investments
dollar column should reflect such amounts available-for-sale.
Part I translated into dollars under U.S. GAAP Line 23c. Enter the income tax
Category 3 and 4 filers must complete translation rules. Differences between this expense (benefit) allocated to OCI items
Schedule B, Part I, for U.S. persons that U.S. dollar GAAP column and the U.S. in the intraperiod allocation.
owned (at any time during the annual dollar income or loss figured for tax
accounting period), directly or indirectly purposes under Regulations section Important. Differences between the
through foreign entities, 10% or more of 1.985-3(c) should be accounted for on functional currency amount of income tax
the total combined voting power of all Schedule H. See Schedule H, Special expense (benefit) reported on line 21 and
classes of stock entitled to vote of the rules for DASTM, later. the amount of taxes that reduce or
increase U.S. earnings and profits (E&P)
foreign corporation, or 10% or more of the Line 8. Enter foreign currency transaction should be accounted for on line 2g of
total value of shares of all classes of stock gain or loss reported on the income Schedule H.
of the foreign corporation. statement. For amounts included in Other
Comprehensive Income (OCI), see the
A person that is both a category 3 and instructions for Lines 23 and 24. Enter Schedule F
category 5 filer because it is treated as a unrealized gain or loss on line 8a and Report all information in U.S. dollars.
U.S. shareholder under section 953(c)(1) realized gain or loss on line 8b. Generally, the foreign corporation's
(A) with respect to the foreign corporation
must complete Schedule B, Part 1 for U.S. Line 16. Enter transactional taxes balance sheet is prepared in functional
persons that owned (on the last day of the excluding items reportable in income tax currency and translated to U.S. dollars
foreign corporation’s taxable year), expense (benefit). Report income taxes on using U.S. GAAP translation rules. If the
directly or indirectly through foreign line 21. foreign corporation uses DASTM, the tax
balance sheet on Schedule F should be
entities, any of the foreign corporation's Line 20. The term “unusual or prepared and translated into U.S. dollars
outstanding stock. infrequently occurring items” is defined by according to Regulations section
Column (e). Enter each shareholder's U.S. GAAP (see FASB Accounting 1.985-3(d), rather than U.S. GAAP.
allocable percentage of the foreign Standards Codification (ASC) Topic 220
corporation's subpart F income. (Income Statement), Subtopic 220-20 Lines 3 and 17. Enter the total asset
(Unusual or Infrequently Occurring Items) amount of derivatives on line 3 and total
Part II or subsequent guidance). If “prior period amount of liability on line 17 reported in
Category 1a, 1c, 3, 4, 5a, and 5c filers adjustments” are not reported separately accordance with ASC 815 (Derivatives
must complete Part II. on the income statement, do not report and Hedging). Do not net positions.
such amounts on this line item (see ASC Include all derivatives, both short-term
Report the direct shareholders of the 250 (Accounting Changes and Error and long-term.
foreign corporation. In the case of a CFC Corrections) or subsequent guidance).
owned by a foreign disregarded entity
(FDE), please include the information of Line 21. Enter income tax expense
the FDE and the regarded entity owner. (benefit) reported in accordance with U.S. Schedule G
Indicate the regarded entity owner's name GAAP (ASC 740 (Income Taxes)). Income Note. Category 1b and 5b filers are not
in parentheses after the FDE's name. If tax expense (benefit) includes current and required to file Schedule G for
there is more than one regarded entity deferred income tax expense (benefit). It foreign-controlled section 965 SFCs and
owner, use separate lines for each, listing may also reflect uncertain tax positions foreign-controlled CFCs, respectively.
each regarded entity owner in column (a) (ASC 740-10) and would not include taxes Question 1
and reporting the information requested in paid in respect of uncertain tax positions If the foreign corporation owned at least a
columns (b), (c), and (d) for each such recorded in prior years. Enter the current 10% interest, directly or indirectly, in any
regarded entity owner. income tax expense (benefit) on line 21a

Instructions for Form 5471 (Rev. 01-2023) -11-

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foreign partnership, attach a statement received or accrued by the foreign instructions for information on the section
listing the following information for each corporation in connection with the 250 deduction. If no deduction is being
foreign partnership. acquisition of depreciable or amortizable claimed, check the “No” box on line 6a
1. Name and EIN (if any) of the property (section 59A(d)(2)), reinsurance and go to line 7.
foreign partnership. payments (section 59A(d)(3)), and certain
payments relating to expatriated entities Question 9a
2. Identify which, if any, of the (section 59A(d)(4)). Under section 367(d), a U.S. transferor
following forms the foreign partnership must report an annual income inclusion
filed for its tax year ending with or within The term “base erosion tax benefit” attributed to the intangible property
the corporation's tax year: Form 1042, generally means any U.S. deduction that transferred to a foreign corporation over
1065, or 8804. is allowed under chapter 1 for the tax year the useful life of the property. Check “Yes”
3. Name of the partnership with respect to any base erosion payment. if the foreign corporation received any
representative (if any). See section 59A(c)(2)(A) and (B) for intangible property in a prior year or the
4. Beginning and ending dates of the further details. current tax year in an exchange under
section 351 or section 361 from a U.S.
foreign partnership's tax year. Questions 5a and 5b transferor that is required to report a
Question 3 If the foreign corporation paid or accrued section 367(d) annual income inclusion for
any interest or royalty (including in the the tax year. If “Yes,” complete line 9b.
Check the “Yes” box if the foreign case of a foreign corporation that is a
corporation is the tax owner of an FDE or partner in a partnership, the foreign Question 9b
FB. The “tax owner” of an FDE is the corporation’s allocable share of interest or Enter in functional currency the amount of
person that is treated as owning the royalty paid by the partnership) for which a the E&P reduction made by the foreign
assets and liabilities of the FDE for deduction is disallowed under section corporation for the current tax year that
purposes of U.S. income tax law. 267A, check “Yes” for question 5a and equals the amount required to be included
If the foreign corporation is the tax enter the total amount for which a in the income of the U.S. transferor. See
owner of an FDE or FB and you are a deduction is not allowed on line 5b. The section 367(d). This amount should also
Category 4, 5a, or 5c filer of Form 5471, amount reported on line 5b should not be entered on Schedule H, Current
you are required to attach Form 8858 to include disallowed deductions attributable Earnings and Profits, as a net subtraction
Form 5471. to interest or royalty paid or accrued by a on line 2i.
U.S. taxable branch of the foreign
If the foreign corporation is the tax corporation; such amounts are reported Question 10
owner of an FDE or FB and you are not a on Form 1120-F. A foreign corporation may qualify as an
Category 1b, 4, or 5 filer of Form 5471, expatriated foreign subsidiary under
you must attach the statement described Interest or royalty paid or accrued by a Regulations section 1.7874-12(a)(9) if
below in lieu of Form 8858. foreign corporation (including through a such foreign corporation is a CFC with
partnership) is subject to section 267A, respect to which an expatriated entity, as
Statement in lieu of Form 8858. This provided in general that the foreign defined in Regulations section
statement must list the name of the FDE or corporation is a CFC (and there are one or 1.7874-12(a)(8) is a U.S. shareholder.
FB, country under whose laws the FDE or more U.S. tax residents that own directly Certain transactions involving an
FB was organized, and EIN (if any) of the or indirectly at least 10% of the stock of expatriated foreign subsidiary and/or its
FDE or FB. the CFC). Section 267A disallows a U.S. shareholders may be subject to
deduction for certain interest or royalty
Questions 4b and 4c special rules. If the answer to Question 10
paid or accrued pursuant to a hybrid is "Yes," attach a statement providing the
Complete lines 4b and 4c if: arrangement, to the extent that, under the name and EIN of the domestic corporation
1. The foreign corporation is a related foreign tax law, there is not a or partnership, as defined in Regulations
party to the U.S. filer within the meaning of corresponding income inclusion (including section 1.7874-12(a)(6) and the
section 59A(g); and long-term deferral). For more detailed relationship of the foreign corporation to
2. The U.S. filer made or accrued a instructions, see the instructions for Form the domestic corporation or partnership.
base erosion payment to, or has a base 1120, Schedule K, Question 21.
Question 14
erosion tax benefit with respect to, the Question 6 Check the "Yes" box on line 14 if you
foreign corporation.
Check the “Yes” box on line 6a if the filer is answer “Yes” to any of the 22 questions in
The term “base erosion payment” claiming a deduction under section 250 the Schedule G, line 14 table below. If
generally means any amount paid or with respect to foreign-derived intangible "Yes," enter the Corresponding Code(s)
accrued by the U.S. filer to a foreign income (FDII), and enter the amounts from the table in the entry space provided
corporation that is a related party to the requested on lines 6b, 6c, and 6d. Enter on line 14 of the form. Enter the applicable
U.S. filer within the meaning of section U.S. dollar amounts on lines 6b, 6c, and corresponding code in capital letters.
59A(g) and with respect to which a U.S. 6d, translated from functional currency at Enter a space between each code. Also
deduction is allowed under chapter 1 of the average exchange rate for the foreign attach the statement described in the table
the Code. See section 59A(d)(1). Base corporation's tax year (see section below.
erosion payments also include amounts 989(b)). See Form 8993 and its

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Form 5471

Schedule G, Line 14

                                 Question                                      See Worksheet A in the  If “Yes,”          Code           If “Yes,” content of 
                                                                               Schedule I instructions Corresponding  Description        statement to be 
                                                                                                            Code to enter                attached to Form 5471
                                                                                                            on 
                                                                                                            Schedule G, 
                                                                                                            line 14
1 During the tax year, was the sum of the CFC’s foreign base company           In other words, is line 7       DM         De minimis     Amount excluded by 
  income (determined without regard to deductions) and gross                   less than line 8 and less                                 reason of the de 
  insurance income less than the lesser of 5% of gross income or $1            than $1 million?                                          minimis rule (but only to 
  million?                                                                                                                               the extent not already 
                                                                                                                                         included in amounts 
                                                                                                                                         below)
2 During the tax year, did the CFC receive any item of income that was         In other words, is              HT         High Tax       Sum of the amounts 
  subject to an effective rate of income tax imposed by a foreign country  line 13g, 14d, 15d, 16d,                                      from lines 13g, 14d, 
  greater than 90% of the maximum rate of tax specified in section 11?         18d, or 19d of Worksheet                                  15d, 16d, 18d, and 19d
                                                                               A greater than zero?  
3 During the tax year, was the CFC’s foreign personal holding company          In other words, is              DED        Deductions     Sum of the amounts 
  income, foreign base company sales income, or foreign base                   line 13b, 13d, 13e, 14b,                   taken into     from lines 13b, 13d, 
  company services income reduced so as to take into account any               15b, or 16b of Worksheet                   account        13e, 14b, 15b, and 16b
  deductions (including taxes)?                                                A greater than zero?
4 During the tax year, did the CFC have any gains or losses that (i) arise  In other words, are any            AHC        Active/hedging  Sum of the excluded 
  out of commodity hedging transactions, (ii) are active business gains        amounts described in                       commodities    amounts described in 
  or losses from the sale of commodities (and substantially all of the         section 954(c)(1)(C)(i),                                  section 954(c)(1)(C)(i), 
  corporation’s commodities are property described in section 1221(a)          (ii), or (iii) excluded from                              (ii), and (iii)
  (1), (2), or (8)), or (iii) are foreign currency gains or losses (as defined line 1c of Worksheet A? 
  in section 988(b)) attributable to any section 988 transactions? 
5 During the tax year, did the CFC have excess foreign currency gains          In other words, are any         BN         Business needs Amount excluded
  over foreign currency losses (as defined in section 988(b)) attributable  amounts excluded from 
  to any section 988 transaction directly related to the business needs of  line 1d of Worksheet A by 
  the foreign corporation?                                                     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 than a         In other words, are any         ARR        Active rents/  Amount excluded
  related person within the meaning of section 954(d)(3),  rents or            amounts described in                       royalties
  royalties that were derived in the active conduct of a trade or business?  section 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 banking         In other words, are any         EF         Certain export Amount excluded
  business, interest that is export financing interest?                        amounts described in                       financing
                                                                               section 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 any         RD         Regular dealers Amount excluded
  described in section 954(c)(1)(B), forward contracts, option contracts,  amounts described in 
  or similar financial instruments (including notional principal contracts     section 954(c)(2)(C)(i) 
  and all instruments referenced to commodities)?  If so, did the foreign      excluded from line 1a of 
  corporation derive any item of income, gain, deduction, or loss (other       Worksheet A? 
  than any item described in section 954(c)(1)(A), (E), or (G)) from any 
  transaction entered into in the ordinary course of its trade or business 
  as a regular dealer? 
9 During the tax year, was the CFC a securities dealer within the              In other words, are any         SD         Securities     Amount excluded
  meaning of section 475?  If so, did the foreign corporation derive any       amounts described in                       dealers
  interest or dividend or equivalent amount described in section 954(c)        section 954(c)(2)(C)(ii) 
  (1)(E) or (G) from any transaction entered into in the ordinary course of  excluded from line 1a of 
  its trade or business as a securities dealer?                                Worksheet A? 

Instructions for Form 5471 (Rev. 01-2023)                                      -13-

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Form 5471, Schedule G, Line 14, continued

                      Question                                             See Worksheet A in the  If “Yes,”        Code           If “Yes,” content of 
                                                                           Schedule I instructions    Corresponding  Description   statement to be 
                                                                                                      Code to enter                attached to Form 
                                                                                                      on                           5471
                                                                                                      Schedule G, 
                                                                                                      line 14
10 During the tax year, did the CFC receive dividends* or interest** from a  In other words, are any     SCDI       Same country   Amount excluded
related person that (i) is a corporation created or organized under the    amounts described in                     dividends/
laws of the same country under the laws of which the CFC is created        section 954(c)(3)(A)(i)                  interest
or organized, and (ii) has a substantial part of its assets used in its    excluded from line 1a of 
trade or business located in the same foreign country?                     Worksheet A?
*Dividends (other than dividends with respect to any stock, which are 
attributable to earnings and profits 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 
(i) and (ii)).
**Interest (other than interest that reduces the payor's subpart F 
income or creates or increases a deficit that may reduce the subpart F 
income of the payor or another CFC).
11 During the tax year, did the CFC receive, from a corporation that is a  In other words, are any       SCRR       Same country   Amount excluded
related person, rents or royalties* for the use of, or privilege of using, amounts described in                     rents/royalties
property within the country under the laws of which the CFC is created  section 954(c)(3)(A)(ii) 
or organized?                                                              excluded from line 1a of 
*Rents or royalties (other than rents or royalties that reduce the payor's  Worksheet A?
subpart F income or create or increase a deficit that 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 related CFC  In other words, are any        LT         Look through   Amount excluded
dividends, interest (including factoring income treated as income          amounts excluded from 
equivalent to interest for purposes of section 954(c)(1)(E)), rents, or    line 1a of Worksheet A by 
royalties attributable or properly allocable to income of the related      reason of the 
person which is neither subpart F income nor income treated as             look-through rule 
effectively connected with the conduct of a trade or business in the       described in section 
United States?                                                             954(c)(6)? 
13 During the tax year, did the CFC derive income (either directly or      In other words, are any       AC         Agricultural   Amount excluded
through a branch or similar establishment, for example, disregarded        amounts excluded from                    commodities
entity) in connection with the purchase or sale from, to, or on behalf of  line 3 of Worksheet A by 
a related person, of agricultural commodities not grown in the United      reason of the special rule 
States in commercially marketable quantities?                              in Regulations section 
                                                                           1.954-3(a)(1)(ii)? 
14 During the tax year, did the CFC derive income (either directly or      In other words, are any       SCM        Same country   Amount excluded
through a branch or similar establishment, for example, disregarded        amounts that are derived                 manufacturing
entity) in connection with the purchase or sale from, to, or on behalf of  in connection with 
a related person, of personal property manufactured in the same            property that does not 
country under the laws of which the CFC is created or organized?           satisfy section 954(d)(1)
                                                                           (A) excluded from line 3 
                                                                           of Worksheet A (that is, 
                                                                           income excluded by 
                                                                           reason of Regulations 
                                                                           section 1.954-3(a)(2))? 
15 During the tax year, did the CFC derive income (either directly or      In other words, are any       SCSU       Same country   Amount excluded
through a branch or similar establishment, for example, a disregarded  amounts that are derived                     sales/use
entity) in connection with the purchase or sale from, to, or on behalf of  in connection with 
a related person, of personal property purchased or sold for use or        property that does not 
consumption in the same country under the laws of which the CFC is         satisfy section 954(d)(1)
created or organized?                                                      (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 or      In other words, are any       PM         Physical       Amount excluded
through a branch or similar establishment, for example, a disregarded  amounts excluded from                        manufacturing
entity) in connection with the purchase or sale from, to, or on behalf of  line 3 of Worksheet A by 
a related person, of personal property manufactured by the CFC within  reason of Regulations 
the meaning of Regulations section 1.954-3(a)(4)(ii) or (iii)?             section 1.954-3(a)(4)(ii) 
                                                                           or (iii)? 

                                                                           -14-                          Instructions for Form 5471 (Rev. 01-2023)

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Form 5471, Schedule G, Line 14, continued

                                 Question                                 See Worksheet A in the  If “Yes,”        Code               If “Yes,” content of 
                                                                          Schedule I instructions    Corresponding  Description       statement to be 
                                                                                                     Code to enter                    attached to Form 
                                                                                                     on                               5471
                                                                                                     Schedule G, 
                                                                                                     line 14
17 During the tax year, did the CFC derive income (either directly or     In other words, are any       SC         Substantial        Amount excluded
   through a branch or similar establishment, for example, a              amounts excluded from                    contribution
   disregarded entity) in connection with the purchase or sale from, to,  line 3 of Worksheet A by 
   or on behalf of a related person, of personal property manufactured    reason of Regulations 
   by the CFC within the meaning of Regulations section 1.954-3(a)(4)     section 1.954-3(a)(4)(iv)? 
   (iv)?
18 During the tax year, did the CFC derive income through the conduct     In other words, are any       BR         Branch             Amount excluded
   of any manufacturing or sales activities (including mere passage of    amounts excluded from 
   title) through a branch or similar establishment (such as a            line 3 of Worksheet A by 
   disregarded entity of the CFC) that would have been foreign base       reason of disregarding a 
   company sales income described in section 954(d) except that either  branch or similar 
   (1) the branch or other similar establishment was not treated as a     establishment (including 
   wholly owned subsidiary separate from the CFC under section 954(d) a disregarded entity) of 
   (2) and the regulations or (2) the income is not foreign base company  the CFC as separate from 
   sales income after the application of Regulations section 1.954-3(b)   the CFC?  
   (2)(ii)(e)?
19 During the tax year, was the CFC an eligible CFC (as defined in        In other words, are any       AF         Active financing   Amount excluded
   section 954(h)(2)) that derived qualified banking or financing income  amounts excluded from 
   (as defined in section 954(h)(3))?                                     lines 1a–1i of Worksheet 
                                                                          A by reason of the special 
                                                                          rule described in section 
                                                                          954(h)? 
20 During the tax year, was the CFC a qualifying insurance company (as  In other words, are any             AI     Active insurance Amount excluded
   defined in section 953(e)(3)) that derived qualified insurance income  amounts excluded from 
   (as defined in section 954(i)(2))?                                     lines 1a–1i of Worksheet 
                                                                          A by reason of the special 
                                                                          rule described in section 
                                                                          954(i)? 
21 During the tax year, did the subpart F income of the CFC exceed the  In other words, is line 36      EP         Earnings &         Excess of line 36 over 
   earnings and profits of such corporation?                              of Worksheet A greater                   profits limitation line 37c
                                                                          than line 37c?  
22 In determining the pro rata share of subpart F income or tested items  In other words, is line 58    XX         Other              The amounts from 
   of the U.S. person filing this return, was the amount of distributions of Worksheet A greater                                      lines 58 and 59 of 
   by the CFC during the tax year and described in section 951(a)(2)(B)  than zero?                                                   Worksheet A.
   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 or                                                                  reduction amount, or 
   exclude any amounts reported or reportable as subpart F income (of                                                                 other amount not 
   or with respect to the CFC)?                                                                                                       reported or reportable
Question 15                                  current tax year. If “Yes,” enter the amount                   extraordinary reduction amount or tiered 
For the foreign corporation’s annual         from the prior year Form 8990, line 31.                        extraordinary reduction amount as to any 
                                                                                                            U.S. shareholder of the foreign 
accounting period with respect to which      Question 17a                                                   corporation. See Regulations section 
reporting is being made on this Form         Check the “Yes” box on line 17a if there                       1.245A-5(e)(3)(i) for further guidance 
5471, if the foreign corporation is required was an extraordinary reduction with                            regarding the election to close the tax 
to file a U.S. income tax return (for        respect to any controlling section 245A                        year. If the “Yes” box on line 17b has been 
example, Form 1120 F), check the “Yes” ‐     shareholder of the foreign corporation, as                     checked and the U.S. shareholder filing 
box if the foreign corporation has interest  defined in Regulations section 1.245A-5(i)                     the Form 5471 is a controlling section 
expense disallowed under section 163(j).     (2), during the tax year of the foreign                        245A shareholder of the foreign 
If “Yes,” enter the amount from the current  corporation. See Regulations section                           corporation, the U.S. shareholder filing 
year Form 8990, line 31.                     1.245A-5(e)(2)(i) for the definition of                        this Form 5471 must attach an Elective 
Question 16                                  extraordinary reduction.                                       Section 245A Year-Closing Statement 
                                                                                                            pursuant to Regulations section 
For the foreign corporation’s annual         Question 17b                                                   1.245A-5(e)(3)(i)(C) containing the 
accounting period with respect to which      If the answer to the question on line 17a                      information required under Regulations 
reporting is being made on this Form         was “Yes,” complete the question on                            section 1.245A-5(e)(3)(i)(D).
5471, if the foreign corporation is required line 17b. Check the “Yes” box on line 17b 
to file a U.S. income tax return (for        if any controlling section 245A shareholder                    Question 18
example, Form 1120 F), check the “Yes” ‐     (as defined in Regulations section                             Check the “Yes” box if during the tax year 
box if the foreign corporation has           1.245A-5(i)(2)) made an election to close                      the reporting corporation had any loans to 
previously disallowed interest expense       the tax year of the foreign corporation                        or from the related party to which the safe 
under section 163(j) carried forward to the  such that no amount is treated as an                           haven rate rules of Regulations section 

