Instructions for Form 5471

Department of the Treasury

Internal Revenue Service

(Rev. January 2024)

(Use with the December 2023 revision of Form 5471 and separate Schedules G-1
and Q; the December 2021 revision of separate Schedules E, H, I-1, and M; the
December 2020 revision of separate Schedules J, P, and R; and the December 2012
revision of separate Schedule O.)
Information Return of U.S. Persons
With Respect to Certain Foreign Corporations
Section references are to the Internal On page 5 of the form, the question entered “XX” on Form 5471,
Revenue Code unless otherwise noted. on Schedule G, line 18, has been Schedule G, line 14, if the answer to
Contents Page deleted and replaced with new question 22 of the table in the
Future Developments . . . . . . . . . . . . 1 questions 18a and 18b to better instructions was “Yes.”
What’s New . . . . . . . . . . . . . . . . . . 1 reflect Regulations section 1.482-2(a) Worksheet A, lines 23 and 25, were
General Instructions . . . . . . . . . . . . . 1 (2)(iii)(B). revised to add a reference to section
Purpose of Form . . . . . . . . . . . . . . . 1 On page 5, the question on 961(c).
Who Must File . . . . . . . . . . . . . . . . 1 Schedule G, line 19a, has been Worksheet A, lines 28 and 31, were
When and Where To File . . . . . . . . . . 2 reworded to better reflect Regulations amended.
Categories of Filers . . . . . . . . . . . . . 2 section 1.385-3. As a result, the
Worksheet A, line 58, was revised
Additional Filing Requirements . . . . . . 7 information requested on line 19b(1)
to more accurately reflect Regulations
Penalties . . . . . . . . . . . . . . . . . . . . 8 has also been reworded.
Other Reporting Requirements . . . . . . 8 section 1.951-1(b)(1)(ii)(A).
Specific Instructions . . . . . . . . . . . . . 9
Changes to separate Sched- The instructions for Worksheet A,
Schedule B . . . . . . . . . . . . . . . . . 12
ule G-1. Line 6b was reworded to line 1a, were clarified by adding a
Schedule C . . . . . . . . . . . . . . . . . 13 better reflect Regulations section reference to the limitation on section
Schedule F . . . . . . . . . . . . . . . . . 13 1.482-7A. 954(c)(6) in Regulations section
Schedule G . . . . . . . . . . . . . . . . . 13 Changes to separate Schedule Q. 1.245A-5.
Schedule I . . . . . . . . . . . . . . . . . . 19 On page 1 of the schedule, line 1f now A new instruction for Worksheet A,
Instructions for Separate requests “Other Foreign Personal lines 13b, 13d, 13e, 14b, 15b, 16b,
Schedules . . . . . . . . . . . . . . . 29 Holding Company Income.” Filers are 18b, and 19b, was added regarding
Schedule E . . . . . . . . . . . . . . . . . 29 directed to see the instructions for an allocation and apportionment of
Schedule E-1 . . . . . . . . . . . . . . . . 32 attachment requirement for line 1f.
Schedule G-1 . . . . . . . . . . . . . . . . 34
expenses to better reflect Regulations
Schedule H . . . . . . . . . . . . . . . . . 35 On page 4 of the schedule, the section 1.954-1(c)(1)(i), (ii), and (iv).
Schedule I-1 . . . . . . . . . . . . . . . . 37 following lines have been shaded A new Worksheet H-1 has been
Schedule J . . . . . . . . . . . . . . . . . 39 under column (xv), Loss Allocation. added to these instructions. Also, new
Schedule M . . . . . . . . . . . . . . . . . 42 • Lines 3, 3(1), and 3(2), pertaining to Worksheet H-1 Instructions have been
Schedule O . . . . . . . . . . . . . . . . . 43 the Tested Income Group. provided.
Schedule P . . . . . . . . . . . . . . . . . 43 • Lines 4, 4(1), and 4(2), pertaining to In the instructions for separate
Schedule Q . . . . . . . . . . . . . . . . . 44 the Residual Income Group. Schedule Q, line 1, the attachment
Schedule R . . . . . . . . . . . . . . . . . 48 Changes to these instructions. requirement for line 1f has been
Principal Business Activity Codes . . . 50 These instructions have been updated clarified.
for the aforementioned changes to
Future Developments
For the latest information about
Form 5471 and separate Schedule Q.
No changes were needed to the
General Instructions
developments related to Form 5471, instructions for separate
its schedules, and its instructions, Purpose of Form
Schedule G-1.
such as legislation enacted after they Form 5471 is used by certain U.S.
In addition, the following changes persons who are officers, directors, or
were published, go to IRS.gov/
have been made. shareholders in certain foreign
Form5471.
The table of questions for Form corporations. The form and schedules
What’s New 5471, Schedule G, line 14, has been are used to satisfy the reporting
amended as follows. If the answer to requirements of sections 6038 and
Changes to Form 5471. On page 1 question 22 of that table is “Yes,” for 6046, and the related regulations.
of the form, new line 1b(3) requests tax year 2023, affected Form 5471
the previous reference ID number(s) filers will enter code “PRS” on Form Who Must File
of the foreign corporation, if any. 5471, Schedule G, line 14. For tax Generally, all U.S. persons described
year 2022, affected Form 5471 filers in Categories of Filers below must