Instructions for Form 5471 (Rev. 01-2023)                                 -15-

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1.482-2(a)(2)(iii)(B) are applicable, and for                                              Line 1c
which the reporting corporation used a        Schedule I                                   Enter the subpart F income inclusion 
rate of interest within the safe-haven range  Use Schedule I to report in U.S. dollars the attributable to tiered extraordinary 
of Regulations section 1.482-2(a)(2)(iii)(B)  U.S. shareholder's pro rata share of         disposition amounts resulting from 
(1) (100% to 130% of the AFR for the          income from the foreign corporation          distributions from an extraordinary 
relevant term).                               reportable under subpart F and other         disposition account of the shareholder 
                                              income realized from a corporate             filing this Form 5471 and received by the 
Question 19a                                  distribution.                                foreign corporation. See Regulations 
Note.   Complete lines 19a and 19b only if 
                                                                                           section 1.245A-5(d) for further guidance 
the filer is a domestic corporation. In       Certain filers may be able to use            on tiered extraordinary disposition 
completing these lines, do not account for    alternative information (as defined in       amounts.
debt instruments that were issued, or         section 3.01 of Rev. Proc. 2019-40) to 
distributions or acquisitions that occurred,  determine certain amounts in this            Line 1d
before April 5, 2016. See Regulations         schedule. See the specific instructions for  Enter the subpart F income inclusion 
section 1.385-3(g)(3) and 1.385-3(b)(3)       Item F—Alternative Information Under         attributable to tiered extraordinary 
(viii).                                       Rev. Proc. 2019-40, earlier, for more        reduction amounts resulting from 
Check “Yes” if, during the tax year, the      details.                                     extraordinary reductions. See Regulations 
filer engaged in at least one of the                                                       section 1.245A-5(f) for further guidance on 
transactions described in Regulations         Note.  A separate Schedule I must be         tiered extraordinary reduction amounts.
section 1.385-3(b)(2). Also check “Yes” if,   filed by or for each Category 4, 5a, or 5b 
taking into account issuances,                U.S. shareholder of the foreign              Lines 1e Through 1h
distributions, and acquisitions during the    corporation with respect to which reporting  Enter on lines 1e through 1h the amounts 
tax year and previous tax years, the filer    is furnished on this Form 5471.              from Worksheet A, lines 63, 65, 67, and 
had issued a debt instrument to the                                                        69, respectively. However, corporate U.S. 
foreign corporation during a period           Line 1
                                                                                           shareholders should report on line 1e the 
described in Regulations section              Subpart F income. U.S. shareholders of       amount from Worksheet A, line 63, less 
1.385-3(b)(3)(iii), which addresses certain   CFCs with subpart F income must report       the amount, if any, reported on line 1a.
issuances of debt instruments to related      that income on their tax returns. For more 
parties within 36 months before or after      information, see sections 245A, 951, 952,      Use Worksheet A, later in these 
certain distributions or acquisitions by the  and 964(e).                                  instructions, to compute the U.S. 
issuer. Otherwise, check “No.” Apply                                                       shareholder's pro rata share of subpart F 
Regulations section 1.385-3(b)(3)(iii)(E) to  Note. Certain current year deficits of a     income of the CFC, which is reportable on 
determine when a debt instrument is           member of the same chain of corporations     lines 1e through 1h. Do not include any 
treated as issued for purposes of             may be considered in determining subpart     income includible on Form 5471, 
Regulations section 1.385-3(b)(3)(iii).       F income. See section 952(c)(1)(C).          Schedule I, lines 1a through 1d, or any 
                                                                                           income includible under section 951A 
Debt that the filer treats as stock           Line 1a                                      (Schedule I-1 is used to provide 
pursuant to Regulations section 1.385-3 
still should be included when completing      Corporate U.S. shareholders should enter     information relating to section 951A). 
line 19a.                                     the foreign-source portion of any subpart F  Subpart F income reportable on lines 1e 
                                              income inclusions attributable to the sale   through 1h includes the following.
Question 19b                                  or exchange by a CFC of stock of another 
Provide the total amount of the               foreign corporation that is eligible for the • Adjusted net foreign base company 
transactions described in Regulations         section 245A dividends received              income (lines 1 through 17).
section 1.385-3(b)(2) (as measured by the     deduction pursuant to section 964(e)(4).     • Adjusted net insurance income 
fair market value of the distribution or, as  Include the amount, if any, that is not      (line 18).
the case may be, the property exchanged       eligible for the section 245A dividends      • Adjusted net related person insurance 
for the debt instrument), and of the          received deduction pursuant to section       income (line 19).
distributions and/or acquisitions described   964(e)(4) on line 1e. Noncorporate U.S.      • International boycott income (line 20).
in Regulations section 1.385-3(b)(3)(i) (as   shareholders should leave line 1a blank.     • Illegal bribes, kickbacks, and other 
                                                                                           payments (line 21).
measured by the fair market value of the      Line 1b                                      • Income described in section 952(a)(5) 
property distributed and/or acquired).                                                     (line 22).
                                              Enter the amount of the U.S. shareholder’s 
Provide the total amount (as measured         subpart F income inclusion attributable to   Important. If the subpart F income of any 
by issue price in the case of an instrument   tiered hybrid dividends received by the      CFC for any tax year was reduced 
treated as stock upon issuance, or            CFC. In general, a dividend received by a    because of the current E&P limitation, any 
adjusted issue price in the case of an        CFC from another CFC is a tiered hybrid      excess of the E&P of the CFC for any 
instrument deemed exchanged for stock)        dividend to the extent of the sum of the     subsequent tax year over the subpart F 
of the debt instrument issuances              receiving CFC's hybrid deduction             income of the CFC for the tax year must 
addressed by line 19a. See Regulations        accounts with respect to shares of stock of  be recharacterized as subpart F income. 
section 1.385-1(d)(1) and 1.385-3(d). The     the CFC that pays the dividend. As to a      As a result, if the foreign corporation has 
adjusted issue price of a debt instrument     domestic corporation that is a U.S.          E&P for the tax period covered by this 
is the issue price increased by the amount    shareholder with respect to both CFCs,       return that is subject to recapture as a 
of original issue discount previously         the tiered hybrid dividend is treated as     result of a prior-year E&P limitation, add 
includible in gross income of any holder      subpart F income of the receiving CFC,       such recapture amount to the result from 
and decreased by payments other than          and the U.S. shareholder must include in     Worksheet A, line 69, and include the 
payments of stated interest. See section      its gross income its pro rata share of the   combined amount on line 1h (Other 
1272(a)(4) and Regulations section            tiered hybrid dividend. See section          subpart F income). See the instructions for 
1.1275-1(b)(1).                               245A(e)(2) and Regulations section           Line 37, Current E&P limitation, later, for a 
                                              1.245A(e)-1(c) for additional information    discussion of the current year E&P 
                                              about tiered hybrid dividends.               limitation.

                                                            -16-                           Instructions for Form 5471 (Rev. 01-2023)

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Line 2 Note. The corporate U.S. shareholder group. See Regulations section
Report on line 2 earnings invested in U.S. should include the line 5b amount on Form 1.986(c)-1(c).
property (Worksheet B). 1120, Schedule C, line 14, column (a), or For a corporate U.S. shareholder,
the comparable line of other corporate include the gain or (loss) as “Other
Line 3 income tax returns. income” on Form 1120, line 10, or on the
Reserved for future use. Line 5c comparable line of other corporate tax
Line 4 Enter the amount of the dividends returns. For a noncorporate U.S.
Enter the factoring income (as defined in received by the shareholder from the shareholder, include the result as “Other
section 864(d)(1)) if no subpart F income foreign corporation that is an extraordinary income” on Schedule 1 (Form 1040),
is reported on line 1a of Worksheet A, reduction amount. See Regulations line 8z (other income), or on the
because of the operation of the de minimis section 1.245A-5(e) for rules for comparable line of other noncorporate tax
rule (see lines 1a and 10 of Worksheet A calculating an extraordinary reduction returns.
and the related instructions under Line 1a amount. Line 8a
and Line 10, De minimis rule), later. Check the “Yes” box on line 8a if the U.S.
Note. The corporate U.S. shareholder
should include the line 5c amount on Form shareholder completing this form had an
Reporting Amounts on Lines 1 1120, Schedule C, line 14, column (a), or extraordinary disposition account with
Through 4 on Your Income Tax the comparable line of other corporate respect to the foreign corporation having a
Return income tax returns. balance greater than zero at any time
during the tax year of the foreign
Line 5d corporation. See Regulations section
U.S. shareholders should compute their 1.245A-5(c) for rules regarding an
pro rata share of the income on Form Enter the amount of hybrid dividends
5471, Schedule I, lines 1a through 1h, 2, received by the U.S. shareholder from the extraordinary disposition account.
and 4. For a corporate shareholder, enter foreign corporation. In general, in the case Line 8b
the result from line 1a on Form 1120, of a domestic corporation that is a U.S.
Schedule C, line 16a; enter the result from shareholder with respect to a CFC, a If “Yes” is checked on line 8a, enter on
line 1b on Form 1120, Schedule C, dividend received by the domestic line 8b the U.S. shareholder’s
line 16b; and enter the remaining lines 1c corporation from the CFC is a hybrid extraordinary disposition account balance
through 1h, 2, and 4 on Form 1120, dividend to the extent of the sum of the at the beginning and end of the foreign
Schedule C, line 16c; or on the U.S. shareholder’s hybrid deduction corporation’s tax year. Attach a statement
comparable line of other corporate tax accounts with respect to shares of stock of detailing any differences between the
returns. For a noncorporate U.S. the CFC. See section 245A(e) and starting and ending balance of the
shareholder, enter the result on Schedule Regulations section 1.245A(e)-1(b) for extraordinary disposition account reported
1 (Form 1040), line 8n (other income - additional information about hybrid on line 8b.
section 951(a) inclusion), or on the dividends. Line 8c
comparable line of other noncorporate tax Note. The corporate U.S. shareholder Enter on line 8c the CFC’s total
returns. should include the line 5d amount on Form extraordinary disposition account balance
Line 5a 1120, Schedule C, line 14, column (a), or with respect to all U.S shareholders of the
the comparable line of other corporate CFC at the beginning of the CFC year and
Enter the amount of dividends received by at the end of the CFC tax year. Attach a
income tax returns.
the shareholder from the foreign statement detailing any differences
corporation that is eligible for a deduction Line 5e between the starting and ending balance
under section 245A. This amount does not Enter on line 5e dividends not reported on reported on line 8c.
include the amount of dividends that are line 5a, 5b, 5c, or 5d. Line 9
not eligible for a deduction under section
245A and are instead entered on lines 5b, Note. The corporate U.S. shareholder If the foreign corporation is a CFC and the
5c, and 5d. See section 245A for guidance should include the line 5e amount on Form filer is a domestic corporation, enter on
on computing the amount of a dividend 1120, Schedule C, line 14, column (a), or line 9 the sum of the hybrid deduction
eligible for a deduction. the comparable line of other corporate accounts with respect to each share of
income tax returns. stock of the CFC that the domestic
Note. The corporate U.S. shareholder corporation owns directly or indirectly
should include the line 5a amount on Form Line 6 (within the meaning of section 958(a)(2),
1120, Schedule C, line 13, column (a), or If previously taxed E&P (PTEP) were and determined by treating a domestic
the comparable line of other corporate distributed, enter the amount of foreign partnership as foreign). The reported
income tax returns. In doing so, the currency gain or (loss) recognized on the amount should reflect the balance of the
corporate U. S. shareholder must distribution, computed under section hybrid deduction accounts as of the close
determine whether it meets the statutory 986(c). See Notice 88-71, 1988-2 C.B. of the tax year of the CFC, and after all
and regulatory requirements for section 374, for rules for computing section 986(c) adjustments to the hybrid deduction
245A DRD. gain or (loss) and Regulations section accounts for the tax year (for example, to
Line 5b 1.986(c)-1(a) and (b) for rules for reflect hybrid deductions of the CFC, or
computing section 986(c) gain or (loss) hybrid dividends paid by the CFC). For
Enter the amount of the dividends recognized with respect to distributions of example, if the CFC is an upper-tier CFC
received by the shareholder from the PTEP within the reclassified section all the stock of which is owned by the filer,
foreign corporation that is an extraordinary 965(a) PTEP group and the section 965(a) then line 9 must reflect the sum of the
disposition amount. See Regulations PTEP group. Do not include any foreign filer’s hybrid deduction accounts with
section 1.245A-5(c) for rules for currency gain or loss with respect to PTEP respect to shares of stock of the upper-tier
calculating an extraordinary disposition within the reclassified section 965(b) CFC; if instead the CFC is a lower-tier
amount. PTEP group or the section 965(b) PTEP CFC all the stock of which is owned by the
filer through an upper-tier CFC, then line 9

Instructions for Form 5471 (Rev. 01-2023) -17-

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must reflect the sum of the upper-tier accrued, or distributed with respect to an respect to each share of stock of the CFC
CFC’s hybrid deduction accounts with instrument of the CFC that is stock for that the domestic corporation owns
respect to shares of stock of the lower-tier U.S. tax purposes. A hybrid deduction directly or indirectly through a partnership,
CFC. includes a deduction allowed to the CFC trust, or estate. In addition, certain
under a foreign tax law with respect to upper-tier CFCs must maintain a hybrid
A hybrid deduction account with equity (such as a notional interest deduction account with respect to each
respect to a share of stock of a CFC deduction). See Regulations section share of the stock of a lower-tier CFC that
reflects the amount of hybrid deductions of 1.245A(e)-1(d) for additional information the upper-tier CFC owns directly or
the CFC that has been allocated to the about hybrid deduction accounts. indirectly through a partnership, trust, or
share. In general, a hybrid deduction is a estate. See Regulations section
deduction or other tax benefit allowed to A domestic corporation that is a U.S. 1.245A(e)-1(d) for more on maintenance
the CFC (or a related person) under a shareholder with respect to a CFC must of hybrid deduction accounts.
foreign tax law for an amount paid, maintain a hybrid deduction account with

-18- Instructions for Form 5471 (Rev. 01-2023)

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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

Instructions for Form 5471                                 -19-

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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 lllegal 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 sections 952(b) and (c) and section 959(b). 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) 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
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
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

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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 Dividends paid to any other person with respect to your stock during 
   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

Instructions for Form 5471 (Rev. 01-2023)                   -21-

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Worksheet A Instructions                     • Property that produces the type of           Line 1i. For tax years beginning after 
                                             income reportable on line 1a;                  December 31, 2004, in the case of any 
Foreign base company income.                 • An interest in a trust, partnership, or      sale by a CFC of an interest in a 
Foreign base company income generally        REMIC; however, see the instructions for       partnership with respect to which the CFC 
does not include the following.              Line 1i for an exception that provides for     is a 25% owner (defined below), such 
• Foreign base company shipping              look-through treatment for certain sales of    CFC is treated for purposes of computing 
income as defined in former section          partnership interests; or                      its foreign personal holding company 
954(f).                                      • Property that does not produce any           income as selling the proportionate share 
• Foreign personal holding company           income.                                        of the assets of the partnership 
income derived in the active conduct of a      Do not include the following.                attributable to such interest. Thus, the sale 
banking, finance, or similar business          Income, gain, deduction, or loss from        of a partnership interest by a CFC that 
(section 954(h)).                            •
                                             any transaction (including a hedging           meets the ownership threshold constitutes 
• Exempt insurance income under              transaction) and transactions involving        subpart F income only to the extent that a 
section 953(e) and certain investment        physical settlement of a regular dealer in     proportionate sale of the underlying 
income of a qualifying insurance company     property, forward contracts, option            partnership assets attributable to the 
or a qualifying insurance branch (sections   contracts, and similar financial instruments   partnership interest would constitute 
953(a)(2) and 954(i)).                       (section 954(c)(2)(C)).                        subpart F income. Do not report these 
• Certain income derived in the ordinary       Gains and losses from the sale or            amounts on line 1b. Instead, report them 
course of business of a securities dealer    •
                                             exchange of any property that, in the          on line 1i.
(section 954(c)(2)(C)(i)).                   hands of the CFC, is property described in 
Line 1a.  Do not include:                    section 1221(a)(1).                            25% owner.  For purposes of these 
                                                                                            rules, a 25% shareholder is a CFC that 
• Interest from conducting a banking         Line 1c. Enter the excess of gains over        owns directly 25% or more of the capital or 
business that is “export financing interest” losses from transactions (including            profits interest in a partnership. For 
(section 904(d)(2)(G));                      futures, forward, and similar transactions)    purposes of the preceding sentence, if a 
• Rents and royalties from actively          in any commodities. See section 954(c)(1)      CFC is a shareholder or partner of a 
conducting a trade or business received      (C) for exceptions. See section 954(c)(5)      corporation or partnership, the CFC is 
from a person other than a “related          for a definition and special rules relating to treated as owning directly its proportionate 
person” (as defined in section 954(d)(3));   commodity transactions.                        share of any such capital or profits interest 
and
• Dividends, interest, rent, or royalty      Line 1d. Enter the excess of foreign           held directly or indirectly by such 
income from related corporate payors         currency gains over foreign currency           corporation or partnership. If a CFC is 
described in section 954(c)(3) or (6).       losses from section 988 transactions. An       treated as owning a capital or profits 
However, see section 964(e) for an           exception applies to transactions directly     interest in a partnership under 
exception to section 954(c)(3) and section   related to the business needs of a CFC.        constructive ownership rules similar to the 
                                                                                            rules of section 958(b), the CFC shall be 
964(e)(4) for an exception to section        Line 1e. Enter any income equivalent to        treated as owning such interest directly or 
954(c)(6).                                   interest, including income from                indirectly for purposes of this definition.
  Interest income includes factoring         commitment fees (or similar amounts) for 
income arising when a person acquires a      loans actually made.                           Line 10. De minimis rule. If the sum of 
trade or service receivable (directly or                                                    foreign base company income 
indirectly) from a related person. The       Line 1f. Include net income from notional      (determined without regard to section 
income is treated as interest on a loan to   principal contracts (except a contract         954(b)(5)) and gross insurance income 
the obligor under section 864(d)(1) and is   entered into to hedge inventory property).     (as defined in section 954(b)(3)(C)) for the 
generally not eligible for the de minimis,   Line 1g. Include payments in lieu of           tax year is less than the smaller of 5% of 
export financing, and related party          dividends that are made as required under      gross income for income tax purposes, or 
exceptions to the inclusion of subpart F     section 1058.                                  $1 million, then no portion of the gross 
income. Also, a trade or service receivable                                                 income for the tax year is treated as 
acquired or treated as acquired by a CFC     Line 1h. Enter amounts received:               foreign base company income or 
from a related U.S. person is considered     • Under a contract under which the             insurance income. In this case, enter zero 
an investment in U.S. property for           corporation is to furnish personal services    on line 10 and skip lines 11 through 19. 
purposes of section 956 (Worksheet B) if     if (a) some person other than the              Otherwise, go to line 11.
the obligor is a U.S. person.                corporation has a right to designate (by 
                                             name or by description) the individual who     Line 11. Full inclusion rule.   If the sum 
Note. Section 111 of the Taxpayer            is to perform the services, or (b) the         of foreign base company income 
Certainty and Disaster Tax Relief Act of     individual who is to perform the services is   (determined without regard to section 
2020 extended the look-through rule of       designated (by name or by description) in      954(b)(5)) and gross insurance income for 
section 954(c)(6). The rule now applies to   the contract; and                              the tax year exceeds 70% of gross income 
tax years of foreign corporations            • From the sale or other disposition of        for income tax purposes, the entire gross 
beginning after December 31, 2005, and       such a contract.                               income for the tax year must (subject to 
                                                                                            the high-tax exception described below, 
before January 1, 2026, and to tax years                                                    the section 952(b) exclusion, and the 
of U.S. shareholders with or within which    Note.  The above rules apply with respect 
such tax years of the foreign corporations   to amounts received for services under a       deductions to be taken into account under 
end. Continue to exclude the applicable      particular contract only if at some time       section 954(b)(5)) be treated as foreign 
types of income specified in section         during the tax year 25% or more in value       base company income or insurance 
954(c)(6) from Worksheet A, line 1a, for     of the outstanding stock of the corporation    income, whichever is appropriate. In this 
the period specified in the previous         is owned, directly or indirectly, by or for    case, enter total gross income (for income 
sentence.                                    the individual who has performed, is to        tax purposes) on line 11. Otherwise, enter 
                                             perform, or may be designated (by name         zero.
Line 1b. Enter the excess of gains over      or by description) as the one to perform,      Lines 13g, 14d, 15d, 16d, 18d, and 19d. 
losses from the sale or exchange of:         such services.                                 Exception for certain income subject 