Jan 25, 2024 Cat. No. 49959G

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

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

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

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

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

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

meaning of section 927(d)(6), as in FSCs. Category 4 filers are not 4. An estate or trust that is not a
effect before repeal); and required to file a Form 5471 (in order foreign estate or trust, as defined in
4. Any deductions that are to satisfy the requirements of section section 7701(a)(31).
apportioned or allocated to the 6038) if the FSC has filed a Form See section 957(c) for exceptions.
nonexempt foreign trade income 1120-FSC. See Temporary
In general, a CFC is a foreign
described above. Regulations section 1.921-1T(b)(3).
corporation that has U.S.
However, these filers are required to
• Category 4 filers who are file Form 5471 for an FSC, regardless
shareholders that own (directly,
shareholders of an FSC are subject to indirectly, or constructively, within the
of whether it has filed Form
the subpart F rules for: meaning of section 958(a) and (b)) on
1120-FSC, if the filer has inclusions
1. All other types of FSC income any day of the tax year of the foreign
with respect to the FSC under section
(including section 923(a)(2) corporation, more than 50% of:
951(a) (as described above).
nonexempt income within the 1. The total combined voting
meaning of section 927(d)(6), as in Other filing exceptions. Certain power of all classes of its voting stock,
effect before its repeal); other filing exceptions apply to all or
categories of filers. See Additional
2. Investment income and carrying Filing Exceptions, later. 2. The total value of the stock of
charges (as defined in section 927(c) the corporation.
and (d)(1), as in effect before its Category 5 Filers
For purposes only of taking into
repeal); and In general, a Category 5 filer is a account income described in section
3. All other FSC income that is not person who was a U.S. shareholder 953(a) (relating to insurance income),
foreign trade income or investment (defined below) that owned stock in a a CFC also includes a foreign
income or carrying charges. foreign corporation that was a CFC corporation that is described in
(defined below) at any time during the section 957(b); and for purposes only
Category 4 Filers—Exceptions foreign corporation’s tax year ending of taking into account related person
From Filing with or within the U.S. shareholder’s insurance income, a CFC includes a
Certain constructive owners. tax year, and who owned that stock on foreign corporation described in
the last day in that year in which the
• A Category 4 filer does not have to section 953(c)(1)(B).
file Form 5471 if all of the following foreign corporation was a CFC. There
conditions are met. are three different types of Category 5
Category 5a Filer
filers, each described below:
1. The Category 4 filer does not Category 5a filers, Category 5b filers,
own a direct interest in the foreign A Category 5a filer is a Category 5
and Category 5c filers.
corporation. filer that is not a Category 5b or 5c
Except as otherwise provided in the filer.
2. The Category 4 filer is required
to furnish the information requested instructions for each type of Category
solely because of constructive 5 filer below, the following definitions Category 5b Filer
ownership (as determined under apply for purposes of Category 5.
Regulations section 1.958-2, U.S. shareholder. For purposes of A person is a Category 5b filer if they
1.6038-2(c), or 1.6046-1(i)) from Category 5, a U.S. shareholder is a are an unrelated section 958(a) U.S.
another U.S. person. U.S. person (defined below) who: shareholder (defined below) of a
foreign-controlled CFC (defined
3. The U.S. person through which 1. Owns (directly, indirectly, or below). This type of Category 5 filer
the Category 4 filer constructively constructively, within the meaning of implements the relief for certain
owns an interest in the foreign section 958(a) and (b)) 10% or more Category 5 filers announced in
corporation files Form 5471 to report of the total combined voting power or section 8.02 of Rev. Proc. 2019-40,
all of the information required of the value of shares of all classes of stock 2019-43 I.R.B. 982.
Category 4 filer. of a CFC; or
Unrelated section 958(a) U.S.
• A Category 4 filer does not have to 2. Owns (either directly or
shareholder. For purposes of
file Form 5471 if it: indirectly, within the meaning of
Category 5b, an unrelated section
section 958(a)) any stock of a CFC
1. Does not own a direct or 958(a) U.S. shareholder is a U.S.
(as defined in sections 953(c)(1)(B)
indirect interest in the foreign shareholder with respect to a
and 957(b)), unless the foreign
corporation, and foreign-controlled CFC who:
corporation has an effective section
2. Is required to file Form 5471 953(c)(3)(C) election in place for the 1. Owns, within the meaning of
solely because of constructive tax year. section 958(a), stock of a
ownership from a nonresident alien. foreign-controlled CFC; and
U.S. person. For purposes of 2. Is not related (using principles
No statement is required to be
Category 5, a U.S. person is: of section 954(d)(3)) to the
attached to the tax return of a
Category 4 filer claiming either 1. A citizen or resident of the foreign-controlled CFC.
constructive ownership exception. United States;
Foreign-controlled CFC. For
See Regulations section 1.6038-2(j) 2. A domestic partnership;
purposes of Category 5b, a
(2) and (3), and Regulations section 3. A domestic corporation; or foreign-controlled CFC is a foreign
1.6038-2(l) for additional information.
corporation that is a CFC that would
Instructions for Form 5471 (Rev. 01-2024) 5
not be a CFC if the determination 1. All other types of FSC income 5.02 of Notice 2018-13, 2018-6 I.R.B.
were made without applying (including section 923(a)(2) 341, for additional information.
subparagraphs (A), (B), and (C) of nonexempt income, within the
Unrelated constructive U.S. share-
section 318(a)(3) so as to consider a meaning of section 927(d)(6), as in holder. A Category 5 filer does not
U.S. person as owning stock that is effect before its repeal);
have to file Form 5471 if all of the
owned by a foreign person. 2. Investment income and carrying following conditions are met.
charges (as defined in section 927(c)
Category 5c Filer 1. The foreign corporation is a
and (d)(1), as in effect before its foreign-controlled CFC.
repeal); and
A person is a Category 5c filer if they 2. The filer is a U.S. shareholder
3. All other FSC income that is not
are a related constructive U.S. that does not own stock, within the
foreign trade income or investment
shareholder (defined below) of a meaning of section 958(a), in the
income or carrying charges.
foreign-controlled CFC (defined foreign-controlled CFC.
below). This type of Category 5 filer Category 5 Filers—Exceptions 3. The filer is not related, using
implements the relief for certain From Filing principles of section 954(d)(3), to the
Category 5 filers announced in foreign-controlled CFC.
section 8.03 of Rev. Proc. 2019-40, Certain constructive owners.
2019-43 I.R.B. 982. • A Category 5 filer does not have to See section 8.04 of Rev. Proc.
file Form 5471 if all of the following 2019-40, 2019-43 I.R.B. 982, for
Related constructive U.S. share- conditions are met. additional information.
holder. For purposes of Category 5c,
a related constructive U.S. 1. The Category 5 filer does not FSCs. Category 5 filers are not
shareholder is a U.S. shareholder with own a direct interest in the foreign required to file a Form 5471 (in order
respect to a foreign-controlled CFC corporation. to satisfy the requirements of section
who: 2. The Category 5 filer is required 6038) if the FSC has filed a Form
to furnish the information requested 1120-FSC. See Temporary
1. Does not own, within the
solely because of constructive Regulations section 1.921-1T(b)(3).
meaning of section 958(a), stock of
ownership (as determined under However, these filers are required to
the foreign-controlled CFC; and
Regulations section 1.958-2, file Form 5471 for an FSC, regardless
2. Is related (using principles of 1.6038-2(c), or 1.6046-1(i)) from of whether it has filed Form
section 954(d)(3)) to the another U.S. person. 1120-FSC, if the filer has inclusions
foreign-controlled CFC. with respect to the FSC under section
3. The U.S. person through which
the Category 5 filer constructively 951(a) (as described above).
Foreign-controlled CFC. For
purposes of Category 5c, the term owns an interest in the foreign Other filing exceptions. Certain
“foreign-controlled CFC” has the same corporation files Form 5471 to report other filing exceptions apply to all
meaning as defined in Category 5b all of the information required of the categories of filers. See Additional
Filer, earlier. Category 5 filer. Filing Exceptions next.
Additional Information for • A Category 5 filer does not have to Additional Filing
Category 5 Filers file Form 5471 if it:
1. Does not own a direct or
Exceptions
Foreign sales corporations (FSCs). indirect interest in the foreign Multiple filers of same information.
• Category 5 filers who are corporation, and With respect to any category of filer,
shareholders of an FSC are not one person may file Form 5471 and
subject to the subpart F rules with 2. Is required to file Form 5471
solely because of constructive the applicable schedules for other
respect to the FSC for: persons who have the same filing
ownership from a nonresident alien.
1. Exempt foreign trade income; requirements. If you and one or more
2. Deductions that are No statement is required to be other persons are required to furnish
apportioned or allocated to exempt attached to the tax return of a information for the same foreign
foreign trade income; Category 5 filer claiming either corporation for the same period, a
constructive ownership exception. joint information return that contains
3. Nonexempt foreign trade See Regulations section 1.6038-2(j)
income (other than section 923(a)(2) the required information may be filed
(2) and (3), and Regulations section with your tax return or with the tax
nonexempt income, within the 1.6038-2(l) for additional information.
meaning of section 927(d)(6), as in return of any one of the other persons.
effect before repeal); and No section 958(a) U.S. sharehold- For example, a U.S. person described
er. A Category 5 filer does not have to in Category 5 may file a joint Form
4. Any deductions that are 5471 with a Category 4 filer or another
apportioned or allocated to the file Form 5471 if no U.S. shareholder
(including the Category 5 filer) owns, Category 5 filer; similarly, a U.S.
nonexempt foreign trade income person described in Category 5b may
described above. within the meaning of section 958(a),
stock in the CFC on the last day in the file a joint Form 5471 with a Category
• Category 5 filers who are year of the foreign corporation in 4 or 5a filer or another Category 5b
shareholders of an FSC are subject to which it was a CFC and the CFC is a filer (but not a Category 5c filer).
the subpart F rules for: foreign-controlled CFC. See section However, for Category 3 filers, the
required information may only be filed

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

by another person having an equal or CFC is considered to have types of transactions that the IRS has
greater interest (measured in terms of participated in a reportable determined to be a tax avoidance
value or voting power of the stock of transaction under the rules of transaction and identified by notice,
the foreign corporation). Regulations section 1.6011-4(c)(3)(i) regulation, or other published
The person that files Form 5471 (G), the shareholder is required to guidance as a listed transaction.
must complete Form 5471 in the disclose information for each 2. Any transaction offered under
manner described in the instructions reportable transaction. Form 8886, conditions of confidentiality for which
for item H. All persons identified in Reportable Transaction Disclosure the corporation (or a related party)
item H must attach a statement to Statement, must be filed for each tax paid an advisor a fee of at least
their income tax return that includes year indicated in Regulations section $250,000.
the information described in the 1.6011-4(c)(3)(i)(G). The following are
3. Certain transactions for which
instructions for item H. See reportable transactions.
the corporation (or a related party)
Regulations section 1.6038-2(j)(1) 1. Any listed transaction, which is has contractual protection against
and (3) for additional information. a transaction that is the same as or disallowance of the tax benefits.
substantially similar to one of the
Domestic corporations.
Shareholders are not required to file
Form 5471 for a foreign insurance Filing Requirements for Categories of Filers
company that has elected (under
section 953(d)) to be treated as a Table of Required Information
domestic corporation and has filed a
U.S. income tax return for its tax year Category of Filer
Required Information*
under that provision. See Rev. Proc. 1a 1b 1c 2 3 4 5a 5b 5c
2003-47, 2003-28 I.R.B. 55, available
The identifying information on page
at IRS.gov/irb/ 1 of Form 5471 above Schedule A;
2003-28_IRB#RP-2003-47, for see Specific Instructions
procedural rules regarding the
Schedule A
election under section 953(d).
Schedule B, Part I
Additional Filing Schedule B, Part II
Requirements
Schedules C and F
Section 338 election. If a section
338 election is made with respect to a Separate Schedule E 1 2 1 2

qualified stock purchase of a foreign

Schedule E-1 (included with
target corporation for which a Form 1 1
separate Schedule E)
5471 must be filed:
• A purchaser (or its U.S. Schedule G
shareholder) must attach a copy of
Separate Schedule G-1
Form 8883, Asset Allocation
Statement Under Section 338, to the Separate Schedule H
first Form 5471 for the new foreign
target corporation (see the Schedule I
Instructions for Form 8883 for details);
Separate Schedule I-1
• A seller (or its U.S. shareholder)
must attach a copy of Form 8883 to Separate Schedule J
the last Form 5471 for the old foreign
target corporation; Separate Schedule M
• A U.S. shareholder that files a
Separate Schedule O, Part I
section 338 election on behalf of a
foreign purchasing corporation that is Separate Schedule O, Part II
a CFC pursuant to Regulations
section 1.338-2(e)(3) must attach a Separate Schedule P
copy of Form 8023, Elections Under
Section 338 for Corporations Making Separate Schedule Q
Qualified Stock Purchases, to the Separate Schedule R
Form 5471 filed with respect to the
purchasing corporation for the tax * See also Additional Filing Requirements.
year that includes the acquisition date 1
Schedules E and E-1 are required for an Unrelated section 958(a) U.S. shareholder. only if the filer claims
(see the Instructions for Form 8023 for deemed paid foreign income taxes of the foreign-controlled section 965 SFC or foreign-controlled CFC
details). under section 960 for the filer’s tax year. See Rev. Proc. 2019-40 for more details.

Reportable transaction disclosure 2

Related constructive U.S. shareholder. only need to complete Schedule E (they can leave Schedule E-1
statement. If a U.S. shareholder of a blank). See Rev. Proc. 2019-40 for more details.

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

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

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

to which the tax relates in accordance Specifications for Substitute Forms 362(e)(2)(C) to limit the transferor's
with the rules of section 986(a). The and Schedules, which reprints the basis in the stock received instead of
average exchange rate is 108.8593 most recent applicable revenue the transferee's basis in the
Japanese Yen to one U.S. dollar or procedure. Pub. 1167 is available at transferred property. The election is
(0.009184) U.S. dollar to one IRS.gov/Pub. 1167. made by a statement as provided in
Japanese Yen. The foreign Regulations section 1.362-4(d)(3).
corporation divides 30,255,400 Yen by
Dormant Foreign Corporations
Rev. Proc. 92-70, 1992-2 C.B. 435, Do not attach the statement
108.8593 to determine the U.S. dollar described above to Form
amount to enter in column (l) of provides a summary filing procedure ! 5471.
Schedule E, Part I, Section 1, line 1. for filing Form 5471 for a dormant CAUTION

Line 1 of Schedule E, Part I, Section foreign corporation (defined in section

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

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

or within your tax year. When filing has a P.O. box, show the box number information, see the Instructions for
Schedule O, report acquisitions, instead. Form 8938, generally, and in
dispositions, and organizations or particular, Duplicative Reporting and
Foreign address. Enter the
reorganizations that occurred during the specific instructions for Part IV,
information in the following order: city,
your tax year. Excepted Specified Foreign Financial
province or state, and country. Follow
Assets.
Section 898 specified foreign cor- the country's practice for entering the
poration (SFC). The annual postal code, if any. Do not abbreviate Item F—Alternative Information
accounting period of an SFC (as the country name. Under Rev. Proc. 2019-40
defined in section 898) is generally
required to be the tax year of the
Item A—Identifying Number Check the item F checkbox if Form
The identifying number of an 5471 has been completed using
corporation's majority U.S.
individual is his or her social security alternative information (as defined in
shareholder. If there is more than one
number (SSN). The identifying section 3.01 of Rev. Proc. 2019-40).
majority shareholder, the required tax
year will be the tax year that results in number of all others is their EIN. If a Section 5 of Rev. Proc. 2019-40
the least aggregate deferral of income U.S. corporation that owns stock in a provides a safe harbor for determining
to all U.S. shareholders of the foreign foreign corporation is a member of a certain items, including taxable
corporation. consolidated group, list the common income and E&P, of certain CFCs
parent as the person filing the return based on alternative information.
For these purposes, section 898(b)
and enter its EIN in item A. Specifically, in the case of a
defines an SFC as any foreign
corporation: Item B—Category of Filer foreign-controlled CFC with respect to
which there is no related section
1. That is treated as a CFC for any Complete item B to indicate the 958(a) U.S. shareholder, if information
purpose under subpart F, and category or categories that describe satisfying the requirements of
2. In which more than 50% of the the person filing this return. If more Regulations section 1.952-2(a), (b),
total voting power or value of all than one category applies, check all and (c)(2) and section 964 and the
classes of stock of the corporation is boxes that apply. See Categories of regulations thereunder is not readily
treated as owned by a U.S. Filers, earlier. available to an unrelated section
shareholder. 958(a) U.S. shareholder or an
Note. If you satisfy the requirements
For more information, see section of both Category 4 and Category 5a unrelated constructive U.S.
898 and Rev. Proc. 2006-45, 2006-45 filers, only check the box for Category shareholder with respect to the
I.R.B. 851, available at IRS.gov/irb/ 4 and leave the box for Category 5a foreign-controlled CFC, an amount
2006-45_IRB#RP-2006-45, as blank. reported on a Form 5471 may be
modified by Rev. Proc. 2007-64, determined by the unrelated section
2007-42 I.R.B. 818, available at Item C—Percentage of Voting 958(a) U.S. shareholder or the
IRS.gov/irb/ Stock Owned unrelated constructive U.S.
2007-42_IRB#RP-2007-64. Enter the total percentage of the shareholder, as applicable, on the
foreign corporation's voting power you basis of alternative information
Name of Person Filing This owned directly, indirectly, or (without adjustments other than those
Return constructively at the end of the described in section 3.01(b) and 3.10
The name of the person filing Form corporation's annual accounting of the revenue procedure) with
5471 is generally the name of the U.S. period. respect to the foreign-controlled CFC.
person described in the applicable See section 3 of Rev. Proc. 2019-40
category or categories of filers (see Item D—Final Year for definitions of terms.
Categories of Filers, earlier). However, Check the item D checkbox only if this Section 6 of Rev. Proc. 2019-40
in the case of a consolidated return, is the final year of the foreign provides a safe harbor for determining
enter the name of the U.S. parent in corporation's existence as a certain items of certain SFCs based
the field for “Name of person filing this corporation for federal tax purposes, on alternative information. Specifically,
return.” Be sure to list each U.S. for example, if a reorganization has in the case of an SFC, other than
shareholder of the foreign corporation occurred, a complete liquidation has either a foreign-controlled CFC with
in Schedule B, Part I. occurred, or an election to treat the respect to which there is no related
foreign corporation as a disregarded section 958(a) U.S. shareholder or a
Name change. If the name of either entity has been made. If this item D is
the person filing the return or the U.S. controlled CFC, if information
checked, complete Schedule O. satisfying the requirements of section
corporation whose activities are being
reported changed within the past 3 Item E—Excepted Specified 964 and the regulations thereunder is
years, show the prior name(s) in Foreign Financial Assets not readily available to an unrelated
parentheses after the current name. section 958(a) U.S. shareholder or an
Check the item E checkbox if any unrelated constructive U.S.
Address excepted specified foreign financial shareholder with respect to the SFC,
assets are reported on Form 5471. If an amount reported on a Form 5471
Include the suite, room, or other unit
this is the case, you do not have to may be determined by the unrelated
number after the street address. If the
also report these assets on Form section 958(a) U.S. shareholder or the
post office does not deliver mail to the
8938. It is only necessary to complete unrelated constructive U.S.
street address and the U.S. person
Form 8938, Part IV, line 17. For more shareholder, as applicable, on the