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to high foreign taxes. Foreign base            1. Elects to treat its related person        illegal bribes, kickbacks, or other 
company income and insurance income            insurance income for the tax year as         payments (within the meaning of section 
do not include any item of income              income effectively connected with the        162(c)) paid by or on behalf of the 
received by a CFC if the taxpayer              conduct of a trade or business in the        corporation, directly or indirectly, to an 
establishes that such income was subject       United States,                               official, employee, or agent of a 
to an effective rate of income tax imposed     2. Elects to waive all treaty benefits       government.
by a foreign country that is greater than      (other than from section 884) for related    Line 22. Income described in section 
90% of the maximum rate of tax specified       person insurance income, and                 952(a)(5). The income of a CFC derived 
in section 11. For more information, see 
section 954(b)(4) and Regulations section      3. Meets any requirement the IRS             from any foreign country during any period 
1.954-1(d)(1).                                 may prescribe to ensure that any tax on      during which section 901(j) applies to such 
                                               such income is paid.                         foreign country will be deemed to be 
Line 18. Adjusted net insurance in-            This election will not be effective if the   income to the U.S. shareholders of such 
come. Insurance income is any income           corporation was a disqualified corporation   CFC. As of the date these instructions 
attributable to the issuing (or reinsuring) of (as defined in section 953(c)(3)(E)) for the were revised, section 901(j) applied to 
any insurance or annuity contract that         tax year for which the election was made     Iran, North Korea, Sudan, and Syria.
would (subject to the modifications            or for any prior tax year beginning after    Lines 24, 27, 30, and 33. Exclusion of 
provided in section 953(b)) be taxed under     1986. See section 953(c)(3)(D) for special   U.S. income.  Subpart F income does not 
subchapter L (insurance company tax) if        rules for this election.                     include any U.S. source income (which, 
such income were income of a domestic 
insurance company. However, insurance          Mutual life insurance companies.      The    for these purposes, includes all carrying 
income does not include exempt                 related person insurance income rules        charges and all interest, dividends, 
insurance income (as defined in section        also apply to mutual life insurance          royalties, and other investment income 
953(e)).                                       companies under regulations prescribed       received or accrued by a FSC) that is 
                                               by the Secretary. For these purposes,        effectively connected with a CFC's 
Line 19. Adjusted net related person           policyholders must be treated as             conduct of a trade or business in the 
insurance income.    Related person            shareholders.                                United States unless that item is exempt 
insurance income is any insurance income                                                    from taxation (or is subject to a reduced 
(within the meaning of section 953(a))         Line 20. International boycott income.       rate of tax) pursuant to a treaty obligation 
attributable to a policy of insurance or       If a CFC or a member of a controlled         of the United States or the Code.
reinsurance for which the person insured       group (within the meaning of section 
(directly or indirectly) is a U.S. shareholder 993(a)(3)) that includes the CFC has         Line 37. Current E&P limitation.          A 
(as defined in section 953(c)(1)(A)) in a      operations in, or related to, a country (or  CFC's subpart F income is limited to the 
CFC (as defined in section 953(c)(1)(B)),      with the government, a company, or a         sum of the following.
or a related person (as defined in section     national of a country) that requires         • Its current year E&P, computed under 
953(c)(6)) to such a shareholder. If a CFC     participation in or cooperation with an      the special rule of section 952(c)(1). Enter 
has related person insurance income, the       international boycott as a condition of      this amount on line 37a.
U.S. shareholder’s pro rata share is to be     doing business within such country or with   • Any tested loss under section 951A(c)
determined under the rules of section          the government, company, or national of      (2)(B)(ii). If the total of all lines 6 of all 
953(c)(5).                                     that country, a portion of the CFC's         separate Schedules I-1 (Form 5471) for 
                                               income is included in subpart F income.      the CFC is a negative number, enter the 
    Exceptions. The above definition           The amount included is determined by         amount as a positive number on line 37b. 
does not apply to any foreign corporation      multiplying the CFC's income (other than     If the total of all lines 6 is a positive 
if:                                            income included under section 951 and        number or zero, enter -0- on line 37b.
•   At all times during the foreign            U.S. source effectively connected              The amount included in the gross 
corporation's tax year, less than 20% of       business income described in section         income of a U.S. shareholder of a CFC 
the total combined voting power of all         952(b)) by the international boycott factor. under section 951(a)(1)(A) for any tax year 
classes of stock of the corporation entitled   This factor is a fraction determined on      and attributable to a qualified activity must 
to vote, and less than 20% of the total        Schedule A (Form 5713).                      be reduced by the shareholder's pro rata 
value of the corporation, is owned (directly                                                share of any qualified deficit (see section 
or indirectly under the principles of section  Special rule.  If the shareholder of a       952(c)(1)(B)).
883(c)(4)) by persons who are (directly or     CFC can clearly demonstrate that the 
indirectly) insured under any policy of        income earned for the tax year is from       Lines 39 through 43. If Worksheet A, 
insurance or reinsurance issued by the         specific operations, then, instead of        line 37c, is less than the amount on 
corporation or who are related persons to      applying the international boycott factor,   Worksheet A, line 36, allocate the subpart 
any such person;                               the addition to subpart F income is the      F income remaining (after having been 
•   The related person insurance income        amount specifically from the operations in   limited) (that is, the line 38 amount) to the 
(determined on a gross basis) of the           which there was participation in or          four categories of subpart F income listed 
corporation for the tax year is less than      cooperation with an international boycott.   on Worksheet A, lines 40 through 43, 
20% of its insurance income for the tax        See Schedule B (Form 5713).                  using the rules of Regulations section 
                                                                                            1.952-1(e).
year, or                                       Line 21. Illegal bribes, kickbacks, and 
•   The corporation:                           other payments. Enter the total of any 

Instructions for Form 5471 (Rev. 01-2023)                      -23-

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

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passive category, or section 901(j) adjustment. Instead, they should be
Instructions for Separate category. See Regulations section reported in the year to which such taxes
Schedules 1.960-1(d)(2)(ii). A foreign corporation relate. This may require an amended
may accrue or pay taxes properly return. See section 905(c), as amended
attributable to a PTEP group within any of by the Tax Cuts and Jobs Act, PL 115-97,
Schedule E the separate categories of income, with December 22, 2017, 131 Stat 2054.
Use Schedule E, Part I, to report taxes the exception of foreign branch category Adjustments include additional payments,
paid, accrued, or deemed paid under income. See Regulations section refunds, and downward adjustments for
section 960(b)(2), by a foreign corporation 1.960-3(c)(1). accrued foreign taxes that are not paid
for which a foreign tax credit is allowed If code 901j is entered on line a, enter within 2 years after the close of the tax
and use Schedule E, Part III, to report on line b the country code for the year to which such taxes relate.
taxes for which a credit may not be taken. sanctioned country using the two-letter Comparison to income tax expense re-
codes (from the list at IRS.gov/ ported on Schedule C (Form 5471).
Note. Schedule E must be completed CountryCodes). The foreign income taxes reported on
even for noncorporate U.S. shareholders. If one of the RBT codes is entered on Schedule E may differ from the amount
Certain noncorporate U.S. shareholders line a, enter on line c the country code for reported as income tax expense on
may elect under section 962 to be taxed at the treaty country using the two-letter line 21a of Schedule C. This is due in part
corporate rates on section 951(a) amounts codes (from the list at IRS.gov/ to differences in the accounting for foreign
and the GILTI inclusion for the tax year, so CountryCodes). tax redeterminations, disallowed taxes,
as to be able to claim a credit for certain and foreign income taxes reported in
foreign taxes paid or accrued by the CFC. Note. Do not complete a separate Other Comprehensive Income for U.S.
The information reported on Schedule E is Schedule E for taxes assigned to the GAAP purposes.
relevant for U.S. shareholders making this section 951A category. Taxes paid,
Comparison to income tax expense re-
election. Also, timely information reporting accrued, or deemed paid with respect to
ported on Schedule H (Form 5471).
is important to the extent the U.S. section 951A PTEP that is in the section
The taxes added or deducted on line 2g of
shareholder chooses to amend its return 951A category are reported on the
Schedule H include both foreign income
in a later year to make the election under Schedule E completed for the general
taxes reported in Part I of Schedule E as
section 962. Schedules E and E-1 are also category.
relevant for noncorporate U.S. well as the taxes reported in Part III of
shareholders who do not make a section Important. In addition to the separate Schedule E that are not creditable foreign
962 election. Taxes paid or accrued with category codes referred to above, if you income taxes.
respect to distributions of PTEP by the have more than one of the categories of Section 1—Taxes Paid or
U.S. shareholder, while not reported on income referred to above, you must
the Form 5471, are subject to different complete and file a separate Schedule E Accrued Directly by Foreign
rules regarding creditability and foreign (including Schedule E-1) using code Corporation
currency gain or loss. See, for example, "TOTAL" that aggregates all amounts Column (a)
sections 965(g) and 986(c). Therefore, it is listed for each line and column of all other
important that the U.S. shareholder track Schedules E and E-1. Amounts reported on Schedule E may
the PTEP groups to follow the different include taxes paid or accrued by the
rules for each group. Part I—Taxes for Which a
foreign corporation or a pass-through
Foreign Tax Credit Is Allowed
Name of person filing Form 5471. The entity (for example, partnership or
name of the person filing Form 5471 is In Part I, Section 1, list income, war profits, disregarded entity) owned by the foreign
generally the name of the U.S. person and excess profits taxes (income taxes) corporation. If the tax is paid or accrued by
described in the applicable category or paid or accrued to each foreign country or the pass-through entity, enter the name of
categories of filers (see Categories of U.S. possession for the foreign such entity instead of the name of the
Filers, earlier). However, in the case of a corporation’s foreign tax year(s) that end foreign corporation. If the tax paid or
consolidated return, enter the name of the with or within its U.S. tax year. accrued by the foreign corporation is
U.S. parent in the field for “Name of In Part I, Section 2, report taxes attributable to a branch or qualified
person filing Form 5471.” deemed paid under section 960(b)(2) with business unit (QBU) of the foreign
Reference ID number of foreign corpo- respect to distributions of PTEP from a corporation, enter the name of the branch
ration. If applicable, use the reference ID lower-tier foreign corporation to the foreign or QBU.
number shown on Form 5471, page 1, corporation with respect to which this
Item 1b(2). Schedule E (Form 5471) is being Column (b)
completed.
Lines a, b, and c. Complete a separate Enter the employer identification number
Schedule E for each applicable separate Amounts not reported in Part I. Do not (EIN) or reference ID number of the payor
category of income. Enter the appropriate report taxes that are not creditable, entity listed in column (a). A reference ID
code on line a (above Part I). To including taxes for which a credit is number is required only in cases in which
determine the appropriate code, see disallowed under section 245A(d), section no EIN was entered for the foreign
Categories of Income in the Instructions 901(j), (k), (l), or (m) or suspended under corporation or pass-through entity owned
for Form 1118, Foreign Tax section 909. Such taxes are reported in by the foreign corporation. Filers are
Credit—Corporations. A foreign Part III. A credit is never allowed for taxes permitted to enter both an EIN and a
corporation may need to report taxes with paid or accrued to the United States. Do reference ID number. See Item 1(b)
respect to all categories of income listed in not report such taxes in Part I, but in Part (2)—Reference ID number for more
the Instructions for Form 1118, with the III. information about reference ID numbers.
exception of foreign branch category Adjustments to foreign income taxes.
income. A foreign corporation may accrue Adjustments to foreign income taxes paid
or pay taxes properly attributable to an or accrued in a prior year should not be
income group within the general category, reflected on Schedule E in the year of

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Column (c) Columns (k) and (l) 15u of foreign source income with respect
to CFC1’s tax year ending December 31,
Check the box if the foreign income taxes Enter the exchange rate in column (k) and 2017, translated to equal $5, and on which
reported in column (j) were paid or the translated dollar amount in column (l). the original liability was $7. Therefore, the
accrued by the corporation during prior tax revised tax liability is $2. All taxes relate to
general category income. Also assume for
years and were suspended due to the Translate the taxes entered in column both years that the local currency in which
application of the rules of section 909 and (j) into dollars at the average exchange the tax was paid was the same as the
that are unsuspended in the current year rate for the tax year to which the tax foreign corporation’s functional currency.
because related income is taken into relates unless one of the exceptions below The country code for Country X is XX.
account by the foreign corporation, certain applies. See section 986(a).
U.S. corporate owners of the foreign The following entries should be made
corporation, or a member of such U.S. Exceptions. If one of the following on the 2022 Form 5471, Schedule E,
corporate owner’s consolidated group. exceptions applies, use the exchange rate General Category, Part I, Section 1, for
in effect on the date the foreign CFC1.
corporation paid the tax.
Column (d) • Line 1, column (a): CFC1
1. The tax is paid before the • Line 1, column (b): 1000123
beginning of the year to which the tax • Line 1, column (d): XX
Enter the two-letter codes (from the list at relates. • Line 1, column (e): 2022/12/31
IRS.gov/CountryCodes) of all foreign
countries and U.S. possessions to which 2. Accrued taxes are not paid before • Line 1, column (f): 2022/12/31
taxes were paid or accrued. If taxes were the date 2 years after the close of the tax • Line 1, column (g): 50u
paid or accrued to more than one country year to which such taxes relate. • Line 1, column (i): u
with respect to the same income, include 3. There is an election in effect under • Line 1, column (j): 10u
each tax paid or accrued to a different section 986(a)(1)(D) to translate foreign • Line 1, column (k): 1.0000
country on separate lines. taxes using the exchange rate in effect on • Line 1, column (l): $10
the date of payment. • Line 1, column (m): 10u
An amended 2017 tax return should be
Column (e) 4. The foreign corporation reports on
filed by or for the U.S. person(s) with
the cash basis. See section 986(a).
respect to which Form 5471 was required
The foreign tax year under foreign tax law 5. The foreign tax is denominated in and that return should include an
may not be the same tax year as the U.S. an inflationary currency. See section amended Form 5471. The amended Form
tax year of the foreign corporation. If the 986(a)(1)(C). 5471 should include an attachment with a
tax is attributable to a pass-through entity schedule that looks like the current version
owned by a foreign corporation, the Report the exchange rate using the
foreign tax year of the foreign corporation “divide-by convention” specified under of Schedule E, Part I, Section 1, with the
within which such pass-through entity’s Reporting exchange rates on Form 5471, following entries for the general category
year ends should be reported on this line. earlier. of income.
• Line 1, column (a): CFC1
Column (g) Column (m) • Line 1, column (b): 1000123
• Line 1, column (d): XX
• Line 1, column (e): 2017/12/31
Enter the income reported to the foreign Enter the tax in functional currency. E&P • Line 1, column (f): 2017/12/31
tax authority under foreign tax law. This takes into account foreign income taxes • Line 1, column (g): 15u
should be the foreign taxable income base paid or accrued by the foreign corporation. • Line 1, column (i): u
for determining the tax reported in column The foreign corporation's E&P is • Line 1, column (j): 1.20u
(j). determined in the foreign corporation's • Line 1, column (k): 1.6667
functional currency. See section 986(b). • Line 1, column (l): $2
Column (h) Line 5 • Line 1, column (m): 1.20u
Report the total of the amounts listed in Section 2—Taxes Deemed Paid
Check the box if taxes were paid on U.S. column (l) on this line 5. This total should (Section 960(b))
source income. also be reported on Schedule E-1, line 4.
The purpose of Section 2 is to track
Line 6 deemed-paid foreign income taxes with
Column (i) Report the total of the amounts listed in respect to current year PTEP distributions
column (m) on this line 6. This total and from lower-tier foreign corporations to the
Enter the three-letter currency code for the the amount reported on line 3 of foreign corporation with respect to which
local currency in which the tax is payable. Schedule E, Part III, are the appropriate this Schedule E (Form 5471) is being
Currency codes are available at www.six- reduction to current year E&P for income completed (“the foreign corporation”).
group.com/en/products-services/financial- taxes. See Schedule H, line 2g. Report a PTEP distribution by a
information/data- lower-tier foreign corporation in Section 2
standards.html#scrollTo=currency-codes. Example. CFC1, a foreign
corporation, with reference ID number only if foreign income taxes are deemed
1000123, pays or accrues tax of 10u = paid under section 960(b) by the foreign
Column (j) $10 to Country X on 50u of Country X corporation with respect to such PTEP
foreign source taxable income with distribution.
Enter the tax paid or accrued in the local respect to CFC1’s foreign tax year ending The only foreign taxes of the
currency in which tax is payable and not December 31, 2022. CFC1 has a distributing foreign corporation that may
the functional currency of the payor or December 31 tax year end for both foreign be treated as deemed paid under section
foreign corporation. See sections 986(a) and U.S. tax purposes. Also, CFC1 960(b) are foreign taxes paid, accrued, or
and 905(c). receives in the tax year ending December deemed paid by the distributing foreign
31, 2022, a refund of 3u from Country X on corporation with respect to the receipt of a

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PTEP distribution from another lower-tier    PTEP Group Classification                    Column (i)
foreign corporation below the distributing 
foreign corporation. Accordingly, there can  Taxes related to         PTEP Group Code     Enter the U.S. dollar amount of the 
be no deemed-paid foreign taxes with         previously taxed E&P                         recipient foreign corporation's income 
respect to a PTEP distribution from a        Reclassified section     R965a               taxes deemed paid that are properly 
lower-tier foreign corporation that is the   965(a) PTEP                                  attributable to the PTEP distribution 
lowest foreign-tier foreign corporation in a                                              reported in column (f) and not deemed to 
chain, and therefore no such distributions   Reclassified section     R965b
will be reported in Section 2. See           965(b) PTEP                                  have been paid by the domestic 
                                                                                          corporation for any prior tax year.
Regulations section 1.960-1(d)(3)(ii)(B).    General section 959(c)   959c1
                                             (1) PTEP 
   Any foreign income taxes paid or                                                       Note. With respect to distributions of 
accrued (but not deemed paid) by the         Reclassified section     R951A               PTEP resulting from inclusions under 
foreign corporation with respect to a PTEP   951A PTEP                                    section 965, report the taxes properly 
distribution from a lower-tier foreign       Reclassified section     R245Ad              attributable to such PTEP without 
corporation (whether or not such PTEP        245A(d) PTEP                                 reduction for the foreign tax credit 
                                                                                          disallowance.
distribution is reported in Section 2), such Section 965(a) PTEP      965a
as withholding taxes imposed on the                                                       Part III—Taxes for Which 
PTEP distribution, are reported in Section   Section 965(b) PTEP      965b
1.                                           Section 951A PTEP        951A                Foreign Tax Credit Is 
                                                                                          Disallowed
                                             Section 245A(d) PTEP     245Ad
                                                                                          Use Part III to report taxes for which 
Column (a)                                   Section 951(a)(1)(A)     951a1A              foreign tax credits are not allowed. While 
                                             PTEP 
Enter the name of each lower-tier foreign                                                 not allowed as a credit, such taxes are 
corporation that made a PTEP distribution                                                 taken into account in determining the 
                                                                                          foreign corporation’s E&P.
with respect to which a deemed-paid tax is   Column (e)
determined in the current year by the                                                     Do not enter taxes that do not meet the 
foreign corporation with respect to which                                                 criteria under Regulations section 1.901-2.
this Schedule E (Form 5471) is being         Enter the year in which the U.S. 
completed.                                   shareholder included income of the 
                                             lower-tier foreign corporation under         Columns (a) and (b)
                                             section 951(a) or section 951A and 
Column (b)                                   established the PTEP account to which        See Part I Taxes for Which a Foreign Tax 
                                             the distribution is attributed. This is the  Credit Is Allowed, earlier, for instructions 
Enter the employer identification number     annual PTEP account. See Regulations         regarding these columns.
(EIN) or reference ID number of the          section 1.960-3(c)(1).
lower-tier foreign corporation listed in 
column (a). A reference ID number is                                                      Column (c)
required only in cases in which no EIN       Column (f)
was entered for the lower-tier foreign                                                    Enter foreign income taxes that are 
corporation. Filers are permitted to enter   Enter the PTEP distribution with respect to  disallowed under section 901(j), generally 
both an EIN and a reference ID number.       the PTEP group within the annual PTEP        foreign income taxes paid or accrued to 
See Item 1b(2)—Reference ID Number for       account identified in column (d) and         certain sanctioned countries.
more information about reference ID          column (e) in the functional currency of the 
numbers.                                     distributing lower-tier foreign corporation. 
                                             If there is a PTEP distribution related to   Column (d)
                                             more than one PTEP group within an 
Column (c)                                   annual PTEP account, complete a              Enter foreign income taxes that are 
                                             separate line for each PTEP group within     disallowed under section 901(k), which 
Enter the applicable two-letter codes (from  an annual PTEP account.                      generally applies to certain taxes paid on 
the list at IRS.gov/CountryCodes).                                                        dividends if the minimum holding period is 
                                                                                          not met with respect to the underlying 
                                             Column (g)
Column (d)                                                                                stock, or if the corporation is obligated to 
                                                                                          make related payments with respect to 
Enter the code which describes the PTEP      Enter the total amount of the lower-tier     positions in similar or related property. 
group classification (as set forth in        foreign corporation’s PTEP in the PTEP       Also enter foreign income taxes 
Regulations section 1.960-3(c)(2)). Please   group within the annual PTEP account         disallowed under section 901(l), which 
enter the applicable PTEP group code         identified in column (d) and column (e).     generally applies to certain taxes paid on 
from the following list.                     Enter such amount in the functional          gain and income other than dividends if 
                                             currency of the distributing lower-tier      the minimum holding period is not met 
                                             foreign corporation.                         with respect to the underlying property, or 
                                                                                          if the corporation is obligated to make 
                                             Column (h)                                   related payments with respect to positions 
                                                                                          in similar or related property.
                                             Enter the total amount of the lower-tier 
                                             foreign corporation’s PTEP group taxes       Column (e)
                                             with respect to the PTEP group within the 
                                             annual PTEP account identified in column     In the case of a covered asset acquisition 
                                             (d) and column (e). Enter this amount in     (as defined in section 901(m)(2)), enter 
                                             U.S. dollars. To determine the appropriate   the disqualified portion of any tax 
                                             translation rate, see section 986(a).        determined with respect to the income or 