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

basis of alternative information Item H—Person(s) on Whose Exception. If the person who is filing
(without adjustments other than those Behalf This Information Return Form 5471 on behalf of others is
described in sections 3.01(b) and Is Filed married to a person identified in item
3.10 of the revenue procedure) with H and they are filing Form 1040 jointly,
respect to the SFC. See section 3 of One person may file Form 5471 and
the applicable schedules for other the statement described above does
Rev. Proc. 2019-40 for definitions of not have to be attached to the jointly
terms. persons who have the same filing
requirements. See Multiple filers of filed Form 1040.
Item G—Alternative Information same information, earlier. The person All persons identified in item H
Code that files the required information on ! must complete a separate
If the item F checkbox is checked, behalf of other persons must CAUTION Schedule P (Form 5471) if the

enter the applicable code from the list complete a joint Form 5471 according person is a U.S. shareholder
provided below. to the applicable column(s) of the described in Category 1a, 1b, 4, 5a, or
Filing Requirements for Categories of 5b. In such a case, the Schedule P
Filers, earlier. This includes must be attached to the statement
Audited separate-entity financial
statements of the foreign corporation that completing item H on page 1 of the described above.
01 are prepared in accordance with U.S. form. When completing item H with
generally accepted accounting principles respect to members of a consolidated Item 1b(2)—Reference ID
(U.S. GAAP). group, identify only the direct owners Number
Audited separate-entity financial in item H (constructive owners are not A reference ID number (defined
statements of the foreign corporation that required to be listed). below) is required in item 1b(2) only in
02
are prepared on the basis of international A separate Schedule I must be filed cases where no EIN was entered in
financial reporting standards (IFRS).
for each person described in Category item 1b(1) for the foreign corporation.
Audited separate-entity financial 4, 5a, or 5b. For each Category 4, 5a, However, filers are permitted to enter
statements of the foreign corporation that or 5b filer that is required to file a both an EIN in item 1b(1) and a
are prepared on the basis of the generally Schedule I, send a copy of their reference ID number in item 1b(2). If
03 accepted accounting principles of the
separate Schedule I to them to assist applicable, enter the reference ID
jurisdiction in which the foreign
corporation is organized (“local-country them in completing their tax return. number you have assigned to the
GAAP”). foreign corporation identified in item
A separate Worksheet H-1 must be
1a.
Unaudited separate-entity financial attached for each person described in
04
statements of the foreign corporation that Category 4, 5a, 5b, or 5c. For each A “reference ID number” is a
are prepared in accordance with U.S. Category 4, 5a, 5b, or 5c filer that is number established by or on behalf of
GAAP. required to file Worksheet H-1, send a the U.S. person identified at the top of
Unaudited separate-entity financial copy of their separate Worksheet H-1 page 1 of the form that is assigned to
05 statements of the foreign corporation that to them to assist them in completing a foreign corporation with respect to
are prepared on the basis of IFRS. their tax return. which Form 5471 reporting is
Unaudited separate-entity financial required. These numbers are used to
statements of the foreign corporation that Note. New Worksheet H-1 may be uniquely identify the foreign
06 found later in these instructions. See
are prepared on the basis of local-country corporation in order to keep track of
GAAP. Worksheet H-1 and Worksheet H-1 the corporation from tax year to tax
Separate-entity records used by the
Instructions, later. year.
07
foreign corporation for tax reporting. Filing requirements for persons The reference ID number must
Separate-entity records used by the identified in item H. Except for meet the requirements set forth below.
foreign corporation for internal members of the filer's consolidated
08
management controls or regulatory or return group, all persons identified in Note. Because reference ID numbers
other similar purposes. item H must attach a statement to are established by or on behalf of the
their tax returns that includes the U.S. person filing Form 5471, there is
following information. no need to apply to the IRS to request
Information described in a code • The name, address, and EIN (or a reference ID number or for
listed above qualifies as alternative reference ID number) of the foreign permission to use these numbers.
information only if information corporation(s).
described in any preceding code is • A statement that their filing Note. The reference ID number
not “readily available” (as defined in requirements with respect to the assigned to a foreign corporation on
section 3.04 of Rev. Proc. 2019-40). foreign corporation(s) have been or Form 5471 generally has relevance
For example, information described in will be satisfied. only on Form 5471, its schedules, and
code 03 above qualifies as alternative • The name, address, and identifying any other form that is attached to or
information only if information number of the taxpayer on the return associated with Form 5471, and
described in codes 01 and 02 is not with which the information was or will generally should not be used with
readily available. be filed. respect to that foreign corporation on
• The IRS Service Center where the any other IRS forms. However, the
For more information, see Rev. return was or will be filed. If the return foreign corporation’s reference ID
Proc. 2019-40. was or will be filed electronically, enter number should also be entered on
“e-file.” Form 8858 if the foreign corporation is
Instructions for Form 5471 (Rev. 01-2024) 11
listed as a tax owner of an FDE or FB foreign corporation to have an EIN for standard. These codes are available
on Form 8858. See the instructions for this election. For the first year that at six-group.com/en/products-
Form 8858, line 3c(2), for more Form 5471 is filed after an entity services/financial-information/data-
information. Also, if a U.S. shareholder classification election is made on standards.html#scrollTo=currency-
is required to file Schedule A (Form behalf of the foreign corporation on codes. Click on List One (XLS).
8992) or Schedule B (Form 8992) with Form 8832, the new EIN must be
Regulations sections 1.6038-2(h)
respect to the CFC, the reference ID entered in item 1b(1) of Form 5471
and 1.6046-1(g) require that certain
number on Form 5471 and the and the old reference ID number must
amounts be reported in U.S. dollars
reference ID number used on be entered in item 1b(2). In
and/or in the foreign corporation's
Schedule A (Form 8992) or subsequent years, the Form 5471 filer
functional currency. The specific
Schedule B (Form 8992) for that CFC may continue to enter both the EIN in
instructions for the affected schedules
must be the same. item 1b(1) and the reference ID
state these requirements.
Requirements. The reference ID number in item 1b(2), but must enter
number that is entered in item 1b(2) at least the EIN in item 1b(1). Special rules apply for foreign
must be alphanumeric (defined below) You must correlate the reference ID corporations that use the U.S. dollar
and no special characters or spaces numbers as follows: Enter the new approximate separate transactions
are permitted. The length of a given reference ID number in item 1b(2) and method of accounting (DASTM) under
reference ID number is limited to 50 enter the previous reference ID Regulations section 1.985-3. See
characters. number(s) in item 1b(3). If there is Schedule C, Schedule F, and
more than one old reference ID Schedule H, later.
The same reference ID number
number, you must enter a space
must be used consistently from tax
between each such number. As Schedule B
year to tax year with respect to a given
indicated above, the length of a given
foreign corporation. If for any reason a Note. If any person (including the
reference ID number is limited to 50
reference ID number falls out of use filer) is both a U.S. shareholder and a
characters and each number must be
(for example, the foreign corporation direct shareholder of the foreign
alphanumeric and no special
no longer exists due to disposition or corporation, that person’s information
characters are permitted.
liquidation), the reference ID number should be provided in both
used for that foreign corporation Note. This correlation requirement Schedule B, Part I and Part II.
cannot be used again for another applies only to the first year the new
foreign corporation for purposes of Part I
reference ID number is used and it
Form 5471 reporting. Category 3 and 4 filers must complete
applies only on Form 5471, page 1,
Schedule B, Part I, for U.S. persons
For these purposes, the term items 1b(2) and 1b(3). On all separate
that owned (at any time during the
“alphanumeric” means the entry can schedules for Form 5471, please
annual accounting period), directly or
be alphabetical, numeric, or any enter only the current reference ID
indirectly through foreign entities, 10%
combination of the two. number in the applicable entry space.
or more of the total combined voting
Taxpayers no longer have the Item 1b(3)—Previous Reference power of all classes of stock entitled
option of entering “FOREIGNUS” or to vote of the foreign corporation, or
“APPLIED FOR” in a column that
ID Number(s), if Any
10% or more of the total value of
requests an EIN or reference ID See Correlation issues, earlier.
shares of all classes of stock of the
number with respect to a foreign Items 1f and 1g—Principal foreign corporation.
entity. Instead, if the foreign entity
Business Activity A person that is both a category 3
does not have an EIN, the taxpayer
must enter a reference ID number that Enter the principal business activity and category 5 filer because it is
uniquely identifies the foreign entity. code number and the description of treated as a U.S. shareholder under
the activity from the list at the end of section 953(c)(1)(A) with respect to
Correlation issues. There are some these instructions. the foreign corporation must complete
situations that warrant correlation of a Schedule B, Part I, for U.S. persons
new reference ID number with a Effective beginning with tax
year 2022, several changes that owned (on the last day of the
previous reference ID number when !
CAUTION were made to the principal
foreign corporation’s tax year), directly
assigning a new reference ID number or indirectly through foreign entities,
to a foreign corporation. For example: business activities and codes listed at
the end of these instructions. See the any of the foreign corporation's
• In the case of a merger or outstanding stock.
acquisition, a Form 5471 filer must revised list before entering a six-digit
use a reference ID number that code and the description of the Column (e). Enter each
correlates the previous reference ID activity on page 1, items 1f and 1g. shareholder's allocable percentage of
number with the new reference ID the foreign corporation's subpart F
number assigned to the foreign Item 1h—Functional Currency income.
corporation; or The foreign corporation's functional Part II
• In the case of an entity currency is determined under section
classification election that is made on 985. Enter the applicable Category 1a, 1c, 3, 4, 5a, and 5c filers
behalf of a foreign corporation on three-character alphabet code for the must complete Part II.
Form 8832, Regulations section foreign corporation's functional Report the direct shareholders of
301.6109-1(b)(2)(v) requires the currency using the ISO 4217 the foreign corporation. In the case of

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

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

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

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

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

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

Form 5471, Schedule G, Line 14

Question See Worksheet A in If “Yes,” Code If “Yes,” content of

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

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

Form 5471, Schedule G, Line 14 (continued)

Question See Worksheet A in If “Yes,” Code If “Yes,” content

the Schedule I corresponding description of statement to be
instructions code to enter attached to Form
on Schedule G, 5471
line 14
9 During the tax year, was the CFC a securities dealer within the In other words, are SD Securities Amount excluded
meaning of section 475? If so, did the foreign corporation any amounts dealers
derive any interest or dividend or equivalent amount described described in section
in section 954(c)(1)(E) or (G) from any transaction entered into 954(c)(2)(C)(ii)
in the ordinary course of its trade or business as a securities excluded from line 1a
dealer? of Worksheet A?
10 During the tax year, did the CFC receive dividends* or In other words, are SCDI Same country Amount excluded
interest** from a related person that (a) is a corporation created any amounts dividends/
or organized under the laws of the same country under the described in section interest
laws of which the CFC is created or organized, and (b) has a 954(c)(3)(A)(i)
substantial part of its assets used in its trade or business excluded from line 1a
located in the same foreign country? of Worksheet A?
*Dividends (other than dividends with respect to any stock,
which are attributable to E&P of the distributing corporation
accumulated during any period during which the person
receiving such dividend did not hold such stock directly or
indirectly through a chain of one or more subsidiaries each of
which meets requirements (a) and (b)).
**Interest (other than interest that reduces the payor's subpart
F income or creates or increases a deficit that may reduce the
subpart F income of the payor or another CFC).
11 During the tax year, did the CFC receive, from a corporation In other words, are SCRR Same country Amount excluded
that is a related person, rents or royalties* for the use of, or any amounts rents/royalties
privilege of using, property within the country under the laws of described in section
which the CFC is created or organized? 954(c)(3)(A)(ii)
*Rents or royalties (other than rents or royalties that reduce the excluded from line 1a
payor's subpart F income or create or increase a deficit that of Worksheet A?
may reduce the subpart F income of the payor or another CFC).
12 During the tax year, did the CFC receive or accrue from a In other words, are LT Look through Amount excluded
related CFC dividends, interest (including factoring income any amounts
treated as income equivalent to interest for purposes of section excluded from line 1a
954(c)(1)(E)), rents, or royalties* attributable or properly of Worksheet A by
allocable to income of the related person which is neither reason of the
subpart F income nor income treated as effectively connected look-through rule
with the conduct of a trade or business in the United States? described in section
*Interest, rents, or royalties (other than interest, rents, or 954(c)(6)?
royalties that create or increase a deficit that may reduce the
subpart F income of the payor or another CFC).
13 During the tax year, did the CFC derive income (either directly In other words, are AC Agricultural Amount excluded
or through a branch or similar establishment, for example, a any amounts commodities
disregarded entity) in connection with the purchase or sale excluded from line 3
from, to, or on behalf of a related person, of agricultural of Worksheet A by
commodities not grown in the United States in commercially reason of the special
marketable quantities? rule in Regulations
section 1.954-3(a)(1)
(ii)?
14 During the tax year, did the CFC derive income (either directly In other words, are SCM Same country Amount excluded
or through a branch or similar establishment, for example, a any amounts that are manufacturing
disregarded entity) in connection with the purchase or sale derived in connection
from, to, or on behalf of a related person, of personal property with property that
manufactured in the same country under the laws of which the does not satisfy
CFC is created or organized? section 954(d)(1)(A)
excluded from line 3
of Worksheet A (that
is, income excluded
by reason of
Regulations section
1.954-3(a)(2))?