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gain attributable to the relevant foreign Columns (a), (b), and (c) Line 1b. If the balance on line 16 of prior
assets (section 901(m)). In columns (a), (b), and (c), report only the year Schedule E-1 was adjusted after the
Note. This rule generally applies to foreign income taxes the foreign filing of the original prior year Form 5471,
covered asset acquisitions after corporation pays or accrues attributable to such adjustments should be reflected on
December 31, 2010. See Regulations the subpart F income group, the tested line 1b. For example, if there were errors
sections 1.901(m)-1 through 1.901(m)-8 income group, and the residual income in the original computation of foreign
for additional information. Note that the group, respectively. Use Schedule Q to income taxes, an adjustment would be
rules contained in these regulations have determine the taxes attributable to each included on this line. See Corrections to
later effective dates. income group. Do not include foreign Form 5471, earlier. Do not include any
income taxes paid or accrued by the adjustments required to be reported on
foreign corporation in its other tax years line 7 or 12. Attach a statement that
Column (f) beginning after December 31, 2017, or includes an explanation and the dollar
that do not relate to the current tax year. amount of each such adjustment, along
Enter the amount of taxes paid or accrued Do not include foreign income taxes that with a total that equals the amount entered
by the foreign corporation to the United are disallowed and are reported on on line 1b.
States. No credit is allowed for these taxes Schedule E, Part III. Do not include taxes Line 2. Use line 2 to reflect adjustments
because only foreign income taxes paid or paid or accrued by the foreign corporation to a U.S. person’s foreign tax credit as a
accrued to a foreign country or possession with respect to its receipt of a PTEP result of redetermined foreign income
of the United States are allowed as a distribution, even if those amounts were taxes. If a U.S. person has appropriately
credit. See section 901(b). included in the total entered on line 5, amended the immediately prior year
column (l), of Schedule E, Part I, Section return, including its Schedule E-1, to
Column (g) 1. These are reported in column (e). Do redetermine its U.S. tax liability, no
not include taxes deemed paid by the adjustment should be included on this line.
foreign corporation with respect to its This line is only applicable if a U.S. person
Report foreign income taxes related to the receipt of a PTEP distribution. These are appropriately amended a prior year return
current tax year that have been also reported in column (e). and there were intervening years between
suspended due to the rules of section 909.
On line 9, report reductions for the the amended year return and the current
Column (h) portion of such taxes that are deemed year return for which an amended return
paid by a U.S. shareholder with respect to was not filed. If so, an adjustment for the
an inclusion under section 951(a) or 951A. prior year amended return (and its impact
Enter taxes for which a foreign tax credit is On line 15, report reductions for foreign on intervening years) should be reflected
disallowed other than those detailed in income taxes attributable to the column on line 2.
columns (c) through (g). Such taxes may (b) tested income group that are not Line 3a. A tax reported on Schedule E,
include, but are not limited to, taxes deemed paid as a result of the inclusion Part I, Section 1, line 5, column (l) for
attributable to section 245A(d) income, percentage or the 80% limitation. Also, on which column (c) was checked because
certain taxes on the purchase or sale of oil line 15, report any other reductions to the such tax was unsuspended in the current
and gas (section 901(f)), certain taxes three income groups in columns (a), (b), year, should be included as a positive
used to provide subsidies (section 901(i)), and (c) necessary to achieve a zero amount in column (a), (b), (c), or (e), as
and taxes for which no credit is allowed balance on line 16. Attach a statement appropriate. Such tax should also be
because of the boycott provisions of explaining why such taxes were not reflected as a negative amount in column
section 908. deemed paid under section 960. The (d).
balance of foreign income taxes paid or
Column (i) accrued with respect to the three income Line 3b. Include as a positive amount in
groups that is entered on line 16 should column (d) foreign income taxes related to
For each line in this column, enter the total equal zero after taking into account the the current tax year that have been
amount for each payor in columns (c) reductions. suspended due to the rules of section 909.
Such taxes are also reported on
through (h). Column (d) Schedule E, Part III, column (g).
Line 3 Use column (d) to report taxes suspended Line 4. The total reported on Schedule E,
Total each amount in column (i) and enter under section 909. Part I, Section 1, line 5, column (l), should
on line 3. All amounts should be in Columns (e)(i) through (e)(x) be separated into columns (a) through (e)
functional currency. according to the type of income or E&P to
Report foreign income taxes paid or which such taxes relate. Therefore, for
Line 4 accrued with respect to E&P described in example, taxes paid or accrued with
Translate the line 3 amount from functional sections 959(c)(1) and (c)(2). See respect to the receipt of a PTEP
currency to U.S. dollars using, in general, instructions for Schedule J, Column (e), distribution are reported in column (e), and
the average exchange rate as defined by for specific information about the ten taxes paid or accrued with respect to
section 989(b)(3). PTEP group columns. Also see current year subpart F income of the
Regulations section 1.960-3(c)(2) for foreign corporation are reported in column
additional information regarding the ten (a).
Schedule E-1 PTEP groups.
Use Schedule E-1 (on pages 2 and 3 of Example 1. Domestic Corporation, a
separate Schedule E) to report the Specific Instructions Related to U.S. shareholder, wholly owns the only
class of stock of CFC1, a foreign
cumulative balance of foreign income Lines 1 through 16 corporation. CFC1, in turn, wholly owns
taxes paid or accrued by a CFC by
separate category of income. Line 1a. This amount should equal the the only class of stock of CFC2, a foreign
amount that was reported as the balance corporation. CFC2, in turn, wholly owns
Enter amounts in U.S. dollars unless on line 16 of the prior year Schedule E-1. the only class of stock of CFC3, a foreign
otherwise noted. corporation. The functional currency of

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Domestic Corporation, CFC1, CFC2, and       the product of (a) such domestic             Line 12. Attach a statement with a 
CFC3 is the U.S. dollar. During Year 1,     corporation’s inclusion percentage,          description and the amount of any 
CFC 3 has subpart F income, after foreign   multiplied by, (b) the aggregate tested      required adjustments to taxes of the 
income tax, of $100 with respect to which   foreign income taxes paid or accrued by      foreign corporation not already taken into 
it pays $20 of foreign income tax. Such tax the CFC. For the computation of such         account on this schedule. An example of 
is properly attributable to subpart F       amount, see Form 1118, Schedule D.           amounts reported on line 12 is taxes 
income of CFC 3 and is reported on line 4,  Amounts reported on line 9 should be         attributable to PTEP distributions to 
column (a) of Schedule E-1 of CFC 3’s       negative numbers. See line 15 with           shareholders ineligible to claim a foreign 
Form 5471. During Year 1, Domestic          respect to reporting tested taxes not        tax credit under section 960(b)(1) (such as 
Corporation reports an inclusion under      deemed paid as a result of the inclusion     foreign corporations).
section 951(a)(1) of $100 and deemed        percentage or the application of the 80% 
paid taxes of $20 under section 960(a) as   limitation.                                  Line 15. Enter the reduction to the 
a result of subpart F income of CFC3.                                                    column (b) tested income group for tested 
                                            Line 10. A domestic corporation is 
During Year 2, CFC3 distributes $40 to                                                   income taxes not deemed paid. See 
                                            deemed to pay foreign income taxes with 
CFC2. CFC2 pays withholding tax of $4                                                    Regulations section 1.960-1. This includes 
                                            respect to distributions of previously taxed 
on the distribution from CFC3. Such tax is                                               taxes attributable to the column (b) tested 
                                            E&P. Section 960(b)(1). Amounts reported 
a tax related to previously taxed earnings                                               income group that were not deemed paid 
                                            on line 10 should be negative numbers.
and profits that were included as subpart F                                              as a result of the domestic corporation’s 
income and is reported on line 4, column       Taxes are deemed paid by a domestic       inclusion percentage or as a result of the 
(e)(x), of Schedule E 1 of CFC2’s Form ‐    corporation that is a U.S. shareholder or a  application of the 80% limit. See section 
5471.                                       foreign corporation that is a controlled     960(d). Enter the reduction to the three 
                                            foreign corporation with respect to          income groups in columns (a), (b), and (c) 
Line 5. Report taxes carried over to a      distributions of PTEP that it receives.      for other taxes not deemed paid. See 
foreign surviving corporation after an      Report on line 10, column (e), the taxes     Regulations section 1.960-1. This includes 
acquisition by a foreign corporation of the that relate to PTEP of the foreign           taxes that are properly attributable to a 
assets of another foreign corporation in a  corporation that are deemed paid by a        subpart F income group but were not 
transaction described in section 381. See   shareholder of the foreign corporation,      deemed paid because there was no 
Regulations section 1.367(b)-7(b)(1) and    either an upper-tier foreign corporation or  subpart F income with respect to that 
(d)(1).                                     a U.S. shareholder, with respect to a        income group in the current year.
Line 6. Enter foreign income taxes          distribution of PTEP made by the foreign 
properly attributable to PTEP and not       corporation.                                 Note. If necessary, enter negative 
                                                                                         amounts on line 15 of columns (a), (b), 
previously deemed paid (from                   Example 3.    The facts are the same as   and (c) in amounts sufficient to reduce 
Schedule E, Part I, Section 2, line 5,      in Example 2, except that during Year 4,     line 16, columns (a), (b), and (c), to zero. 
column (i)). The total reported on          CFC1 distributes $36 to Domestic             Attach a statement explaining why such 
Schedule E, Part I, Section 2, line 5,      Corporation. Domestic Corporation is         taxes were not deemed paid under section 
column (i) should be broken out on          deemed to pay the $4 of withholding taxes    960.
Schedule E-1, line 6, columns (e)(i)        deemed paid by CFC1 in Year 3 and paid 
through (e)(x) based on the type of PTEP    by CFC2 in Year 2. A negative $4 will be 
to which such taxes relate.                 recorded on line 10, column (e)(x), of       Schedule G-1
   Example 2.  The facts are the same as    CFC1’s Form 5471, Schedule E-1.
                                                                                         Note. A separate Schedule G-1 must be 
in Example 1, except that, in addition,        See Example 2 for reporting on line 10    filed for each cost sharing arrangement 
CFC2 distributes $36 to CFC1 in Year 3.     with respect to taxes on distributions from  (CSA) as defined in Regulations section 
CFC1 is deemed to pay the $4 of             CFC3 to CFC2.                                1.482-7(b) in which the foreign corporation 
withholding tax paid by CFC2 in Year 2. 
See section 960(b). Such tax is             Line 11. Foreign income taxes                was a controlled participant (as defined in 
attributable to previously taxed subpart F  reclassified from section 959(c)(2)          Regulations section 1.482-7(j)) during the 
income and is reported on line 6, column    previously taxed E&P to section 959(c)(1)    tax year. All amounts should be reported 
(e)(x), of Schedule E 1 of CFC1’s Form ‐    previously taxed E&P should be reported      in U.S. dollars.
5471. Such tax is also reported as a        as negative numbers in columns (e)(vi)       Name of person filing Form 5471.      The 
negative number on line 10, column (e)(x),  through (e)(x) and as positive numbers in    name of the person filing Form 5471 is 
of Schedule E 1 of CFC2’s Form 5471.‐       columns (e)(i) through (e)(v).               generally the name of the U.S. person 
Line 7. Attach a statement with a              Example 4.    The facts are the same as   described in the applicable category or 
description and the amount of any           in Example 1, except that during Year 2      categories of filers (see Categories of 
adjustments required before taking into     CFC2 invests $40 in U.S. property. At the    Filers, earlier). However, in the case of a 
account taxes deemed paid by the foreign    time of investment in such property, CFC2    consolidated return, enter the name of the 
corporation. Do not include any             continues to maintain a $36 balance in its   U.S. parent in the field for “Name of 
adjustments required to be reported on      section 959(c)(2) previously taxed E&P       person filing Form 5471.”
line 1b or 12.                              account. CFC2 reclassifies such amount       Reference ID number of foreign corpo-
                                            as section 959(c)(1) previously taxed E&P    ration. If applicable, use the reference ID 
Line 9. A domestic corporation is           on Schedule J. Accordingly, $4 of foreign    number shown on Form 5471, page 1, 
deemed to pay foreign income taxes          income taxes related to section 959(c)(2)    Item 1b(2).
attributable to inclusions under section    previously taxed E&P is reclassified to 
951(a)(1). See section 960(a). Amounts      section 959(c)(1) previously taxed E&P on    Question 4. Enter the foreign 
reported on line 9 should be negative       line 11, column (e)(iii). A negative $4 will corporation’s share of reasonably 
numbers.                                    be recorded on line 11, column (e)(x), and   anticipated benefits (RAB) for the CSA 
   If a domestic corporation includes an    a positive $4 will be recorded on line 11,   during the tax year. See Regulations 
amount in income under section 951A,        column (e)(iii).                             section 1.482-7(e) for rules on a 
such domestic corporation is deemed to                                                   determining and updating controlled 
pay foreign income taxes equal to 80% of                                                 participant’s RAB share. If the foreign 

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corporation applied more than one RAB total amount of stock-based compensation number shown on Form 5471, page 1,
share during the tax year in determining its taken into account as an IDC for the tax Item 1b(2).
share of intangible development costs year pursuant to such election. If the
Special rules for DASTM. If the foreign
(IDCs), enter the RAB share that was taxpayer attaches the statement
corporation uses DASTM, enter on line 1
applied to IDCs incurred at the end of the described in the previous sentence, then
the dollar GAAP income or (loss) from
year. See Regulations section 1.482-7(d) in the entry space provided for line 6b the
line 22 of Schedule C. Enter on lines 2a
for more information on IDCs. taxpayer should include the total amount
through 4 the adjustments made in
of stock-based compensation taken into
Question 5a. Check the “Yes” box if the figuring current E&P for U.S. tax purposes.
account as an IDC, including stock-based
U.S. taxpayer made any platform Report these amounts in U.S. dollars.
compensation pursuant to the election
contributions as defined in Regulations Enter on line 5b the DASTM gain or loss
described above and any not subject to
section 1.482-7(c) to the CSA during the figured under Regulations section
such election.
tax year. If “Yes,” complete lines 5b and 1.985-3(d).
5c. Check the appropriate box on line 6c to
indicate whether any stock-based Lines 2a through 2i. Certain
Questions 5b and 5c. Enter the foreign compensation was granted during the adjustments (required by Regulations
corporation's RAB share of the total term of the CSA to individuals who sections 1.964-1(b) and (c)) must be
present value of all platform contributions performed functions in business activities made to the foreign corporation's line 1 net
made by the U.S. taxpayer during the tax that generate cost shared intangibles that book income or (loss) to determine its
year with respect to the foreign were not treated as directly identified with, current E&P. These adjustments may
corporation on line 5b. The total present or reasonably allocable to, the IDA as include both positive and negative
value of all platform contributions made by defined in Regulations section 1.482-7(d) adjustments to conform the foreign book
the U.S. taxpayer during the tax year (1)(i). This would include stock-based income to U.S. GAAP and to U.S. tax
should be entered even if only a portion compensation granted in earlier years accounting principles. If the foreign
(or none) of the value of those platform (which could give rise to deductions in the corporation's books are maintained in
contributions was included in the U.S. current tax year) that were not treated as functional currency in accordance with
taxpayer's taxable income as platform identified with or reasonably allocable to U.S. GAAP, enter on line 1 the functional
contribution transaction (PCT) payments the IDA. currency GAAP income or (loss) from
during the tax year. If possible, include a line 22 of Schedule C, rather than starting
reasonable present value estimate for any Questions 7a and 7b. For the tax year, with foreign book income, and show
PCTs that are priced using a method that enter the total amount of IDCs for the CSA GAAP-to-tax adjustments on lines 2a
does not involve the calculation of a on line 7a. See Regulations section through 2i.
present value. Otherwise, attach a brief 1.482-7(d) for more information on IDCs.
Lines 2b and 2c. Generally,
statement of the reason(s) it is not On line 7b, enter the amount of IDCs depreciation, depletion, and amortization
possible to include a present value allocated to the foreign corporation for the allowances must be based on the
estimate for one or more PCTs (for tax year based on the foreign historical cost of the underlying asset, and
example, no revenue projections for a corporation’s RAB share. depreciation must be figured according to
PCT that is priced based on a sales-based
section 167. However, if 20% or more of
royalty from a comparable uncontrolled
the foreign corporation's gross income is
transaction). Schedule H from U.S. sources, depreciation must be
If the U.S. taxpayer engaged in multiple Use Schedule H to report the foreign figured on a straight line basis according
PCTs during the tax year with the foreign corporation's current E&P for U.S. tax to Regulations section 1.312-15.
corporation and used different methods to purposes. Enter the amounts on lines 1
price the PCTs, check the appropriate through 5c in the CFC's functional Line 2f. Inventories must be taken into
boxes on line 5c to indicate which currency. account according to the rules of
sections 471 (incorporating the provisions
methods were selected as the best Certain filers may be able to use of section 263A) and 472 and the related
method for one or more of the PCTs alternative information (as defined in regulations.
reported in the tax year. See Regulations section 3.01 of Rev. Proc. 2019-40) to
section 1.482-7(g) for more information on determine certain amounts in this Line 2g. See the instructions for
the methods applicable to PCTs. schedule. See specific instructions for Schedule C, Line 21, earlier. Reflect
Questions 6b and 6c. See generally Item F—Alternative Information Under differences between the income tax
Regulations section 1.482-7 for more Rev. Proc. 2019-40, earlier, for more expense (benefit) reported for book
information on determining whether details. purposes and the income taxes deducted
stock-based compensation is directly or added to E&P. Such differences
identified with, or reasonably allocable to, Note. Category 5b and 5c filers are not include, for example, deferred income tax
the intangible development activity (IDA) required to file Schedule H for expenses, uncertain tax positions,
under the CSA. See Regulations section foreign-controlled CFCs. intraperiod allocations, adjustments made
after closing the financial statements
1.482-7(d)(3) and Notice 2005-99 for Name of person filing Form 5471. The (post-closing adjustments) and not
more information on determining the name of the person filing Form 5471 is reflected in income tax expense (benefit),
measurement and timing of stock-based generally the name of the U.S. person and the adjustment for a foreign tax
compensation IDCs, including an election described in the applicable category or redetermination that required a
available with respect to options on categories of filers (see Categories of redetermination of the U.S. tax liability.
publicly traded stock and certain other Filers, earlier). However, in the case of a
stock-based compensation. If the taxpayer consolidated return, enter the name of the Line 2h. Enter the adjustment to foreign
made the election described in U.S. parent in the field for “Name of currency gains or losses. Attach a
Regulations section 1.482-7(d)(3)(iii)(B) or person filing Form 5471.” statement with a description of the gain or
Notice 2005-99, the taxpayer should losses.
attach a statement to Form 5471 Reference ID number of foreign corpo-
explaining that the taxpayer made such ration. If applicable, use the reference ID In the case of section 988 losses,
determine whether Form 8886 needs to be
election and include in such statement the

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completed, as described in Additional Line 5d. Enter the line 5c functional line 6 must include the code for passive
Filing Requirements, earlier. currency amount translated into U.S. category income (PAS) in the entry space
Line 2i. Enter the net amount of any dollars at the average exchange rate for for separate category (at the top of
additional adjustments not included on the foreign corporation's tax year. See Schedule I-1). This is the case even if the
lines 2a through 2h. List these additional section 989(b). Report the exchange rate Schedule I-1 also includes general
adjustments on a separate statement. using the “divide-by convention” specified category income. With respect to a
Attach this statement to Form 5471. under Reporting Exchange Rates on Form taxpayer completing Schedule I-1 with
Schedule H is only prepared for the 5471, earlier. If the foreign corporation respect to a foreign corporation with only
general, passive, and section 901(j) uses DASTM, enter on line 5d the same general category income (and no passive
categories of income. For example, if U.S. amount entered on line 5c. category income) on line 6, the taxpayer
should enter the code “GEN” in the entry
GAAP income reported on Schedule C Line 5e. Enter the exchange rate used in space for separate category.
contains items related to PTEP, include computing line 5d. Report the exchange
the necessary adjustments on line 2i of rate using the "divide-by convention" Note. The other reporting requirements of
Schedule H for the appropriate category of specified under Reporting Exchange a taxpayer that includes passive category
income (general or passive) and attach a Rates on Form 5471. income with general category income in a
statement that itemizes and explains Schedule I-1 do not change because the
those adjustments. Report adjustments for Blocked income. The E&P of the foreign
foreign taxes related to the PTEP on corporation, as reflected on Schedule H, taxpayer includes passive category
line 2g. This adjustment is necessary must not be reduced by all or any part of income with general category income in a
because foreign taxes imposed on PTEP such E&P that could not have been Schedule I-1. For example, the taxpayer
distributions do not reduce current year distributed by the foreign corporation due may still be required to complete a Form
E&P. Foreign taxes imposed on PTEP to currency or other restrictions or 1116 or a Form 1118, and/or a Form 5471
distributions reduce PTEP and are limitations imposed under the laws of any (including Schedule J and Schedule P),
reported on Schedule J, line 6. foreign country. and separately report passive category
income and section 951A category
Example. Domestic Corporation, a income.
U.S. shareholder, wholly owns the only Schedule I-1 Line 1. Enter the CFC’s gross income.
class of stock of CFC1, a foreign This schedule is used to report information The amount of gross income entered on
corporation. CFC1, in turn, wholly owns determined at the CFC level with respect line 1 will generally be a positive amount.
the only class of stock of CFC2, a foreign to amounts used in the determination of However, if a CFC’s cost of goods sold
corporation. During Year 1, Domestic income inclusions by U.S. shareholders exceeds its gross receipts, a negative
Corporation reports an inclusion under under section 951A. The information in amount is permitted on line 1.
section 951(a)(1) of $100 as a result of this schedule will be used by the U.S.
subpart F income of CFC2. During Year 2, shareholder(s) of the CFC to file Form Line 2. Enter the CFC’s exclusions as
CFC2 distributes $40 to CFC1. CFC1 8992, U.S. Shareholder Calculation of described in Regulations section
pays withholding tax of $4 on the Global Intangible Low-Taxed Income 1.951A-2(c).
distribution from CFC2. Such tax is related (GILTI), and may assist in the completion Line 2a. Enter the amount of the
to previously taxed subpart F income. On of Form 1118, or Form 1116, if applicable. CFC’s income or loss described in section
Domestic Corporation’s financial
statements, Domestic Corporation reports Enter the amounts on lines 1 through 952(b), which is generally income or loss
the $4 withholding tax as current income 10c in the CFC's functional currency. The from sources within the United States that
tax expense. Domestic Corporation functional currency amounts entered on is effectively connected to the conduct of a
reports on CFC1’s Form 5471, lines 6 through 10c must be converted to trade or business by the CFC in the United
Schedule H, on line 2g, a positive U.S. dollars. States and not reduced or exempt from
tax pursuant to an income tax treaty with
adjustment for the $4 of tax on the PTEP Certain filers may be able to use the United States.
distribution. alternative information (as defined in
Line 5b. DASTM gain or (loss), reflecting section 3.01 of Rev. Proc. 2019-40) to Line 2b. Enter the amount, if any, of
unrealized exchange gain or loss, should determine certain amounts in this the CFC’s gross income or loss taken into
be entered on line 5b only for foreign schedule. See specific instructions for account in determining the CFC’s subpart
corporations that use DASTM. Item F—Alternative Information Under F income (as defined in section 952). Note
Rev. Proc. 2019-40, earlier, for more that an amount determined under section
Line 5c. The line 5c current year E&P details. 956(a) is not considered subpart F
amount may include amounts with respect income. The amount to be entered is
to the general category, passive category, Name of person filing Form 5471. The computed after application of the high-tax
or section 901(j) category. See name of the person filing Form 5471 is exception in section 954(b)(4), but before
Regulations section 1.960 1(d)(2). Enter ‐ generally the name of the U.S. person application of the E&P limitation in section
on lines 5c(i), 5c(ii), 5c(iii)(A), 5c(iii)(B), described in the applicable category or 952(c)(1)(A).
5c(iii)(C), and 5c(iii)(D), as applicable, the categories of filers (see Categories of
portion of the line 5c current year E&P Filers, earlier). However, in the case of a Line 2c. Enter the amount, if any, of
amount with respect to each applicable consolidated return, enter the name of the the CFC’s gross income excluded from
category of income. If applicable for lines U.S. parent in the field for “Name of foreign base company income (as defined
5c(iii)(A), 5c(iii)(B), 5c(iii)(C), and 5c(iii) person filing Form 5471.” in section 954) and insurance income (as
(D), also enter the country code for the Separate category. Schedule I-1 is now defined in section 953) by reason of
sanctioned country using the two-letter completed once. (It is no longer section 954(b)(4), the high-tax exception
codes (from the list at IRS.gov/ completed separately for each applicable (include amounts excluded from tested
CountryCodes). category of income.) Therefore, income under Regulations section
Schedule I-1 is completed once (for 1.951A-2(c)(7)).
Note. The amounts reported on line 5c general category income, passive Line 2d. Enter the amount of any
include both foreign source and U.S. category income, or both). A Schedule I-1 dividend income received by the CFC
source income. that includes passive category income on