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

Form 5471, Schedule G, Line 14 (continued)

Question See Worksheet A in If “Yes,” Code If “Yes,” content

the Schedule I corresponding description of statement to be
instructions code to enter attached to Form
on Schedule G, 5471
line 14
15 During the tax year, did the CFC derive income (either directly In other words, are SCSU Same country Amount excluded
or through a branch or similar establishment, for example, a any amounts that are sales/use
disregarded entity) in connection with the purchase or sale derived in connection
from, to, or on behalf of a related person, of personal property with property that
purchased or sold for use or consumption in the same country does not satisfy
under the laws of which the CFC is created or organized? section 954(d)(1)(B)
excluded from line 3
of Worksheet A (that
is, income excluded
by reason of
Regulations section
1.954-3(a)(3))?
16 During the tax year, did the CFC derive income (either directly In other words, are PM Physical Amount excluded
or through a branch or similar establishment, for example, a any amounts manufacturing
disregarded entity) in connection with the purchase or sale excluded from line 3
from, to, or on behalf of a related person, of personal property of Worksheet A by
manufactured by the CFC within the meaning of Regulations reason of
section 1.954-3(a)(4)(ii) or (iii)? Regulations section
1.954-3(a)(4)(ii) or
(iii)?
17 During the tax year, did the CFC derive income (either directly In other words, are SC Substantial Amount excluded
or through a branch or similar establishment, for example, a any amounts contribution
disregarded entity) in connection with the purchase or sale excluded from line 3
from, to, or on behalf of a related person, of personal property of Worksheet A by
manufactured by the CFC within the meaning of Regulations reason of
section 1.954-3(a)(4)(iv)? Regulations section
1.954-3(a)(4)(iv)?
18 During the tax year, did the CFC derive income through the In other words, are BR Branch Amount excluded
conduct of any manufacturing or sales activities (including any amounts
mere passage of title) through a branch or similar excluded from line 3
establishment (such as a disregarded entity of the CFC) that of Worksheet A by
would have been foreign base company sales income reason of
described in section 954(d) except that either (a) the branch disregarding a
or other similar establishment was not treated as a wholly branch or similar
owned subsidiary separate from the CFC under section 954(d) establishment
(2) and the regulations, or (b) the income is not foreign base (including a
company sales income after the application of Regulations disregarded entity) of
section 1.954-3(b)(2)(ii)(e)? the CFC as separate
from the CFC?
19 During the tax year, was the CFC an eligible CFC (as defined In other words, are AF Active Amount excluded
in section 954(h)(2)) that derived qualified banking or any amounts financing
financing income (as defined in section 954(h)(3))? excluded from lines
1a–1i of Worksheet A
by reason of the
special rule
described in section
954(h)?
20 During the tax year, was the CFC a qualifying insurance In other words, are AI Active Amount excluded
company (as defined in section 953(e)(3)) that derived any amounts insurance
qualified insurance income (as defined in section 954(i)(2))? excluded from lines
1a–1i of Worksheet A
by reason of the
special rule
described in section
954(i)?
21 During the tax year, did the subpart F income of the CFC In other words, is EP Earnings & Excess of line 36
exceed the earnings and profits of such corporation? line 36 of Worksheet profits over line 37c
A greater than limitation
line 37c?

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

Form 5471, Schedule G, Line 14 (continued)

Question See Worksheet A in If “Yes,” Code If “Yes,” content

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

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

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

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

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

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

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

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

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

Worksheet A

Summary of U.S. Shareholder’s Pro Rata Share of Subpart F Income of a CFC (See the Worksheet A
instructions, later.) Enter the amounts on lines 1a through 62, 64, 66, and 68 in functional currency.

1 Gross foreign personal holding company income:

a Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A)
(excluding amounts described in sections 954(c)(2), (3), and (6)) 1a
b Excess of gains over losses from certain property transactions
(section 954(c)(1)(B)) 1b
c Excess of gains over losses from commodity transactions (section 954(c)(1)(C)) 1c
d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D)) 1d
e Income equivalent to interest (section 954(c)(1)(E)) 1e
f Net income from a notional principal contract (section 954(c)(1)(F)) 1f
g Payments in lieu of dividends (section 954(c)(1)(G)) 1g
h Certain amounts received for services under personal service
contracts (see section 954(c)(1)(H)) 1h
i Certain amounts from sales of partnership interests to which the
look-through rule of section 954(c)(4) applies 1i
2 Gross foreign personal holding company income. Add lines 1a through 1i 2
3 Gross foreign base company sales income (see section 954(d)) 3
4 Gross foreign base company services income (see section 954(e)) 4
5 Gross foreign base company income. Add lines 2 through 4 5
6 Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 18 and
19) 6
7 Gross foreign base company income and gross insurance income. Add lines 5 and 6 7
8 Enter 5% of total gross income (as computed for income tax purposes) 8
9 Enter 70% of total gross income (as computed for income tax purposes) 9
10 If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 19 10
11 If line 7 is more than line 9, enter total gross income (as computed for income tax purposes) 11
12 Total adjusted gross foreign base company income and insurance income (enter the greater of
line 7 or line 11) 12
13 Adjusted net foreign personal holding company income:
a Enter amount from line 2 13a
b Expenses directly related to amount on line 2 13b
c Subtract line 13b from line 13a 13c
d Related person interest expense (see section 954(b)(5)) 13d
e Other expenses allocated and apportioned to the amount on line 2
under section 954(b)(5) 13e
f Net foreign personal holding company income. Subtract the sum of
lines 13d and 13e from line 13c 13f
g Net foreign personal holding company income excluded under
high-tax exception 13g
h Subtract line 13g from line 13f 13h
14 Adjusted net foreign base company sales income:
a Enter amount from line 3 14a
b Expenses allocated and apportioned to the amount on line 3 under
section 954(b)(5) 14b
c Net foreign base company sales income. Subtract line 14b from line 14a 14c
d Net foreign base company sales income excluded under high-tax exception 14d
e Subtract line 14d from line 14c 14e
15 Adjusted net foreign base company services income:
a Enter amount from line 4 15a
b Expenses allocated and apportioned to line 4 under section 954(b)(5) 15b
c Net foreign base company services income. Subtract line 15b from line 15a 15c
d Net foreign base company services income excluded under high-tax exception 15d
e Subtract line 15d from line 15c 15e
16 Adjusted net full inclusion foreign base company income:
a Enter the excess, if any, of line 11 over line 7 16a
b Expenses allocated and apportioned under section 954(b)(5) 16b
c Net full inclusion foreign base company income. Subtract line 16b from line 16a 16c
d Net full inclusion foreign base company income excluded under high-tax exception 16d
e Subtract line 16d from line 16c 16e

22 Instructions for Form 5471

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

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

Worksheet A

Worksheet A (continued) (See instructions.)

39 If the amount on line 37c is less than the amount on line 36, allocate the subpart F income remaining (after having been limited)
to lines 40, 41, 42, and 43 below in the manner prescribed by Regulations section 1.952-1(e). If the amount on line 37c is
greater than or equal to the amount on line 36, enter the amount from line 26 onto line 40, enter the amount from line 29 onto
line 41, enter the amount from line 32 onto line 42, and enter the amount from line 35 onto line 43.
40 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal . . . . . . . . 40
41 Section 954(d) subpart F Foreign Base Company Sales Income subtotal . . . . . . . . . . 41
42 Section 954(e) subpart F Foreign Base Company Services Income subtotal . . . . . . . . . 42
43 Other subpart F income subtotal . . . . . . . . . . . . . . . . . . . . . . . 43
44 Shareholder’s pro rata share of line 40 . . . . . . . . . . . . . 44
45 Shareholder’s pro rata share of export trade income that applies to line 44
amount (see section 970(a)) . . . . . . . . . . . . . . . . . 45
46 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 45 from
line 44 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
47 Shareholder’s pro rata share of line 41 . . . . . . . . . . . . . 47
48 Shareholder’s pro rata share of export trade income that applies to line 47
amount (see section 970(a)) . . . . . . . . . . . . . . . . . 48
49 Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 48 from line 47 49
50 Shareholder’s pro rata share of line 42 . . . . . . . . . . . . . 50
51 Shareholder’s pro rata share of export trade income that applies to line 50
amount (see section 970(a)) . . . . . . . . . . . . . . . . . 51
52 Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from line
50 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52
53 Shareholder’s pro rata share of line 43 . . . . . . . . . . . . . 53
54 Shareholder’s pro rata share of export trade income that applies to line 53
amount (see section 970(a)) . . . . . . . . . . . . . . . . . 54
55 Other subpart F income subtotal. Subtract line 54 from line 53 . . . . . . . . . . . . . 55
56 Add lines 46, 49, 52, and 55 . . . . . . . . . . . . . . . . . . . . . . . . . 56
57 Divide the number of days in the tax year that the corporation was a CFC by
the number of days in the tax year and multiply the result by line 56 . . . . 57
58 The amount of dividends received by any other person with respect to your
stock multiplied by a fraction, the numerator of which is the CFC's subpart F
income for the tax year and the denominator of which is the sum of the CFC's
subpart F income and tested income (section 951A(c)(2)(A) and Regulations
section 1.951A-2(b)(1)) for the tax year . . . . . . . . . . . . . 58
59 Divide the number of days in the tax year you did not own such stock by the
number of days in the tax year and multiply the result by line 56 . . . . . 59
60 Enter the smaller of line 58 or line 59 . . . . . . . . . . . . . . 60
61 Shareholder’s pro rata share of subpart F income. Subtract line 60 from line 57 . . . . . . 61
62 Amount of line 61 that applies to section 954(c) subpart F Foreign Personal Holding Company Income 62
63 Translate the amount on line 62 from functional currency to U.S. dollars at the average exchange rate.
See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1e . . . . . . . . 63
64 Amount of line 61 that applies to section 954(d) subpart F Foreign Base Company Sales Income . . 64
65 Translate the amount on line 64 from functional currency to U.S. dollars at the average exchange rate.
See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1f . . . . . . . . 65
66 Amount of line 61 that applies to section 954(e) subpart F Foreign Base Company Services Income . 66
67 Translate the amount on line 66 from functional currency to U.S. dollars at the average exchange rate.
See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1g . . . . . . . . 67
68 Amount of line 61 that applies to other subpart F income . . . . . . . . . . . . . . . 68
69 Translate the amount on line 68 from functional currency to U.S. dollars at the average exchange rate.
See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1h . . . . . . . . 69

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

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

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

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

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

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

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

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 defined in section 956(c) and (d)) held (directly or
indirectly) by the CFC as of the close of:
a The first 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 profits described in section 959(c)(1)(A) with respect to the U.S. shareholder after
reductions (if any) for current year distributions . . . . . . . . . . . . . . . . . . 5
6 Section 956(a)(1) amount. Subtract line 5 from line 4 . . . . . . . . . . . . . . . . 6
7 Applicable earnings:
a Current year earnings and profits . . . . . . . . . . . . . . . 7a
b Line 7a plus accumulated earnings and profits . . . . . . . . . . 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 profits described in section 959(c)(1) after reductions (if any) for current year distributions 11
12 Applicable earnings. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . 12
13 Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12 . . . . . 13
14 Section 956(a) amount. Enter the smaller of line 6 or line 13 . . . . . . . . . . . . . . 14
15 Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder . . . . . . 15
16 Tentative section 956 amount. Subtract line 15 from line 14 . . . . . . . .. . . . . . . 16
17 Amount of deduction under section 245A, if any, that the shareholder would be allowed if the
shareholder received a hypothetical distribution within the meaning of Regulations section 1.956-1(a)(2).
If the shareholder is not a U.S. corporation, this amount is zero . . . . . . . . . . . . . 17
18 Section 956 amount. Subtract line 17 from line 16 . . . . . . . . . . . . . . . . . 18
19 Translate the amount on line 18 from functional currency to U.S. dollars at the year-end spot rate (as
provided in section 989(b)). Enter the result here and on line 2 of Schedule I . . . . . . . . . 19