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from a related person as defined in section (defined below). This amount must be instructions for Line 6 for foreign currency
954(d)(3). Do not include the amounts of converted from functional currency to U.S. translation.
any dividend income received from a dollars using the average exchange rate
related person that are already included in for the year of the CFC. See Regulations Line 9b. Enter the CFC’s qualified
the amounts entered on line 2b or line 2c. section 1.951A-1(d)(1). interest expense, as defined in
Regulations section 1.951A 4(b)(1)(iii).‐
Line 2e. Enter the amount of the Qualified business asset
CFC’s taxable income or loss from investment (QBAI). QBAI is the average Line 9c. Enter the CFC’s tested loss
sources outside the United States and its of the CFC's aggregate adjusted bases, QBAI amount, as defined in Regulations
possessions from the following. as of the close of each quarter of its section 1.951A 4(b)(1)(iv).‐
• The extraction (by the corporation or taxable year, in specified tangible property Line 9d. Subtract the sum of line 9b
any other person) of minerals from oil or used in its trade or business in the and line 9c from line 9a and enter the
gas wells located outside the United production of tested income, and for which result on line 9d.
States and its possessions. a deduction is allowable under section
• The sale or exchange of assets used 167. Adjusted basis in any property must Lines 10a through 10c. In general, see
(by the corporation) in the trade or be determined by using the alternative Regulations section 1.951A 4(b)(2) to ‐
business of extracting minerals from oil or depreciation system under section 168(g) determine how to compute the CFC’s
gas wells located outside the United and allocating depreciation deductions tested interest income.
States and its possessions. with respect to such property ratably to Line 10a. Enter the amount of interest
each day during the period in the taxable
Line 3. Combine lines 2a through 2e. The income included on line 4. See the
year to which such depreciation relates.
line 3 result can be positive or negative. instructions for Line 6 for foreign currency
Line 4. Subtract line 3 from line 1 and Specified tangible property and translation.
enter the result on line 4. The line 4 result dual-use property. Specified tangible Line 10b. Enter the CFC’s qualified
can be positive or negative. For example: property means any tangible property interest income, as defined in Regulations
used in the production of tested income. If section 1.951A 4(b)(2)(iii).‐
such property was used in the production
Line 1 of tested income and income that is not Line 10c. Subtract line 10b from
gross line 10a and enter the result on line 10c.
income $1,000 $1,000 $(1,000) $(1,000) tested income (that is, dual-use property),
the property is treated as specified
Line 3 total tangible property in the same proportion
exclusions 800 (800) 800 (800) that the amount of tested income Schedule J
Line 4 determined before allocable deductions Use Schedule J to report a CFC’s
(line 1 (that is, line 4) produced with respect to accumulated E&P in its functional
minus the property bears to the total amount of currency, computed under sections 964(a)
line 3) $200 $1,800 $(1,800) $(200) gross income produced with respect to the and 986(b). Also use this schedule to
property. report the E&P of specified foreign
corporations that are only treated as CFCs
Partnership property. A CFC with for limited purposes under section 965(e)
Line 5. Enter the deductions (including tested income that is a partner of a (2).
taxes) properly allocable to the amount on partnership that has depreciable tangible
line 4 (or to which such deductions would property determines its share of the Note. Category 1b, 1c, 5b, and 5c filers
be allocable if there were such gross partnership’s average adjusted basis in are not required to file Schedule J for
income). See section 951A(c)(2)(A)(ii) and the depreciable tangible property of the foreign-controlled section 965 SFCs or
Regulations section 1.951A-2(c)(3). partnership based on the amount of the foreign-controlled CFCs.
Line 6. Subtract line 5 from line 4 and distributive share of the gross income
enter the result on line 6. The line 6 result produced by the property that is included Name of person filing Form 5471. The
can be positive or negative. See the line 4 in the CFC’s gross tested income (defined name of the person filing Form 5471 is
instructions above for examples. This below) relative to the total amount of gross generally the name of the U.S. person
amount must be converted from functional income produced by the property. The described in the applicable category or
currency to U.S. dollars using the average partnership’s average adjusted basis in categories of filers (see Categories of
exchange rate for the year of the CFC. the depreciable tangible property of the Filers, earlier). However, in the case of a
See Regulations section 1.951A-1(d)(1). partnership is generally determined based consolidated return, enter the name of the
Report the exchange rate using the on the average of the adjusted basis in the U.S. parent in the field for “Name of
“divide-by convention” specified under property as of the close of each quarter of person filing Form 5471.”
Reporting exchange rates on Form 5471, the partnership’s tax year that ends with or Reference ID number of foreign corpo-
earlier. within the CFC’s tax year. See ration. If applicable, use the reference ID
Regulations section 1.951A-3(g). number shown on Form 5471, page 1,
Line 7. If the CFC has a tested loss on Item 1b(2).
line 6, enter zero. If the CFC has tested Gross tested income. For these
income on line 6, enter only those foreign purposes, a CFC’s gross tested income is Lines a and b. Complete a separate
income taxes that are properly attributable its gross income less total exclusions Schedule J for each applicable separate
to the CFC’s tested income group. This (Schedule I 1, line 4).‐ category of income. Enter the appropriate
amount must be converted from functional Lines 9a through 9d. In general, see code on line a (at the top of page 1 of
currency to U.S. dollars using the average Regulations section 1.951A 4(b)(1) to ‐ Schedule J). To determine the appropriate
exchange rate for the year of the CFC. determine how to compute the CFC’s code, see Categories of Income in the
See section 986. tested interest expense. Instructions for Form 1118. A foreign
corporation may need to report E&P with
Line 8. If the CFC has a tested loss on Line 9a. Enter the amount of interest respect to all categories of income listed in
line 6, enter zero. If the CFC has tested expense included on line 5. See the the Instructions for Form 1118, except
income on line 6, enter the Qualified foreign branch category income. A foreign
Business Asset Investment (QBAI)

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corporation may have E&P in an income        Columns (a), (b), and (c)                      1. PTEP attributable to, or reclassified 
group within the general category, passive   Report the opening balance, current year     as, investments in U.S. property (section 
category, or section 901(j) category. See    additions and subtractions, and the          959(c)(1)(A) amounts).
Regulations section 1.960 1(d)(2)(ii). A ‐   closing balance in the foreign                 2. PTEP attributable to subpart F 
foreign corporation may have PTEP in a       corporation's E&P described in section       income inclusions (not described in any 
PTEP group within any of the separate        959(c)(3). In general, this is E&P of the    other column) and reclassified as 
categories of income, except foreign         foreign corporation that has not been        investments in U.S. property.
branch category income. See Regulations      included in gross income of a U.S. person      3. PTEP attributable to inclusions 
section 1.960 3(c)(1).‐                      under section 951(a)(1) and section 951A.    under previous section 951(a)(1)(C) and 
If code 901j is entered on line a, enter                                                  subpart F income inclusions reclassified 
on line b the country code for the             In column (a), report E&P described in 
sanctioned country using the two-letter      section 959(c)(3) and earned after the       as investments in excess passive assets.
codes (from the list at IRS.gov/             repeal of section 902, that is, post-2017    • Column (e)(iv) is PTEP originally 
CountryCodes).                               E&P not previously taxed (post-2017          attributable to inclusions under section 
                                             section 959(c)(3) balance). The repeal of    951A and reclassified as investments in 
Note. A separate Schedule J should not       section 902 is effective for tax years of    U.S. property (section 959(c)(1)(A) 
be completed for the section 951A            foreign corporations beginning after         amounts).
category. Reclassified section 951A PTEP     December 31, 2017, and to tax years of       • Column (e)(v) is PTEP described in the 
and section 951A PTEP that is in the         U.S. shareholders in which or with which     following three subgroups (which are 
section 951A category should be reported     such tax years of foreign corporations       aggregated into a single PTEP group).
on the general category Schedule J.          end.                                           1. PTEP attributable to hybrid 
                                                                                          dividends under section 245A(e)(2) and 
Note. For purposes of this Schedule J,         In column (b), report post-1986            reclassified as investments in U.S. 
include in each separate category of         undistributed earnings, as defined under     property.
income, foreign source and U.S. source       section 902(c)(1), and as in effect prior to 
income.                                      the repeal of section 902.                     2. PTEP attributable to section 1248 
                                                                                          amounts under section 959(e) and 
Important. In addition to the separate         Use column (c) to report the aggregate     reclassified as investments in U.S. 
category codes referred to above, if you     amount of the foreign corporation's          property.
have more than one of the categories of      pre-1987 section 964(a) E&P accumulated        3. PTEP attributable to section 1248 
income referred to above, you must           since 1962 and not previously distributed    amounts from the gain on the sale of 
complete and file a separate Schedule J      or deemed distributed. These amounts are     foreign corporation stock by a CFC and 
using code “TOTAL” that aggregates all       figured in U.S. dollars using the rules of   reclassified as investments in U.S. 
amounts listed for each line and column in   Regulations section 1.964-1(a) through       property.
Part I of all other Schedules J.             (d), and translated into the foreign         • Column (e)(vi) is PTEP attributable to 
                                             corporation's functional currency            section 965(a) inclusions (section 959(c)
Part I—Accumulated E&P of                    according to Notice 88-70, 1988-2 C.B.       (2) amounts). Do not include in column (e)
Controlled Foreign Corporation               369.                                         (vi) E&P reported in column (e)(vii).
Check the box at the top of Part I if the    Column (d)                                   • Column (e)(vii) is E&P treated as PTEP 
                                                                                          under section 965(b)(4)(A) (section 959(c)
person filing Form 5471 does not have all    Use column (d) to report hovering deficits   (2) amounts).
U.S. shareholders’ information necessary     (see section 381(c)(2)(B) and Regulations    • Column (e)(viii) is PTEP attributable to 
to complete any one of the previously        section 1.367(b)-7) and suspended taxes      section 951A inclusions (section 959(c)(2) 
taxed E&P amounts required to be             (see section 909). See Specific              amounts).
included in column (e). If the person filing instructions related to lines 1 through 13,  • Column (e)(ix) is PTEP described in the 
Form 5471 is unable to determine whether     below, for additional information pertaining following three subgroups (which are 
amounts should be reported as previously     to reporting amounts in column (d).          aggregated into a single PTEP group).
taxed E&P, those amounts should be 
included in column (a), Post-2017 E&P        Column (e)                                     1. PTEP attributable to hybrid 
Not Previously Taxed, section 959(c)(3)      Use column (e) to report the running         dividends under section 245A(e)(2).
balance. For example, one U.S.               balance of the foreign corporation's PTEP,     2. PTEP attributable to section 1248 
shareholder might not know the amount of     section 964(a) E&P accumulated since         amounts under section 959(e).
the other U.S. shareholder’s section 951A    1962 that have resulted in deemed              3. PTEP attributable to section 1248 
inclusion that is allocated to the CFC       inclusions under subpart F, or amounts       amounts from the gain on the sale of a 
because the first U.S. shareholder does      treated as PTEP under section 965(b)(4)      foreign corporation stock by a CFC.
not have information with respect to the     (A). Pre-1987 U.S. dollar PTEP should be     • Column (x) is PTEP attributable to 
second U.S. shareholder’s net CFC tested     translated into the foreign corporation's    section 951(a)(1)(A) inclusions (section 
income or pro rata share of QBAI. See the    functional currency using the rules of       959(c)(2) amounts) not otherwise 
instructions for Schedule P for an           Notice 88-70 and added to post-1986          described in the instructions for columns 
example.                                     amounts in the appropriate PTEP group.       (e)(vi) through (ix).
Enter the amounts in this schedule in        • Columns (e)(i) and (e)(ii) are PTEP 
the functional currency of the foreign       originally attributable to inclusions under    Schedule J reports PTEP by subgroups 
corporation as reported on Form 5471,        section 965(a) and E&P treated as PTEP       because those groups may be subject to 
page 1, Item 1h Functional Currency. If the  under section 965(b)(4)(A), respectively,    different rules under sections 960, 965(g), 
foreign corporation is the owner of a        and reclassified as investments in U.S.      245A(e)(3), and 986(c). The different rules 
qualified business unit(s) (QBU) with a      property (section 959(c)(1)(A) amounts).     are applicable for individuals, as well as 
different functional currency, translate the • Column (e)(iii) is PTEP described in the   corporations, estates, and trusts. For 
E&P of the QBU(s) to the foreign             following three subgroups (which are         example, an individual U.S. shareholder 
corporation’s functional currency.           aggregated into a single PTEP group).        who receives a distribution of PTEP 
                                                                                          originally attributable to inclusions under 
                                                                                          section 965(a) may only claim a credit for 

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a portion of the foreign taxes attributable   numbers on line 2a of column (a), (b), (c),    receipt of a distribution of PTEP from a 
to a distribution of such PTEP. See section   or (e), as applicable.                         lower tier foreign corporation.‐
965(g) and Regulations section 1.965-5 
                                              Line 2b. This line of column (d) accounts 
for more information. This is the case for                                                   Example.     Domestic Corporation, a 
                                              for foreign income taxes that are 
both direct foreign tax credits (that is,                                                    U.S. shareholder, wholly owns the only 
                                              suspended in the current tax year. Report 
those foreign taxes paid or accrued                                                          class of stock of CFC1, a foreign 
                                              such amounts as negative numbers.
directly by the shareholder upon receipt of                                                  corporation. CFC1, in turn, wholly owns 
the PTEP distribution and allowed as a        Line 3. Enter the current year E&P (or         the only class of stock of CFC2, a foreign 
credit under sections 901 or 903) and         deficit in E&P) amount from the applicable     corporation. CFC2, in turn, wholly owns 
indirect foreign tax credits (that is, those  line 5c of Schedule H (Form 5471). For         the only class of stock of CFC3, a foreign 
taxes deemed paid by the shareholder          example, if you are completing Schedule J      corporation. The functional currency of 
with respect to taxes originally paid or      for the passive category (that is, you have    Domestic Corporation, CFC1, CFC2, and 
accrued by the CFC under section              entered "PAS" on line a at the top of          CFC3 is the U.S. dollar. During Year 1, 
960(b)). With respect to direct credits, this page 1 of Schedule J), enter the current       Domestic Corporation reports an inclusion 
reduction applies regardless of whether       year E&P (or deficit in E&P) amount from       under section 951(a)(1) of $100 as a result 
such individual made an election under        Schedule H (Form 5471), line 5c(ii), in the    of subpart F income of CFC3. During Year 
section 962. Therefore, the reporting on      applicable column. Line 3 should never         2, CFC3 distributes $40 to CFC2. CFC2 
Schedule J is necessary regardless of         have an amount entered in column (e).          pays withholding tax of $4 on the 
                                                                                             distribution from CFC3. Such tax is related 
whether the U.S. shareholder made a           Line 4. Report as a positive number E&P        to previously taxed subpart F income. 
section 962 election.                         attributable to distributions of PTEP from     Domestic Corporation reports on CFC2’s 
Column (f)                                    lower-tier foreign corporations. Generally,    Form 5471, Schedule J, line 4, column (e)
Use column (f) to report the opening and      the E&P of a CFC attributable to amounts       (x), as a positive number, the $40 PTEP 
closing balance of the foreign                that are, or have been, included in the        distribution. Domestic Corporation reports 
corporation's accumulated E&P. This           gross income of a U.S. shareholder under       on line 6, column (e)(x), as a negative 
amount is the sum of post-2017 E&P not        section 951(a) are not, when distributed       number, the $4 of tax on the PTEP 
previously taxed, post-1986 undistributed     through a chain of ownership described in      distribution.
earnings, pre-1987 E&P not previously         section 958(a), also included in the gross 
taxed, and PTEP. Do not include column        income of another CFC in such chain for        Line 7. Enter on line 7 E&P as of the 
(d) amounts in the total reported in column   purposes of the application of section         close of the tax year before actual 
(f).                                          951(a) to such other CFC with respect to       distributions or inclusions under section 
                                              such U.S. shareholder. See section             951(a)(1) or section 951A during the year.
Specific Instructions Related to              959(b).                                        Line 8. Enter amounts included in gross 
Lines 1 Through 13                            Line 5a. Enter earnings carried over to a      income of the U.S. shareholder(s) under 
Line 1a. Enter the balances for each          foreign surviving corporation after an         section 951(a)(1)(A) or section 951A with 
column at the beginning of the tax year.      acquisition by a foreign corporation of the    respect to the CFC. Report the inclusion 
These balances should equal the amounts       assets of another foreign corporation in a     as a negative amount in columns (a) 
reported as the ending balances in the        transaction described in section 381. See      through (c), as applicable. Report the 
prior year Schedule J.                        Regulations section 1.367(b)-7. The            inclusion as a positive amount in columns 
                                              amounts entered on line 5a may be              (e)(vi) through (e)(x), as applicable. 
Line 1b. If there is a difference between     negative or positive. Negative amounts         Amounts reported as positive numbers on 
last year’s ending balance on Schedule J      are hovering deficits reported in column       line 8 of column (e)(viii) should only be 
and the amount that should be last year’s     (d) of line 5a.                                reported with respect to negative amounts 
ending balance, taking into account                                                          on line 8 of column (a). The negative 
modifications in Schedule J, include the      Line 5b. If the foreign surviving              amounts could be reported on a different 
difference on line 1b and attach an           corporation had a deficit in E&P prior to a    Schedule J than the positive amounts if 
explanation for the difference. If there are  transaction described in section 381, such     such amounts are reclassified from one 
multiple reasons for differences, include     deficit is recharacterized as a hovering       separate category to another separate 
the explanation and amount of each such       deficit after such nonrecognition              category.
difference on the attachment. Do not          transaction. See section 381(c)(2)(B) and 
include adjustments required to be            Regulations sections 1.367(b)-7(d)(2)(i)       Note. Section 951(a)(1)(A) inclusions are 
reported on line 6 or 12.                     (post-1986 undistributed earnings) and         taken into account for the tax year before 
                                              1.367(b)-7(e)(1) (pre-1987 E&P not             actual distributions and section 951(a)(1)
Lines 1a through 1c.   These lines of         previously taxed). An amount equal to the      (B) inclusions. See section 959(a).
column (d) account for the balance of prior   deficit reported in column (a), (b), or (c) of 
year hovering deficits and suspended          line 5a is included as a positive amount on    Note. The amount included in gross 
taxes that have not yet been deducted.        line 5b of column (a), (b), or (c),            income of U.S. shareholders of the CFC 
Such amounts are reported as negative         respectively. An amount equal to the total     under section 951A might not be known if 
numbers.                                      hovering deficits reported on line 5b of       there is more than one U.S. shareholder. 
Line 2a. This line of column (d) is the       columns (a), (b), and (c) is included as a     In that case, see the example in the 
unsuspended taxes under section 909 as        negative number in column (d) of line 5b.      instructions for Schedule P for reporting 
                                                                                             information.
a result of related income taken into         Line 6. Attach a statement detailing the 
account by the foreign corporation, certain   nature and amount of any adjustments not       Note. The amount reported on line 8 will 
U.S. corporate owners of the foreign          accounted for in the E&P determined            not necessarily equal the tested income 
corporation, or a member of such U.S.         before reduction for distributions and         reported on Schedule I-1. For an example 
corporate owner’s consolidated group.         inclusions (that is, adjustments other than    of when this might occur, see Regulations 
Report the unsuspended taxes on line 2a       those listed on lines 2a through 5b). Do       section 1.951A-5(b)(2)(ii).
of column (d) as a positive number. Report    not include amounts reported on line 1b. 
the unsuspended taxes as negative             An example of an adjustment entered on         Line 9. Report actual distributions as 
                                              Line 6 is the foreign taxes imposed on         negative numbers.

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Note. Actual distributions are taken into    989(b). Report the exchange rate in the       If an amount is entered on line 14, you 
account for the tax year before section      entry space provided at the top of            must attach a statement that includes the 
951(a)(1)(B) inclusions. See section 959(f)  Schedule M using the “divide-by               following information. Column (a) of the 
(2). An actual distribution is first out of  convention” specified under Reporting         attached statement should provide a 
PTEP, if any, and then out of the section    exchange rates on Form 5471, earlier.         description of the type of other amounts 
959(c)(3) balance. See section 959(c).                                                     received during the annual accounting 
                                             Name of person filing Form 5471.        The 
                                                                                           period. Columns (b) through (f) should 
Note. The total of all amounts entered in    name of the person filing Form 5471 is 
                                                                                           request dollar amounts of the specified 
Schedule R (Form 5471), column (d) must      generally the name of the U.S. person 
                                                                                           other amounts received during the annual 
equal the amount on line 9, column (f) of    described in the applicable category or 
                                                                                           accounting period by the foreign 
the Schedule J (Form 5471) that is filed     categories of filers (see Categories of 
                                                                                           corporation from the persons listed in the 
with code “TOTAL” entered on line a of       Filers, earlier). However, in the case of a 
                                                                                           headings for columns (b) through (f). 
that Schedule J.                             consolidated return, enter the name of the 
                                                                                           These headings must comport to those 
                                             U.S. parent in the field for “Name of 
                                                                                           used on the Schedule M (Form 5471) to 
Line 10. Use line 10 to report               person filing Form 5471.”
reclassifications of section 959(c)(2) PTEP                                                which this statement is attached. The 
in columns (e)(vi) through (e)(x) to section Reference ID number of foreign corpo-         attached statement must include a “totals” 
959(c)(1) PTEP in columns (e)(i) through     ration. Use the reference ID number           line that ties into the amounts reported in 
(e)(v). A potential section 951(a)(1)(B)     shown on Form 5471, line 1b(2).               each column of line 14.
inclusion results in a reclassification of   Lines 4 and 19.  Report on these lines        If an amount is entered on line 29, you 
section 959(c)(2) PTEP, if any, to section   platform contribution transaction             must attach a statement that includes the 
959(c)(1) PTEP before reclassification out   payments received and paid by the foreign     following information. Column (a) of the 
of the section 959(c)(3) E&P balance. See    corporation (without giving effect to any     attached statement should provide a 
section 959(a)(2) and (f)(1). The amounts    netting of payments). See Regulations         description of the type of other amount 
reclassified are reported as negative        section 1.482-7(b)(1)(ii). The corporation    paid during the annual accounting period. 
numbers in columns (e)(vi) through (e)(x)    is required to complete both lines only if    Columns (b) through (f) should request 
and positive numbers in columns (e)(i)       the corporation provides a platform           dollar amounts of the specified other 
through (e)(v), as applicable.               contribution to other controlled              amounts paid during the annual 
Line 11. Use this line to report E&P not     participants and is required to make          accounting period by the foreign 
previously taxed, which is treated as        platform contribution transaction             corporation to the persons listed in the 
earnings invested in U.S. property and,      payments to other controlled participants     headings for columns (b) through (f). 
therefore, reclassified to section 959(c)(1) that provide a platform contribution to       These headings must comport to those 
PTEP (column (e)(iii)). The amounts          other controlled cost sharing arrangement     used on the Schedule M (Form 5471) to 
reclassified are reported as negative        participants.                                 which this statement is attached. The 
                                                                                           attached statement must include a “totals” 
numbers in columns (a) through (c) and       Lines 5 and 20.  Report on these lines        line that ties into the amounts reported in 
positive numbers in column (e)(iii), as      cost sharing transaction payments             each column of line 29.
applicable.                                  received and paid by the foreign 
Line 12. Attach a statement detailing the    corporation (without giving effect to any     Lines 31 and 33. Report on these lines 
nature and amount of any adjustments in      netting of payments). See Regulations         the largest aggregate outstanding 
E&P not accounted for on lines 8 through     section 1.482-7(b)(1)(i). The corporation is  accounts receivable and payable 
11. Do not include adjustments required to   required to complete line 5 only if the       balances during the year with the related 
be reported on line 1b or line 6.            corporation itself incurred intangible        parties described in columns (b) through 
                                             development costs. If the corporation         (f). Report only accounts receivable or 
Line 13. The hovering deficit offset         does not itself incur intangible              payable arising in connection with the 
included in column (d) is reported as a      development costs, then it should only        provision of services or the sale or 
positive number. The same amount             report cost sharing transaction payments      processing of property. Only net accounts 
entered in column (d) is reported as a       made on line 20.                              receivable and payable to the extent that 
negative number on line 13 of column (a)                                                   the CFC’s books net the accounts payable 
or (b), as appropriate. See section 381(c)   Lines 9 and 24.  Report on line 9 the sum     against the receivable as payment of the 
(2)(B) and Regulations section               of tiered hybrid dividends received by the    accounts receivable.
1.367(b)-7(d)(2)(ii).                        foreign corporation during its tax year. 
                                             Report on line 24 the sum of hybrid           Lines 32 and 34. Report on these lines 
                                             dividends or tiered hybrid dividends paid     the largest outstanding balances during 
Schedule M                                   by the foreign corporation during its tax     the year of gross amounts borrowed from, 
Every U.S. person described in Category      year.                                         and gross amounts loaned to, the related 
                                                                                           parties described in columns (b) through 
4 must file Schedule M to report the         Lines 10 and 25. Report on these lines        (f). Do not enter aggregate cash flows, 
transactions that occurred during the        dividends received and paid by the foreign    year-end loan balances, average 
foreign corporation's annual accounting      corporation not previously taxed under        balances, or net balances. Do not include 
period ending with or within the U.S.        subpart F in the current year or in any prior an account receivable or payable balance 
person's tax year.                           year.                                         arising in connection with the provision of 
If a U.S. corporation that owns stock in     Lines 13 and 28. Report on these lines        services or the sale or processing of 
a foreign corporation is a member of a       loan guarantee fees received (line 13) and    property if the amount of such balance 
consolidated group, list the common          loan guarantee fees paid (line 28). See       does not, at any time during the tax year, 
parent as the U.S. person filing             section 482.                                  exceed what is ordinary and necessary to 
Schedule M.                                                                                carry on the trade or business. Any 
                                             Lines 14 and 29. Report on these lines        outstanding balance from these 
Important.  In translating the amounts       “other amounts received” (line 14) and        transactions should be reported on the 
from functional currency to U.S. dollars,    “other amounts paid” (line 29).               Balance Sheet (Form 5471, Schedule F, 
use the average exchange rate for the 
foreign corporation's tax year. See section 

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page 4) and possibly also on Schedule M, Column (d). Enter the method of corporation W. Mr. Lyons does not own
lines 31 and 33. acquisition (for example, purchase, gift, any of the stock of corporation W.
Accrued payments and receipts. A bequest, trade). Mr. Lyons completes and files Form
5471 and Schedule O for the corporations
corporation that uses an accrual method Column (e)(2). Enter the number of
in which he is a 10% or more shareholder.
of accounting must use accrued payments shares acquired indirectly (within the
Mr. Lyons is also required to submit a
and accrued receipts for purposes of meaning of section 958(a)(2)) by the
chart if the foreign corporation is a
computing the total amount to enter on shareholder listed in column (a).
each line of Schedule M. member of a chain of corporations, and to
Column (e)(3). Enter the number of indicate if he is a 10% or more
shares constructively owned (within the shareholder in any of those corporations.
Schedule O meaning of section 958(b)) by the Mr. Lyons would prepare a list showing
Schedule O is used to report the shareholder listed in column (a). the corporations as follows.
organization or reorganization of a foreign • Corporation W.
corporation and the acquisition or Section D—Disposition of Stock • Corporation F.
disposition of its stock. • Corporation FI.
Every U.S. citizen or resident described Section D must be completed by • Corporation FJ.
in Category 2 must complete Part I. Every shareholders who dispose of their interest • Corporation FK.
U.S. person described in Category 3 must (in whole or in part) in a foreign Then Mr. Lyons is required to indicate
complete Part II. corporation. that he is a 10% or more shareholder in
Column (d). Enter the method of corporations F, FI, and FJ.
See Regulations section 1.6046-1(i) for disposition (for example, sale, bequest,
rules on determining when U.S. persons gift, trade).
constructively own stock of a foreign Schedule P
corporation and therefore are subject to Example. In 1999, Mr. Jackson, a Use Schedule P to report the PTEP in the
the section 6046 filing requirements. U.S. citizen, purchased 10,000 shares of U.S. shareholder’s annual PTEP accounts
Name of person filing Form 5471. The common stock of foreign corporation X. with respect to a CFC in the CFC’s
name of the person filing Form 5471 is The purchase represented 10% functional currency (Part I) and the U.S.
generally the name of the U.S. person ownership of the foreign corporation. shareholder’s U.S. dollar basis in that
described in the applicable category or On July 1, 2022, Mr. Jackson made a PTEP (Part II). For purposes of the
categories of filers (see Categories of gift of 5,000 shares of foreign corporation preceding sentence, a CFC includes an
Filers, earlier). However, in the case of a X to his son, John. Because Mr. Jackson SFC that is only treated as a CFC for
consolidated return, enter the name of the has reduced his holding in the foreign limited purposes under section 965(e)(2).
U.S. parent in the field for “Name of corporation, he is required to complete
person filing Form 5471.” Form 5471 and Schedule O. To show the Note. A separate Schedule P must be
required information about the disposition, completed by each Category 1a, 1b, 4, 5a,
Reference ID number of foreign corpo- Mr. Jackson completes Section D as or 5b filer.
ration. Use the reference ID number follows:
shown on Form 5471, line 1b(2). • Enters his name in column (a). If a U.S. shareholder wholly owns the
Part I • Enters “common” in column (b). CFC, Schedule P should include the same
• Enters “July 1, 2022” in column (c). information reported on Schedule J, Part I,
Column (d). Enter the date the • Enters “gift” in column (d). column (e). If there is more than one U.S.
shareholder first acquired 10% or more (in • Enters “5,000” in column (e)(1). shareholder, the amounts reported on
value or voting power) of the outstanding • Enters “-0-” in column (f) because the Schedule P with respect to each U.S.
stock of the foreign corporation. disposition was by gift. shareholder might be different from the
Column (e). Enter the date the • Enters the name and address of his amounts reported on Schedule J.
shareholder acquired (whether in one or son, John, in column (g). Example. Corporation A, a domestic
more transactions) an additional 10% or corporation, owns 50% of the only class of
more (in value or voting power) of the Section F—Additional Information stock of CFC1 and Corporation B, a
outstanding stock of the foreign domestic corporation, owns the remaining
corporation. Item (b). List the date of any 50% of the stock of CFC1. Corporation A
reorganization of the foreign corporation wholly owns the only class of stock of
Part II that occurred during the last 4 years while CFC2. The functional currency of all
any U.S. person held 10% or more in
Section A—General Shareholder corporations is the U.S. dollar. CFC1 has
value or vote (directly or indirectly) of the tested income of $100x and CFC2 has
Information corporation's stock. If there is more than tested loss of $30x. See section 951A(c)
one such date, use the most recent date. (2). Neither Corporation A nor Corporation
If the shareholder's latest tax return was However, do not enter a date for which B has any net deemed tangible income
filed electronically, enter “e-filed” in information was reported on Section E. return that would reduce the GILTI
column (b)(3) instead of a service center. Instead, enter the date (if any) of any inclusion of Corporation A or B.
reorganization prior to that date (if it is Corporation A has a section 951A
Section C—Acquisition of Stock within the last 4 years). inclusion of $20 because its pro rata share
of CFC1’s tested income ($50x) is offset
Example for Item (c). Mr. Lyons, a
Section C is completed by shareholders by its pro rata share of CFC2’s tested loss
U.S. person, acquires a 10% ownership in
who are completing Schedule O because ($30x). Corporation B has a section 951A
foreign corporation F. F is the 100% owner
they have acquired sufficient stock in a inclusion of $50x. On Schedule P of the
of two foreign corporations, FI and FJ. F is
foreign corporation. If the shareholder Form 5471 with respect to CFC1 filed by
also a 50% owner of foreign corporation
acquired the stock in more than one Corporation B, Corporation B will report on
FK. In addition, F is 90% owned by foreign
transaction, use a separate line to report line 7, column (h), $50x of PTEP as a
each transaction. result of its section 951A inclusion with

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respect to CFC1. Corporation A will report income, foreign source and U.S. source In general, a taxpayer that is subject to
$20x of PTEP as a result of its section income. tax as a domestic corporation that is a
951A inclusion on its Form 5471, U.S. shareholder (“corporate U.S.
Schedule P, line 7, column (h), with Important. In addition to the separate shareholder”) of a CFC is deemed to pay
respect to CFC1. category codes referred to above, if you all or a portion of the foreign income taxes
The Form 5471, Schedule J, for CFC1 have more than one of the categories of paid or accrued by the CFC that are
should include PTEP of $70x with respect income referred to above, you must properly attributable to subpart F income
to the aggregate section 951A inclusions complete and file a separate Schedule P or tested income included in gross income
of Corporation A and Corporation B. using code "TOTAL" that aggregates all by the corporate U.S. shareholder. See
However, if Corporation A does not know amounts listed for each line and column of section 960(a) and (d). A corporate U.S.
Corporation B’s section 951A inclusion at all other Schedules P. shareholder may claim a credit for such
foreign taxes, subject to certain limitations.
the time Corporation A files its Form 5471, Part I
Corporation A will only be able to
Enter amounts in the functional currency
complete Schedule J, Part I, with respect Note. If an individual, estate, or trust that
of the foreign corporation as reported on
to its PTEP of $20x on line 8, column (e) is a U.S. shareholder of a CFC makes an
Form 5471, page 1, Item 1h Functional
(viii). Similarly, Corporation B will only be election under section 962 (“962 electing
Currency.
able to complete Schedule J, Part I, with shareholder”), any inclusions under
section 951 or section 951A of the U.S.
respect to its PTEP of $50x on line 8, Pre-1987 U.S. dollar PTEP should be
shareholder will be treated as received by
column (e)(viii). In the following year, translated into the foreign corporation's
a corporate U.S. shareholder for purposes
Corporation A and Corporation B should functional currency using the rules of
of section 960. See section 962(b) and
each report the other corporation’s PTEP Notice 88-70 and added to post-1986
Regulations section 1.962-2(b). As a
on Schedule J, Part I, line 1b, column (e) amounts in the appropriate PTEP
result, these U.S. shareholders may also
(viii), and the corresponding reduction to category.
CFC1’s E&P described in section 959(c) claim a foreign tax credit for foreign
(3) on Schedule J, Part I, line 1b, column Part II income taxes deemed paid with respect to
such inclusions. See sections 962(a)(1)
(a). Dollar basis. Enter amounts in U.S. and 951A(f)(1)(A).
Name of person filing Form 5471. The dollars. The U.S. shareholder’s U.S. dollar
name of the person filing Form 5471 is basis in PTEP is generally equal to the Note. See also section 1293(f) for
generally the name of the U.S. person U.S. dollar amount of E&P that the U.S. inclusions with respect to a passive
described in the applicable category or shareholder previously included in gross foreign investment company.
categories of filers (see Categories of income. See Regulation sections 989(b)
Filers, earlier). However, in the case of a (1) and (3), 1.951A-1(d)(1), and To calculate the foreign taxes deemed
consolidated return, enter the name of the 1.965-1(b)(1) and (2). paid by the corporate U.S. shareholder
(including a 962 electing shareholder),
U.S. parent in the field for “Name of The U.S. shareholder’s U.S. dollar determine for each of its CFCs the
person filing Form 5471.” basis is used by the U.S. shareholder to income, deductions, and taxes that are
Reference ID number of foreign corpo- determine the amount of foreign currency assigned to each separate category of
ration. If applicable, use the reference ID gain or loss on the PTEP that the U.S. income and each income group within
number shown on Form 5471, page 1, shareholder is required to recognize under each separate category. See Regulations
Item 1b(2). section 986(c). section 1.960-1(c)(1). The income groups
Lines a and b. Complete a separate Columns (a) through (k). Use columns include the subpart F income groups, the
Schedule P for each applicable separate (a) through (k) to report the opening tested income group, and the residual
category of income. Enter the appropriate balance of, current year additions and income group.
code on line a (at the top of page 1 of subtractions to, and the closing balance
Schedule P). To determine the of, the PTEP in the U.S. shareholder’s Computer Generated
appropriate code, see Categories of annual PTEP accounts with respect to a Schedule Q
Income in the Instructions for Form 1118. CFC. Expand the Schedule Q if you are
A foreign corporation may have PTEP Columns (a) through (j) of Schedule P reporting with respect to more than two
in a PTEP group within any of the separate correspond to Schedule J, columns (e)(i) units. Specifically, if you are reporting with
categories of income, with the exception through (e)(x). See the instructions for respect to more than two units, add to
of foreign branch category income. See Schedule J for specific line instructions. pages 1 and 2, as appropriate, new lines
(3), (4), (5), etc. in all necessary locations.
Regulations section 1.960 3(c)(1).‐ Line 1b. If there is a difference between
If code 901(j) is entered on line a, enter last year’s ending balance on Schedule P Specific Instructions for
on line b the country code for the and the amount that should be last year’s Schedule Q
sanctioned country using the two-letter ending balance, taking into account
codes (from the list at IRS.gov/ modifications in Schedule P, include the Name of person filing Form 5471. The
CountryCodes). difference on line 1b and attach an name of the person filing Form 5471 is
explanation for the difference. If there are generally the name of the U.S. person
Note. A separate Schedule P should not multiple differences, include the described in the applicable category or
be completed for the section 951A explanation and amount of each such categories of filers (see Categories of
category. Reclassified section 951A PTEP difference on the attachment. Filers, earlier). However, in the case of a
and section 951A PTEP that is in the consolidated return, enter the name of the
section 951A category should be reported U.S. parent in the field for “Name of
on the Schedule P completed for the Schedule Q person filing Form 5471.”
general category. Use Schedule Q to report the CFC’s Reference ID number of foreign corpo-
income, deductions, taxes, and assets by ration. If applicable, use the reference ID
Note. For purposes of this Schedule P, CFC income groups for purposes of number shown on Form 5471, page 1,
include in each separate category of sections 960(a) and (d). item 1b(2).

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Line A. Complete a separate Schedule Q             section 1.904-4(c)(4). This is one reason     category of a CFC are on line 1 (“subpart 
for each applicable separate category of           that, in the case of a CFC, tested            F income groups”). See Regulations 
income. Enter the appropriate code from            unit-by-tested unit reporting is required     section 1.960-1(d)(2)(ii)(B). Each single 
the table below for the separate category          with respect to the income groups on lines    item of foreign base company income (as 
of income with respect to which the                1a through 1j and line 3. A foreign           defined in Regulations section 1.954-1(c)
Schedule Q is being completed.                     corporation that is not a CFC, but that is a  (1)(iii)) is a separate subpart F income 
                                                   noncontrolled 10%-owned foreign               group. With respect to a CFC, Regulations 
                                                   corporation must report this information on   section 1.954-1(c)(1)(iii)(A)(2) identifies as 
Codes for Categories of Income                     a foreign QBU-by-foreign QBU basis. This      a single item of income all foreign base 
                                                   would be the case, for example, if you are    company income (other than foreign 
Code Category of Income                            completing Schedule Q for purposes of         personal holding company income) that 
PAS   Passive category income                      attaching it to Schedules K-2 and K-3 for     falls within both a single separate category 
901j  Section 901(j) income                        purposes of section 1293(f).                  (typically, general category income) and a 
GEN   General category income                      To figure the amounts to enter on lines       single category of foreign base company 
                                                   1a through 1j, on lines (1), (2), etc., under income described in each of Regulations 
If code 901j is entered on line A, enter           each line 1a through 1j, enter the name of    sections 1.954-1(c)(1)(iii)(A)(2)(i) through 
on line 1m, column (a), the country code           each unit of the foreign corporation (the     (v). For example, with respect to line 1g, 
for the sanctioned country using the               relevant unit being each tested unit in the   there is a single subpart F income group 
two-letter codes (from the list at IRS.gov/        case of a CFC and each QBU in the case        within the general category that consists of 
CountryCodes).                                     of a 10%-owned foreign corporation),          all of a CFC’s foreign base company sales 
                                                   including the foreign corporation itself, and income.
Important. In addition to the separate             the information required in each column (i)     Use lines 1a through 1f to enter the 
category codes referred to above, if you           through (xvi) with respect to the amount in   passive category foreign personal holding 
have more than one of the categories of            each subpart F income group within each       company income of the CFC under the 
income referred to above, you must                 category for each unit.                       appropriate income group (dividends, 
complete and file a separate Schedule Q            On lines (1), (2), etc., under line 4,        interest, rents, royalties, and annuities; net 
using code “TOTAL” that aggregates all             enter the name of each unit and enter the     gain from certain property transactions; 
amounts listed for each line and column in         information required for columns (i)          net gain from commodities transactions; 
all other Schedules Q.                             through (xvi) for each unit, but do not enter net foreign currency gain; income 
Line B. If category code “PAS” is entered          amounts excluded from subpart F income        equivalent to interest; and other passive 
on line A, a separate Schedule Q must be           under the subpart F high-tax exception        category foreign personal holding 
completed for each applicable grouping             (those amounts are reported on lines (1),     company income of the CFC), each of 
under Regulations section 1.904-4(c)(3).           (2), etc., under lines 1a through 1j) or      which is also treated as a separate 
See Regulations sections 1.954-1(c)(1)(iii)        tested income under the GILTI high-tax        subpart F income group under 
(B) and 1.904-4(c)(3) through (5). Enter on        exclusion (those amounts are reported on      Regulations section 1.960-1. See 
line B the appropriate code from the table         lines (1), (2), etc., under line 3).          Regulations section 1.954-1(c)(1)(iii)(B).
below for each of the following groups             Line C. If code 901j is entered on line A,    Note. Enter the following passive 
under Regulations section 1.904-4(c)(3):           enter the country code for the sanctioned     category foreign personal holding 
                                                   country using the two-letter codes from       company income of the CFC on line 1e:
Codes for Passive Groups                           the list at IRS.gov/CountryCodes.               Income from notional principal 
                                                                                                 •
                                                   Line D. Taxpayers are generally required      contracts,
Code Passive Group                                 to complete a separate Schedule Q for         • Payments in lieu of dividends,
i     All passive income received during the tax   foreign source income in each separate        • Personal service contracts.
      year that is subject to a withholding tax of category and U.S. source income in each       See section 954(c)(1)(F) through (H).
      15% or greater must be treated as one        separate category. On a given                   Attach a statement that includes all of 
      item of income. See Regulations section      Schedule Q, taxpayers are generally           the information requested by Schedule Q 
      1.904-4(c)(3)(i).                            required to check the box for either foreign  delineating the amount on line 1e for each 
ii    All passive income received during the tax   source income or U.S. source income, as       of the four groups reporting on line 1e. For 
      year that is subject to a withholding tax of applicable. However, if a taxpayer has        example, if both income equivalent to 
      less than 15% (but greater than zero)        entered code “TOTAL” on line A and the        interest and income from notional principal 
      must be treated as one item of income.       total reported on that Schedule Q includes    contracts are included on line 1e, on the 
      See Regulations section 1.904-4(c)(3)(ii).   both foreign source income and U.S.           statement, identify the amount related to 
iii   All passive income received during the tax   source income, the taxpayer may check         each of those income groups for each 
      year that is subject to no withholding tax   both boxes on line D.                         column.
      or other foreign tax must be treated as one 
      item of income. See Regulations section      Line E. A separate Schedule Q is                Use lines 1g through 1j to enter the 
      1.904-4(c)(3)(iii).                          required for foreign oil and gas extraction   foreign base company sales income, 
iv    All passive income received during the tax   income (FOGEI) and foreign oil related        foreign base company services income, 
      year that is subject to no withholding tax   income (FORI). If the Schedule Q is being     full inclusion income, and insurance 
      but is subject to foreign tax other than a   prepared to report the FOGEI or FORI of a     income described in section 952(a)(1) of 
      withholding tax must be treated as one       CFC, check the box for Item E. Indicate       the CFC.
      item of income. See Regulations section      the amount of FOGEI and FORI in each 
      1.904-4(c)(3)(iv).                           income group.                                   To figure the amounts to enter on lines 
                                                                                                 1a through 1j, on lines (1), (2), etc., under 
                                                   Line 1. Subpart F Income 
Note. The grouping rules of Regulations                                                          each line 1a through 1j, enter the name of 
section 1.904-4(c)(3)(i) through (iv) apply        Groups                                        each QBU of the CFC, including the CFC 
separately to income attributable to each          The separate subpart F income groups          itself, and the information required in each 
tested unit of a CFC. See Regulations              within each applicable section 904            column (i) through (xvi) with respect to the 
                                                                                                 amount in each subpart F income group 

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within each category for each QBU. On          Line 3. Tested Income Group                      GILTI high-tax exclusion, in the 
lines 1a through 1j, enter the total for each  Use line 3 to report tested income in the        appropriate column on line 4.
column by adding the amounts on lines          tested income group of the CFC (a “tested        Example. For line 1(a)(1), $100 of gross 
(1), (2), etc., excluding from such total any  income group”). See Regulations section          income is reported in column (ii), $35 of 
amounts reported with respect to income        1.960-1(d)(2)(ii)(C). On lines (1), (2), etc.,   foreign tax is reported in each of columns 
excluded from subpart F income under the       under line 3, enter the name of each             (x) and (xii), and the checkbox in column 
high-tax exception in section 954(b)(4)        tested unit of the CFC (including the CFC        (xiv) is checked. For line 1(a)(2), $75 of 
(“subpart F high-tax exception”). These        tested unit itself) and enter for each tested    gross income is reported in column (ii), $5 
amounts are included in the total amount       unit the information required in columns (ii)    of foreign tax is reported in each of 
of residual income, which is reported on       through (xvi), based on the tentative gross      columns (x) and (xii), and the checkbox in 
line 4. As a result, the amounts included      tested income attributable to each tested        column (xiv) is not checked. For line 3(1), 
on lines 1a through 1j for each column         unit (without regard to any amounts              $200 of gross income is reported in 
may not equal the sum of the amounts           excluded under the GILTI high-tax                column (ii), $70 of foreign tax is reported in 
reported on lines (1), (2), etc., for each     exclusion in Regulations section                 each of columns (x) and (xii), and the 
column because any item excluded from          1.951A-2(c)(7) (“GILTI high-tax                  checkbox in column (xiv) is checked. For 
subpart F income by reason of the              exclusion”)). If the GILTI high-tax              line 3(2), $150 of gross income is reported 
high-tax election is included in the           exclusion applies with respect to any            in column (ii), $10 of foreign tax is reported 
summation on line 4 instead of the             tested unit of the CFC, include the              in each of columns (x) and (xii), and the 
summations on lines 1a through 1j. See         amounts reported for columns (ii) through        checkbox in column (xiv) is not checked. 
the instructions for column (xiv) and line 4.  (xiii), (xv), and (xvi) in the total reported on For line 4(1), $300 of gross income is 
Example.   For line 1(a)(1), gross income      line 4. See the instructions for line 4. As a    reported in column (ii) and $105 of foreign 
of $50 is reported in column (ii), foreign tax result, the total amount entered on line 3       tax is reported in column (x). On line 4(1), 
of $20 is reported in each of columns (x)      may not equal the sum of the amounts             both columns (xii) and (xiv) should be 
and (xii), and the checkbox in column (xiv)    reported in columns (ii) through (xiii), (xv),   blank in all cases. As a result, the amount 
is checked. For line 1(a)(2), gross income     and (xvi) on lines 3(1), 3(2), etc., if any      reported on line 4 for column (ii) is the sum 
of $100 is reported in column (ii), $5 of      tested unit’s tentative tested income is         of the amounts reported in column (ii) on 
foreign tax is reported in each of columns     excluded under the GILTI high-tax                lines 1(a)(1), 3(1), and 4(1), which equals 
(x) and (xii), and the checkbox in column      exclusion (these amounts are included in         $600 ($100 + $200 + $300). The amount 
(xiv) is not checked. For line 1(a)(3), gross  the total amounts reported on line 4). In        reported in column (x), line 4, is the sum of 
income of $75 is reported in column (ii), $3   general, tested income will be in a single       the amounts reported in column (x) on 
of foreign tax is reported in each of          tested income group within the general           lines 1(a)(1), 3(1), and 4(1), which equals 
columns (x) and (xii), and the checkbox in     category. Because a CFC cannot earn              $210 ($35 + $70 + $105). No amount 
column (xiv) is not checked. As a result,      section 951A category income or foreign          should be reported in column (xii) of line 4 
the amount reported in column (ii) on          branch category income at the CFC level,         as foreign tax on residual amounts are not 
line 1(a) is the sum of the amounts            there is no tested income group within           creditable. The amounts reported on 
reported in column (ii) on line 1(a)(2) and    either section 904 category. With respect        line 1(a)(1) would not be included in the 
1(a)(3), which is equal to $175 ($100 +        to the general category tested income            total for line 1(a), but the amount reported 
$75). The amounts reported in columns (x)      group of a CFC, GILTI inclusion amounts          on line 1(a)(2) would be included in the 
and (xii) on line 1(a) are the sum of the      and taxes with respect to the tested             total reported on line 1(a). Similarly, the 
amounts reported in each column on lines       income group will generally be treated as        amounts reported on line 3(1) would not 
1(a)(2) and 1(a)(3), which is equal to $8      income and deemed paid taxes in the              be included in the total reported on line 3, 
($5 + $3). The items reported on line 1(a)     section 951A category. See Regulations           but the amounts reported on line 3(2) 
(1), gross income of $50 and $20 of            sections 1.904-4(g) and 1.904-6(e).              would be reported in the total reported on 
foreign tax, are not included in the totals                                                     line 3.
reported on line 1(a). These amounts are       Line 4. Residual Income Group
included in the totals for each respective     Use line 4 to report the information             Column (i). Consistent with the reporting 
column on line 4. As a result, the amount      required in columns (i) through (xvi) that is    requirement on Form 1118, enter the 
reported on line 4, column (ii), is increased  in a section 904 category but that is not of     two-letter code (from the list at IRS.gov/
by $50 and the amount reported in column       a type that is included in one of the            CountryCodes) of each foreign country 
(x) on line 4 is increased by $20. No          subpart F income groups or a tested              and U.S. possession within which income 
amount is reported on line 4, column (xii),    income group and is therefore assigned to        is sourced and/or to which taxes were 
because foreign income taxes attributable      the residual income group. See                   paid or accrued.
to high-tax exception or high-tax exclusion    Regulations section 1.960-1(d)(2)(ii)(D).        Column (ii). Enter the amount of gross 
income are not creditable.                     Enter the name of each QBU and enter the         income of the CFC that is assigned to 
                                               information required for columns (i)             each income group within each section 
On lines 1k through 1m, enter                  through (xvi) for each QBU on lines 4(1),        904 category.
international boycott income described in      4(2), etc., but do not enter amounts 
section 952(a)(3), illegal bribes,             excluded from subpart F income under the         Columns (iii) through (vii). Expenses. 
kickbacks, and other payments described        subpart F high-tax exception (those              Deductions of the CFC, including for 
in section 952(a)(4), and income included      amounts are reported on lines (1), (2), etc.     current year taxes, are allocated and 
in a section 901(j) separate category          under lines 1a through 1i) or tested             apportioned to the income groups to 
described in section 952(a)(5). See            income under the GILTI high-tax exclusion        determine net income (or loss) in each 
Regulations section 1.960-1(d)(2)(ii)(B)       (those amounts are reported on lines 3(1),       income group and to identify the current 
(2).                                           3(2), etc.). Enter the sum of the amounts        year foreign income taxes that relate to the 
Line 2. Recaptured Subpart F                   reported on lines 4(1), 4(2), etc., plus the     income in each income group for section 
Income                                         sum of amounts excluded from subpart F           960 purposes. See Regulations sections 
                                               income under the subpart F high-tax              1.960-1(c)(1) and 1.960-1(d)(3)(ii). Enter 
Enter income that is recaptured as subpart     exception and tested income under the            the expenses allocated and apportioned 
F income in the current year. See section                                                       to the item of gross income reported for 
952(c)(2).                                                                                      each QBU or tested unit as well as the 

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aggregate amount of such expenses amount reported in column (xii) may not
allocated and apportioned to each group. be the same as the sum of the amounts in Schedule R
See the instructions for lines 1 through 4. columns (viii) through (x) if columns (viii) Schedule R is used to report basic
through (x) include taxes that are not
Column (viii). Current year tax on reat- information pertaining to distributions from
creditable, including taxes paid or accrued
tributed income from disregarded pay- foreign corporations. This information is
to sanctioned countries, foreign taxes
ments. This column is used to report required by sections 245A, 959, and
disallowed under section 901(k), (m), and
current year tax imposed solely by reason 986(c).
(l), and taxes paid or accrued to the United
of the receipt of a disregarded payment Name of Person Filing Form
States.
that is a reattribution payment. The current
year tax is allocated and apportioned to Column (xiii). Average asset value. 5471
the income group to which an amount of Foreign gross income that arises from a The name of the person filing Form 5471
gross income is assigned by reason of the disregarded payment that is treated as a is generally the name of the U.S. person
receipt of the reattribution payment. See remittance for U.S. tax purposes is described in the category or categories of
Regulations sections 1.960-1(d)(3)(ii)(A) assigned to an income group by reference filers (see Categories of Filers, earlier).
and 1.861-20(d)(3)(v)(B). Report current to the income groups to which the assets However, in the case of a consolidated
year taxes allocated and apportioned to of the payor taxable unit are assigned (or return, enter the name of the U.S. parent
the item of gross income reported for each would be assigned if the taxable unit were in the field for “Name of person filing Form
QBU or tested unit as well as the a United States person) under the rules of 5471.”
aggregate amount of such foreign taxes in Regulations section 1.861-9 for purposes
each group. See the instructions for lines of apportioning interest expense. This rule Reference ID Number of
1 through 4. uses the payor’s asset apportionment Foreign Corporation
percentages as a proxy for the
Column (ix). Current year tax on all If applicable, use the reference ID number
accumulated earnings of the payor taxable
other disregarded payments. This shown on Form 5471, page 1, Item 1b(2).
unit from which the remittance is made.
column is used to report current tax Column (a): Description of distribu-
For this purpose the assets of the taxable
imposed solely by reason of the receipt of tion. The description should include
unit making the remittance are determined
a disregarded payment other than a whether the distribution was cash or
in accordance with the rules of
reattribution payment, and which is noncash and taxable or nontaxable to
Regulations section 1.987-6(b) that apply
therefore either a remittance or a shareholders. Use code sections to
in determining the source and separate
contribution. See Regulations section properly identify the taxable or nontaxable
category of exchange gain or loss on a
1.861-20(d)(3)(v)(C). Foreign tax imposed consequences of the distribution. For
section 987 remittance, as modified in two
by reason of a disregarded payment that example, “taxable cash dividend eligible
respects. See Regulations section
is a remittance is assigned to the income for a dividends received deduction under
1.861-20(d)(3)(v)(C)(1). Report asset
groups based upon the assets of the section 245A” or “nontaxable cash
values for each QBU or tested unit as well
payor. See Regulations section distribution of PTEP.” Report parts of a
as the aggregate amount of assets in each
1.861-20(d)(3)(v)(C)(1). Foreign tax distribution on separate rows if the
group. See the instructions for lines 1
imposed by reason of a disregarded distribution is partially taxable and partially
through 4.
payment that is a contribution is assigned nontaxable, or if the distribution is either
to the residual grouping. See Regulations Column (xiv). High-tax election. Check taxable or nontaxable by reason of
section 1.861-20(d)(3)(v)(C)(2). Report the box in column (xiv) of the line different Code sections. For example, a
current year taxes allocated and corresponding to any item of income with cash distribution of $100 that is a
apportioned to the item of gross income respect to which the subpart F high-tax nontaxable distribution of PTEP under
reported for each QBU or tested unit as exception applies. If any amount is section 959(a) of $30, a taxable dividend
well as the aggregate amount of such excluded under the subpart F high-tax eligible for a dividends received deduction
foreign taxes allocated and apportioned to exception, do not include it in the total for under section 245A of $15, a taxable
each group. See the instructions for lines line 1a through 1j, but instead add the dividend under section 301(c)(1) of $25, a
1 through 4. amount to the total for line 4. See the nontaxable distribution applied against
instructions for lines 1 and 4. If a GILTI
Column (x). Other current year taxes. basis under section 301(c)(2) of $10, and
high-tax exclusion under Regulations
Any other current year tax is allocated and a taxable distribution treated as gain from
section 1.951A-2(c)(7)(viii) is effective with
apportioned among the section 904 the sale or exchange of property under
respect to the CFC for the CFC inclusion
categories under the rules of Regulations section 301(c)(3) of $20, would be
year, check the box in column (xiv) that
section 1.904-6(a) based on the portion of reported on five rows.
corresponds to the item(s) of income to
the foreign taxable income (as If noncash distributions were made,
which the exception applies. If an amount
characterized under federal income tax attach a statement and show both the tax
reported on line 3(1), 3(2), etc., is
principles) that is assigned to a particular bases and fair market values.
excluded from gross income under the
section 904 category. Any other current Column (b): Date of distribution. Enter
GILTI high-tax exclusion, do not include it
year foreign tax is allocated to the CFC the month, day, and year using the
in the total amount for line 3. Instead,
income group to which the items of foreign following format: MM-DD-YYYY. For
include the amounts in the total for line 4.
gross income are assigned under the rules example, June 30, 2022, would be
See the instructions for lines 3 and 4.
of Regulations section 1.861-20. Report entered as “06-30-2022.”
current year taxes allocated and Column (xv). Loss allocation. This
apportioned to the item of gross income column is used to report a reduction to Column (c): Amount of distribution in
reported for each QBU or tested unit as subpart F income in each applicable foreign corporation's functional cur-
well as the aggregate amount of such income group when the foreign rency. The amount of a distribution is
foreign taxes allocated and apportioned to corporation's subpart F income exceeds generally the amount of any money paid to
each group. See the instructions for lines current year E&P. See Regulations the shareholder plus the fair market value
1 through 4. sections 1.952-1(c) and (e) and 1.951A-6. (FMV) of any property transferred to the
shareholder. However, this amount is
Column (xii). Foreign taxes for which
credit is allowed (U.S. dollars). The

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

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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. 01-2023) -41-

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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Principal Business Activity Codes                                       Using the list of activities and codes below,               Enter on page 1, Item 1f, the six-digit code selected 
                                                                 determine from which activity the company derives the       from the list below. In item 1g, enter a brief description 
This list of principal business activities and their             largest percentage of its “total receipts.” If the company  of the company's business activity.
associated codes is designed to classify an enterprise           purchases raw materials and supplies them to a 
by the type of activity in which it is engaged to facilitate     subcontractor to produce the finished product, but 
the administration of the Internal Revenue Code. These           retains title to the product, the company is considered a 
principal business activity codes are based on the North         manufacturer and must use one of the manufacturing 
American Industry Classification System.                         codes (311110-339900).
Agriculture, Forestry, Fishing,                              painting, wallcovering, flooring, Nonmetallic Mineral Product              339900 Other Miscellaneous 
                                                             tile, & finish carpentry)         Manufacturing                                   Manufacturing
and Hunting                               238900             Other Specialty Trade             327100 Clay Product & Refractory Mfg     Wholesale Trade
111100 Oilseed & Grain Farming                               preparation)
Crop Production                                              Contractors (including site       327210 Glass & Glass Product Mfg         Merchant Wholesalers, Durable Goods
                                                                                               327300 Cement & Concrete Product Mfg
111210 Vegetable & Melon Farming          Manufacturing                                        327400 Lime & Gypsum Product Mfg         423100 Motor Vehicle & Motor Vehicle 
                                                                                                                                               Parts & Supplies
       (including potatoes & yams)        Food Manufacturing                                   327900 Other Nonmetallic Mineral         423200 Furniture & Home Furnishings
111300 Fruit & Tree Nut Farming           311110             Animal Food Mfg                          Product Mfg                       423300 Lumber & Other Construction 
111400 Greenhouse, Nursery, &             311200             Grain & Oilseed Milling           Primary Metal Manufacturing                     Materials
       Floriculture Production            311300             Sugar & Confectionery Product     331110 Iron & Steel Mills & Ferroalloy   423400 Professional & Commercial 
111900 Other Crop Farming (including                         Mfg                                      Mfg                                      Equipment & Supplies
       tobacco, cotton, sugarcane, hay,   311400             Fruit & Vegetable Preserving &    331200 Steel Product Mfg from            423500 Metal & Mineral (except 
       peanut, sugar beet & all other                        Specialty Food Mfg                       Purchased Steel                          Petroleum)
       crop farming)
Animal Production                         311500             Dairy Product Mfg                 331310 Alumina & Aluminum Production     423600 Household Appliances & 
112111 Beef Cattle Ranching & Farming     311610             Animal Slaughtering and                  & Processing                             Electrical & Electronic Goods
112112 Cattle Feedlots                                       Processing                        331400 Nonferrous Metal (except          423700 Hardware & Plumbing & Heating 
112120 Dairy Cattle & Milk Production     311710             Seafood Product Preparation &            Aluminum) Production &                   Equipment & Supplies
                                                             Packaging                                Processing
112210 Hog & Pig Farming                  311800             Bakeries, Tortilla & Dry Pasta    331500 Foundries                         423800 Machinery, Equipment, & 
                                                                                                                                               Supplies
112300 Poultry & Egg Production                              Mfg                               Fabricated Metal Product                 423910 Sporting & Recreational Goods & 
112400 Sheep & Goat Farming               311900             Other Food Mfg (including         Manufacturing                                   Supplies
112510 Aquaculture (including shellfish &                    coffee, tea, flavorings, &        332110 Forging & Stamping                423920 Toy & Hobby Goods & Supplies
       finfish farms & hatcheries)                           seasonings)                       332210 Cutlery & Handtool Mfg            423930 Recyclable Materials
112900 Other Animal Production            Beverage and Tobacco Product                         332300 Architectural & Structural Metals 423940 Jewelry, Watch, Precious Stone, 
Forestry and Logging                      Manufacturing                                               Mfg                                      & Precious Metals
113110 Timber Tract Operations            312110             Soft Drink & Ice Mfg              332400 Boiler, Tank, & Shipping          423990 Other Miscellaneous Durable 
113210 Forest Nurseries & Gathering of    312120             Breweries                                Container Mfg                            Goods
       Forest Products                    312130             Wineries                          332510 Hardware Mfg                      Merchant Wholesalers, Nondurable 
113310 Logging                            312140             Distilleries                      332610 Spring & Wire Product Mfg         Goods
Fishing, Hunting, and Trapping            312200             Tobacco Manufacturing             332700 Machine Shops; Turned Product;    424100 Paper & Paper Products
114110 Fishing                            Textile Mills and Textile Product Mills                     & Screw, Nut, & Bolt Mfg          424210 Drugs & Druggists' Sundries
114210 Hunting & Trapping                 313000             Textile Mills                     332810 Coating, Engraving, Heat          424300 Apparel, Piece Goods, & Notions
Support Activities for Agriculture and    314000             Textile Product Mills                    Treating, & Allied Activities     424400 Grocery & Related Products
Forestry                                  Apparel Manufacturing                                332900 Other Fabricated Metal Product    424500 Farm Product Raw Materials
                                                                                                      Mfg
115110 Support Activities for Crop        315100             Apparel Knitting Mills            Machinery Manufacturing                  424600 Chemical & Allied Products
       Production (including cotton       315210             Cut & Sew Apparel Contractors     333100 Agriculture, Construction, &      424700 Petroleum & Petroleum Products
       ginning, soil preparation,         315250             Cut & Sew Apparel Mfg (except            Mining Machinery Mfg              424800 Beer, Wine, & Distilled Alcoholic 
       planting, & cultivating)                              Contractors)                      333200 Industrial Machinery Mfg                 Beverages
115210 Support Activities for Animal      315990             Apparel Accessories & Other       333310 Commercial & Service Industry     424910 Farm Supplies
       Production (including farriers)                       Apparel Mfg                              Machinery Mfg                     424920 Book, Periodical, & Newspapers
115310 Support Activities For Forestry    Leather and Allied Product                           333410 Ventilation, Heating,             424930 Flower, Nursery Stock, & Florists' 
Mining                                    Manufacturing                                               Air-Conditioning, & Commercial           Supplies
211120 Crude Petroleum Extraction         316110             Leather & Hide Tanning &                 Refrigeration Equipment Mfg       424940 Tobacco Products & Electronic 
211130 Natural Gas Extraction                                Finishing                         333510 Metalworking Machinery Mfg               Cigarettes
212110 Coal Mining                        316210             Footwear Mfg (including rubber    333610 Engine, Turbine & Power           424950 Paint, Varnish, & Supplies
                                                             & plastics)                              Transmission Equipment Mfg        424990 Other Miscellaneous Nondurable 
212200 Metal Ore Mining                   316990             Other Leather & Allied Product    333900 Other General Purpose                    Goods
212310 Stone Mining & Quarrying                              Mfg                                      Machinery Mfg                     Wholesale Trade Agents and Brokers
212320 Sand, Gravel, Clay, & Ceramic &    Wood Product Manufacturing                           Computer and Electronic Product          425120 Wholesale Trade Agents & 
       Refractory Minerals Mining &       321110             Sawmills & Wood Preservation      Manufacturing                                   Brokers
       Quarrying                          321210             Veneer, Plywood, & Engineered     334110 Computer & Peripheral             Retail Trade
212390 Other Nonmetallic Mineral                             Wood Product Mfg                         Equipment Mfg
       Mining & Quarrying                 321900             Other Wood Product Mfg            334200 Communications Equipment Mfg      Motor Vehicle and Parts Dealers
213110 Support Activities for Mining      Paper Manufacturing                                  334310 Audio & Video Equipment Mfg       441110 New Car Dealers
Utilities                                 322100             Pulp, Paper, & Paperboard Mills   334410 Semiconductor & Other             441120 Used Car Dealers
221100 Electric Power Generation,         322200             Converted Paper Product Mfg              Electronic Component Mfg          441210 Recreational Vehicle Dealers
       Transmission & Distribution        Printing and Related Support Activities              334500 Navigational, Measuring,          441222 Boat Dealers
221210 Natural Gas Distribution           323100             Printing & Related Support               Electromedical, & Control         441227 Motorcycle, ATV, & All other 
221300 Water, Sewage & Other Systems                         Activities                               Instruments Mfg                          Motor Vehicle Dealers
221500 Combination Gas & Electric         Petroleum and Coal Products                          334610 Manufacturing & Reproducing       441300 Automotive Parts, Accessories, 
Construction                              Manufacturing                                               Magnetic & Optical Media                 & Tire Retailers
                                          324110             Petroleum Refineries (including   Electrical Equipment, Appliance, and 
Construction of Buildings                                    integrated)                       Component Manufacturing                  Building Material and Garden 
                                                                                                                                        Equipment and Supplies Dealers
236110 Residential Building Construction  324120             Asphalt Paving, Roofing, &        335100 Electric Lighting Equipment Mfg   444110 Home Centers
236200 Nonresidential Building                               Saturated Materials Mfg           335200 Household Appliance Mfg           444120 Paint & Wallpaper Retailers
       Construction                       324190             Other Petroleum & Coal            335310 Electrical Equipment Mfg          444140 Hardware Retailers
Heavy and Civil Engineering                                  Products Mfg                      335900 Other Electrical Equipment &      444180 Other Building Material Dealers
Construction                              Chemical Manufacturing                                      Component Mfg                     444200 Lawn & Garden Equipment & 
237100 Utility System Construction        325100             Basic Chemical Mfg                Transportation Equipment                        Supplies Retailers
237210 Land Subdivision                   325200             Resin, Synthetic Rubber, &        Manufacturing                            Food and Beverage Retailers
237310 Highway, Street, & Bridge                             Artificial & Synthetic Fibers &   336100 Motor Vehicle Mfg                 445110 Supermarkets and Other 
       Construction                                          Filaments Mfg                     336210 Motor Vehicle Body & Trailer Mfg         Grocery Retailers (except 
237990 Other Heavy & Civil Engineering    325300             Pesticide, Fertilizer, & Other    336300 Motor Vehicle Parts Mfg                  Convenience)
       Construction                                          Agricultural Chemical Mfg         336410 Aerospace Product & Parts Mfg     445131 Convenience Retailers
Specialty Trade Contractors               325410             Pharmaceutical & Medicine Mfg     336510 Railroad Rolling Stock Mfg        445132 Vending Machine Operators
238100 Foundation, Structure, & Building  325500             Paint, Coating, & Adhesive Mfg    336610 Ship & Boat Building              445230 Fruit & Vegetable Retailers
       Exterior Contractors (including    325600             Soap, Cleaning Compound, &        336990 Other Transportation Equipment    445240 Meat Retailers
       framing carpentry, masonry,                           Toilet Preparation Mfg                   Mfg                               445250 Fish & Seafood Retailers
       glass, roofing, & siding)          325900             Other Chemical Product &          Furniture and Related Product            445291 Baked Goods Retailers
238210 Electrical Contractors                                Preparation Mfg                   Manufacturing                            445292 Confectionery & Nut Retailers
238220 Plumbing, Heating, &               Plastics and Rubber Products                         337000 Furniture & Related Product       445298 All Other Specialty Food 
       Air-Conditioning Contractors       Manufacturing                                               Manufacturing                            Retialers
238290 Other Building Equipment           326100             Plastics Product Mfg              Miscellaneous Manufacturing              445320 Beer, Wine, & Liquor Retailers
       Contractors                        326200             Rubber Product Mfg                339110 Medical Equipment & Supplies 
238300 Building Finishing Contractors                                                                 Mfg
       (including drywall, insulation, 

                                                                                               -42-

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Principal Business Activity Codes (Continued)
Furniture and Home Furnishings               Pipeline Transportation                  Insurance Carriers and Related           541380  Testing Laboratories & Services
Retailers                                    486000 Pipeline Transportation           Activities                               Specialized Design Services
449110  Furniture Retailers                  Scenic & Sightseeing Transportation      524110 Direct Life, Health, & Medical    541400  Specialized Design Services 
449121  Floor Covering Retailers             487000 Scenic & Sightseeing                     Insurance Carriers                        (including interior, industrial, 
449122  Window Treatment Retailers                  Transportation                    524120 Direct Insurance (except Life,            graphic, & fashion design)
449129  All Other Home Furnishings           Support Activities for Transportation           Health & Medical) Carriers        Computer Systems Design and Related 
        Retailers                            488100 Support Activities for Air        524210 Insurance Agencies &              Services
Electronics and Appliance Retailers                 Transportation                           Brokerages                        541511  Custom Computer Programming 
449210  Electronic & Appliance Retailers     488210 Support Activities for Rail       524290 Other Insurance Related                   Services
        (including computers)                       Transportation                           Activities (including third-party 541512  Computer Systems Design 
                                                                                             administration of insurance and 
General Merchandise Retailers                488300 Support Activities for Water             pension funds)                            Services
455110  Department Stores                           Transportation                    Funds, Trusts, and Other Financial       541513  Computer Facilities Management 
455210  Warehouse Clubs,                     488410 Motor Vehicle Towing              Vehicles                                         Services
        Supercenters,& Other General         488490 Other Support Activities for Road 525100 Insurance & Employee Benefit      541519  Other Computer Related 
        Merch. Retailers                            Transportation                           Funds                                     Services
Health and Personal Care Retailers           488510 Freight Transportation            525910 Open-End Investment Funds         Other Professional, Scientific, and 
456110  Pharmacies & Drug Retailers                 Arrangement                              (Form 1120-RIC, U.S. Income       Technical Services
456120  Cosmetics, Beauty Supplies, &        488990 Other Support Activities for             Tax Return for Regulated          541600  Management, Scientific, & 
        Perfume Retailers                           Transportation                           Investment Companies)                     Technical Consulting Services
456130  Optical Goods Retailers              Couriers and Messengers                  525920 Trusts, Estates, & Agency         541700  Scientific Research & 
456190  Other Health & Personal Care         492110 Couriers & Express Delivery              Accounts                                  Development Services
        Retailers                                   Services                          525990 Other Financial Vehicles          541800  Advertising, Public Relations, & 
Gasoline Stations & Fuel Dealers             492210 Local Messengers & Local                 (including mortgage REITs and             Related Services
457100  Gasoline Stations (including                Delivery                                 closed-end investment funds)      541910  Marketing Research & Public 
                                                                                             “Offices of Bank Holding                  Opinion Polling
        convenience stores with gas)         Warehousing and Storage                         Companies” and “Offices of        541920  Photographic Services
457210  Fuel Dealers (including Heating      493100 Warehousing & Storage (except            Other Holding Companies” are      541930  Translation & Interpretation 
        Oil & Liquefied Petroleum)                  lessors of mini-warehouses &             located under Management of               Services
Clothing and Accessories Retailers                  self-storage units)                      Companies (Holding 
                                                                                             Companies) below.                 541940  Veterinary Services
458110  Clothing & Clothing Accessories      Information                              Real Estate and Rental and               541990  All Other Professional, Scientific, 
        Retailers                            Motion Picture and Sound Recording                                                        & Technical Services
458210  Shoe Retailers                       Industries                               Leasing                                  Management of Companies 
458310  Jewelry Retaileres                   512100 Motion Picture & Video Industries Real Estate                              (Holding Companies)
458320  Luggage & Leather Goods                     (except video rental)             531110 Lessors of Residential Buildings 
        Retailers                            512200 Sound Recording Industries               & Dwellings (including equity     551111  Offices of Bank Holding 
Sporting, Hobby, Book, Musical               Publishing Industries                           REITs)                                    Companies
Instrument & Miscellaneous Retailers         513110 Newspaper Publishers              531120 Lessors of Nonresidential         551112  Offices of Other Holding 
459110  Sporting Goods Retailers             513120 Periodical Publishers                    Buildings (except                         Companies
                                                                                             Mini-warehouses) (including 
459120  Hobby, Toy, & Game Retailers         513130 Book Publishers                          equity REITs)                     Administrative and Support and 
459130  Sewing, Needlework, & Piece          513140 Directory & Mailing List          531130 Lessors of Mini-warehouses &      Waste Management and 
        Goods Retailers                             Publishers                               Self-Storage Units (including     Remediation Services
459140  Musical Instrument & Supplies        513190 Other Publishers                         equity REITs)
        Retailers                            513210 Software Publishers               531190 Lessors of Other Real Estate      Administrative and Support Services
459210  Book Retailers & News Dealers        Broadcasting & Content Providers &              Property (including equity REITs) 561110  Office Administrative Services
        (including newsstands)               Telecommunications                       531210 Offices of Real Estate Agents &   561210  Facilities Support Services
459310  Florists                             516100 Radio & Television Broadcasting          Brokers                           561300  Employment Services
459410  Office Supplies & Stationery                Stations                          531310 Real Estate Property Managers     561410  Document Preparation Services
        Retailers                            516210 Media Streaming, Social           531320 Offices of Real Estate Appraisers 561420  Telephone Call Centers
459420  Gift, Novelty, & Souvenir                   Networks, & Other Content         531390 Other Activities Related to Real  561430  Business Service Centers 
        Retailers                                   Providers                                Estate                                    (including private mail centers & 
459510  Used Merchandise Retailers           517000 Telecommunications (including     Rental and Leasing Services                      copy shops)
459910  Pet & Pet Supplies Retailers                Wired, Wireless, Satellite, Cable 532100 Automotive Equipment Rental &     561440  Collection Agencies
459920  Art Dealers                                 & Other Program Distribution,            Leasing                           561450  Credit Bureaus
459930  Manufactured (Mobile) Home                  Resellers, Agents & Other         532210 Consumer Electronics &            561490  Other Business Support Services 
        Dealers                                     Telecommunications, & Internet           Appliances Rental                         (including repossession services, 
                                                    Service Providers)
459990  All Other Miscellaneous Retailers    Data Processing, Web Search Portals,     532281 Formal Wear & Costume Rental              court reporting, & stenotype 
        (including tobacco, candle, &        & Other Information Services             532282 Video Tape & Disc Rental                  services)
        trophy retailers)                    518210 Computing Infrastructure          532283 Home Health Equipment Rental      561500  Travel Arrangement & 
Nonstore Retailers                                  Providers, Data Processing, Web   532284 Recreational Goods Rental                 Reservation Services
various Nonstore retailers sell all types of        Hosting & Related Services        532289 All Other Consumer Goods          561600  Investigation & Security Services
        merchandise using such               519200 Web Search Portals, Libraries,           Rental                            561710  Exterminating & Pest Control 
        methods as Internet, mail-order             Archives, & Other Info. Services  532310 General Rental Centers                    Services
        catalogs, interactive television, or                                                                                   561720  Janitorial Services
        direct sales. These types of         Finance and Insurance                    532400 Commercial & Industrial           561730  Landscaping Services
        Retailers should select the PBA      Depository Credit Intermediation                Machinery & Equipment Rental & 
        associated with their primary line                                                   Leasing                           561740  Carpet & Upholstery Cleaning 
        of products sold. For example,       522110 Commercial Banking                Lessors of Nonfinancial Intangible               Services
        establishments primarily selling     522130 Credit Unions                     Assets (except copyrighted works)        561790  Other Services to Buildings & 
        prescription and non-prescription    522180 Savings Institutions & Other      533110 Lessors of Nonfinancial                   Dwellings
        drugs, select PBA code 456110               Depository Credit Intermediation         Intangible Assets (except         561900  Other Support Services 
        Pharmacies & Drug Retailers.                                                                                                   (including packaging & labeling 
                                             Nondepository Credit Intermediation             copyrighted works)
                                                                                                                                       services, & convention & trade 
Transportation and                           522210 Credit Card Issuing               Professional, Scientific, and                    show organizers)
Warehousing                                  522220 Sales Financing                   Technical Services                       Waste Management and Remediation 
Air, Rail, and Water Transportation          522291 Consumer Lending                                                           Services
481000  Air Transportation                   522292 Real Estate Credit (including     Legal Services                           562000  Waste Management & 
482110  Rail Transportation                         mortgage bankers & originators)   541110 Offices of Lawyers                        Remediation Services
483000  Water Transportation                 522299 Intl, Secondary Market, & Other   541190 Other Legal Services
Truck Transportation                                Nondepos. Credit Intermediation   Accounting, Tax Preparation,             Educational Services
484110  General Freight Trucking, Local      Activities Related to Credit             Bookkeeping, and Payroll Services        611000  Educational Services (including 
                                             Intermediation                           541211 Offices of Certified Public               schools, colleges, & universities)
484120  General Freight Trucking,            522300 Activities Related to Credit             Accountants                       Health Care and Social 
        Long-distance                               Intermediation (including loan    541213 Tax Preparation Services          Assistance
484200  Specialized Freight Trucking                brokers, check clearing, &        541214 Payroll Services
Transit and Ground Passenger                        money transmitting)                                                        Offices of Physicians and Dentists
Transportation                               Securities, Commodity Contracts, and     541219 Other Accounting Services
485110  Urban Transit Systems                Other Financial Investments and          Architectural, Engineering, and Related  621111  Offices of Physicians (except 
485210  Interurban & Rural Bus               Related Activities                       Services                                         mental health specialists)
        Transportation                       523150 Investment Banking & Securities   541310 Architectural Services            621112  Offices of Physicians, Mental 
                                                                                                                                       Health Specialists
485310  Taxi Service                                Intermediation                    541320 Landscape Architecture Services   621210  Offices of Dentists
485320  Limousine Service                    523160 Commodity Contracts               541330 Engineering Services              Offices of Other Health Practitioners
                                                    Intermediation                    541340 Drafting Services                 621310  Offices of Chiropractors
485410  School & Employee Bus                523210 Securities & Commodity            541350 Building Inspection Services      621320  Offices of Optometrists
        Transportation                              Exchanges                         541360 Geophysical Surveying &           621330  Offices of Mental Health 
485510  Charter Bus Industry                 523900 Other Financial Investment               Mapping Services                          Practitioners (except Physicians)
485990  Other Transit & Ground                      Activities (including portfolio   541370 Surveying & Mapping (except 
        Passenger Transportation                    management & investment                  Geophysical) Services
                                                    advice)

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Principal Business Activity Codes (Continued)
621340 Offices of Physical, Occupational 624310 Vocational Rehabilitation       721191 Bed & Breakfast Inns                 811420 Reupholstery & Furniture Repair
       & Speech Therapists, &                   Services                        721199 All Other Traveler                   811430 Footwear & Leather Goods 
       Audiologists                      624410 Childcare Services                     Accommodation                               Repair
621391 Offices of Podiatrists            Arts, Entertainment, and               721210 RV (Recreational Vehicle) Parks      811490 Other Personal & Household 
621399 Offices of All Other                                                            & Recreational Camps                        Goods Repair & Maintenance
       Miscellaneous Health              Recreation                             721310 Rooming & Boarding Houses,           Personal and Laundry Services
       Practitioners                     Performing Arts, Spectator Sports, and        Dormitories & Workers’ Camps         812111 Barber Shops
Outpatient Care Centers                  Related Industries                     Food Services and Drinking Places           812112 Beauty Salons
621410 Family Planning Centers           711100 Performing Arts Companies       722300 Special Food Services (including     812113 Nail Salons
621420 Outpatient Mental Health &        711210 Spectator Sports (including            food service contractors &           812190 Other Personal Care Services 
       Substance Abuse Centers                  sports clubs & racetracks)             caterers)                                   (including diet & weight reducing 
621491 HMO Medical Centers               711300 Promoters of Performing Arts,   722410 Drinking Places (Alcoholic                  centers)
621492 Kidney Dialysis Centers                  Sports, & Similar Events               Beverages)                           812210 Funeral Homes & Funeral 
621493 Freestanding Ambulatory           711410 Agents & Managers for Artists,  722511 Full Service Restaurants                    Services
       Surgical & Emergency Centers             Athletes, Entertainers, & Other 722513 Limited Service Restaurants          812220 Cemeteries & Crematories
621498 All Other Outpatient Care                Public Figures                  722514 Cafeterias, Grill buffets, & Buffets 812310 Coin-Operated Laundries & 
       Centers                           711510 Independent Artists, Writers, & 722515 Snack & Nonalcoholic Beverage               Drycleaners
Medical and Diagnostic Laboratories             Performers                             Bars                                 812320 Drycleaning & Laundry Services 
621510 Medical & Diagnostic              Museums, Historical Sites, and Similar                                                    (except Coin-Operated)
       Laboratories                      Institutions                           Other Services
Home Health Care Services                712100 Museums, Historical Sites, &    Repair and Maintenance                      812330 Linen & Uniform Supply
                                                Similar Institutions            811110 Automotive Mechanical &              812910 Pet Care (except Veterinary) 
621610 Home Health Care Services         Amusement, Gambling, and Recreation           Electrical Repair & Maintenance             Services
Other Ambulatory Health Care Services    Industries                             811120 Automotive Body, Paint, Interior,    812920 Photofinishing
621900 Other Ambulatory Health Care      713100 Amusement Parks & Arcades              & Glass Repair                       812930 Parking Lots & Garages
       Services (including ambulance     713200 Gambling Industries             811190 Other Automotive Repair &            812990 All Other Personal Services
       services & blood & organ banks)   713900 Other Amusement & Recreation           Maintenance (including oil           Religious, Grantmaking, Civic, 
Hospitals                                       Industries (including golf             change & lubrication shops & car     Professional, and Similar Organizations
622000 Hospitals                                courses, skiing facilities,            washes)                              813000 Religious, Grantmaking, Civic, 
Nursing and Residential Care Facilities         marinas, fitness centers, &     811210 Electronic & Precision                      Professional, & Similar 
623000 Nursing & Residential Care               bowling centers)                       Equipment Repair &                          Organizations (including 
       Facilities                        Accommodation and Food                        Maintenance                                 condominium and homeowners 
                                                                                811310 Commercial & Industrial                     associations)
Social Assistance                        Services                                      Machinery & Equipment (except        Other
624100 Individual & Family Services      Accommodation                                 Automotive & Electronic) Repair 
624200 Community Food & Housing, &       721110 Hotels (except Casino Hotels) &        & Maintenance                        999000 Unclassified Establishments 
       Emergency & Other Relief                 Motels                          811410 Home & Garden Equipment &                   (unable to classify)
       Services                                                                        Appliance Repair & Maintenance
                                         721120 Casino Hotels

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