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

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

subsequent quarters should be the field for “Name of person filing Part I—Taxes for Which a
recorded as zero on line 1); and Form 5471.” Foreign Tax Credit Is Allowed
• In determining applicable earnings, Reference ID number of foreign In Part I, Section 1, list income, war
current year E&P will include only E&P corporation. If applicable, use the profits, and excess profits taxes
that are allocable (on a pro rata basis)
reference ID number shown on Form (income taxes) paid or accrued to
to the part of the year during which the
5471, page 1, item 1b(2). each foreign country or U.S. territory
foreign corporation was a CFC.
Lines a, b, and c. Complete a for the foreign corporation’s foreign tax
separate Schedule E for each year(s) that ends with or within its U.S.
Instructions for Separate applicable separate category of tax year.
Schedules income. Enter the appropriate code In Part I, Section 2, report taxes
on line a (above Part I). To determine deemed paid under section 960(b)(2)
the appropriate code, see Categories with respect to distributions of PTEP
Schedule E of Income in the Instructions for Form from a lower-tier foreign corporation to
Use Schedule E, Part I, to report taxes 1118, Foreign Tax the foreign corporation with respect to
paid, accrued, or deemed paid under Credit—Corporations. Taxes with which this Schedule E (Form 5471) is
section 960(b)(2) by a foreign respect to all categories of income being completed.
corporation for which a foreign tax listed in the Instructions for Form
credit is allowed, and use Schedule E, 1118, with the exception of foreign Amounts not reported in Part I. Do
Part III, to report taxes for which a branch income, may need to be not report taxes that are not
credit may not be taken. reported. A foreign corporation may creditable, including taxes for which a
accrue or pay taxes properly credit is disallowed under section
Note. Schedule E must be completed attributable to an income group within 245A(d) or section 901(j), (k), (l), or
even for noncorporate U.S. the general category, passive (m); or suspended under section 909.
shareholders. Certain noncorporate category, or section 901(j) category. Such taxes are reported in Part III. A
U.S. shareholders may elect under See Regulations section 1.960-1(d)(2) credit is never allowed for taxes paid
section 962 to be taxed at corporate (ii). A foreign corporation may accrue or accrued to the United States. Do
rates on section 951(a) amounts and or pay taxes properly attributable to a not report such taxes in Part I. Report
the global intangible low-taxed income PTEP group within any of the separate them instead in Part III.
(GILTI) inclusion for the tax year, so as categories of income, with the Adjustments to foreign income tax-
to be able to claim a credit for certain exception of foreign branch category es. Adjustments to foreign income
foreign taxes paid or accrued by the income. See Regulations section taxes paid or accrued in a prior year
CFC. The information reported on 1.960-3(c)(1). should not be reflected on Schedule E
Schedule E is relevant for U.S.
If code 901j is entered on line a, in the year of adjustment. Instead,
shareholders making this election.
enter on line b the country code for they should be reported in the year to
Also, timely information reporting is
the sanctioned country using the which such taxes relate. This may
important to the extent the U.S.
two-letter codes (from the list at require an amended return. See
shareholder chooses to amend its
IRS.gov/CountryCodes). section 905(c). Adjustments include
return in a later year to make the
additional payments, refunds, and
election under section 962. Schedules If one of the RBT codes is entered
downward adjustments for accrued
E and E-1 are also relevant for on line a, enter on line c the country
foreign taxes that are not paid within 2
noncorporate U.S. shareholders who code for the treaty country using the
years after the close of the tax year to
do not make a section 962 election. two-letter code (from the list at
which such taxes relate.
Taxes paid or accrued with respect to IRS.gov/CountryCodes).
distributions of PTEP by the U.S. Comparison to income tax ex-
shareholder, while not reported on Note. Do not complete a separate pense reported on Form 5471,
Form 5471, are subject to different Schedule E for taxes assigned to the Schedule C. The foreign income
rules regarding creditability and section 951A category. Taxes paid, taxes reported on Schedule E may
foreign currency gain or loss. See, for accrued, or deemed paid with respect differ from the amount reported as
example, sections 965(g) and 986(c). to section 951A PTEP that is in the income tax expense on line 21a of
Therefore, it is important that the U.S. section 951A category are reported Schedule C. This is due in part to
shareholder track the PTEP groups to on the Schedule E completed for the differences in the accounting for
follow the different rules for each general category. foreign tax redeterminations,
group. disallowed taxes, and foreign income
Important. In addition to the taxes reported in Other
Name of person filing Form 5471. separate category codes referred to Comprehensive Income for U.S.
The name of the person filing Form above, if you have more than one of GAAP purposes.
5471 is generally the name of the U.S. the categories of income referred to
person described in the applicable above, you must complete and file a Comparison to income tax ex-
category or categories of filers (see separate Schedule E (including pense reported on Schedule H
Categories of Filers, earlier). However, Schedule E-1) using code “TOTAL” (Form 5471). The taxes added or
in the case of a consolidated return, that aggregates all amounts listed for deducted on line 2g of Schedule H
enter the name of the U.S. parent in each line and column of all other include both foreign income taxes
Schedules E and E-1. reported in Part I of Schedule E as
well as the taxes reported in Part III of
Instructions for Form 5471 (Rev. 01-2024) 29
Schedule E that are not creditable or accrued to a different country on 1. The tax is paid before the
foreign income taxes. separate lines. beginning of the year to which the tax
relates.
Section 1—Taxes Paid or
Column (e) 2. Accrued taxes are not paid
Accrued Directly by Foreign
before the date 2 years after the close
Corporation The foreign tax year under foreign tax of the tax year to which such taxes
Column (a) law may not be the same tax year as relate.
the U.S. tax year of the foreign
3. There is an election in effect
Amounts reported on Schedule E may corporation. If the tax is attributable to
under section 986(a)(1)(D) to
include taxes paid or accrued by the a pass-through entity owned by a
translate foreign taxes using the
foreign corporation or a pass-through foreign corporation, the foreign tax
exchange rate in effect on the date of
entity (for example, a partnership or year of the foreign corporation within
payment.
disregarded entity) owned by the which such pass-through entity’s year
ends should be reported on this line. 4. The foreign corporation reports
foreign corporation. If the tax is paid or
on the cash basis. See section 986(a).
accrued by the pass-through entity,
enter the name of such entity instead Column (g) 5. The foreign tax is denominated
of the name of the foreign corporation. in an inflationary currency. See
If the tax paid or accrued by the Enter the income reported to the section 986(a)(1)(C).
foreign corporation is attributable to a foreign tax authority under foreign tax
Report the exchange rate using the
branch or qualified business unit law. This should be the foreign taxable
“divide-by convention” specified under
(QBU) of the foreign corporation, income base for determining the tax
Reporting exchange rates on Form
enter the name of the branch or QBU. reported in column (j).
5471, earlier.

Column (b) Column (h)

Column (m)
Enter the EIN or reference ID number Check the box if taxes were paid on
U.S. source income. Enter the tax in functional currency.
of the payor entity listed in column (a). E&P takes into account foreign
A reference ID number is required income taxes paid or accrued by the
only in cases in which no EIN was Column (i)
foreign corporation. The foreign
entered for the foreign corporation or corporation's E&P is determined in the
pass-through entity owned by the Enter the three-letter currency code
for the local currency in which the tax foreign corporation's functional
foreign corporation. Filers are currency. See section 986(b).
permitted to enter both an EIN and a is payable. Currency codes are
reference ID number. See Item available at six-group.com/en/ Line 5
1b(2)—Reference ID Number, earlier, products-services/financial- Report the total of the amounts listed
for more information about reference information/data- in column (l) on this line 5. This total
ID numbers. standards.html#scrollTo=currency- should also be reported on
codes. Schedule E-1, line 4.
Column (c)
Column (j) Line 6
Check the box if the foreign income Report the total of the amounts listed
taxes reported in column (j) were paid Enter the tax paid or accrued in the in column (m) on this line 6. This total
or accrued by the foreign corporation local currency in which tax is payable and the amount reported on line 3 of
during prior tax years and were and not the functional currency of the Schedule E, Part III, are the
suspended due to the application of payor or foreign corporation. See appropriate reduction to current year
the rules of section 909 and that are sections 986(a) and 905(c). E&P for income taxes. See
unsuspended in the current year Schedule H, line 2g.
because related income is taken into Columns (k) and (l) Example. CFC1, a foreign
account by the foreign corporation, corporation, with reference ID number
certain U.S. corporate owners of the Enter the exchange rate in column (k) 1000123, pays or accrues tax of 10u =
foreign corporation, or a member of and the translated dollar amount in $10 to Country X on 50u of Country X
such U.S. corporate owner’s column (l). foreign source taxable income with
consolidated group. respect to CFC1’s foreign tax year
Translate the taxes entered in
ending December 31, 2023. CFC1
column (j) into dollars at the average
Column (d) has a December 31 tax year end for
exchange rate for the tax year to
both foreign and U.S. tax purposes.
which the tax relates unless one of the
Enter the two-letter codes (from the Also, CFC1 receives in the tax year
exceptions below applies. See section
list at IRS.gov/CountryCodes) of all ending December 31, 2023, a refund
986(a).
foreign countries and U.S. territories of 3u from Country X on 15u of foreign
to which taxes were paid or accrued. If Exceptions. If one of the following source income with respect to CFC1’s
taxes were paid or accrued to more exceptions applies, use the exchange tax year ending December 31, 2017,
than one country with respect to the rate in effect on the date the foreign translated to equal $5, and on which
same income, include each tax paid corporation paid the tax. the original liability was $7. Therefore,

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

the revised tax liability is $2. All taxes The only foreign taxes of the in Regulations section 1.960-3(c)(2)).
relate to general category income. distributing foreign corporation that Please enter the applicable PTEP
Also assume for both years that the may be treated as deemed paid under group code from the following list.
local currency in which the tax was section 960(b) are foreign taxes paid,
paid was the same as the foreign accrued, or deemed paid by the PTEP Group Classification
corporation’s functional currency. The distributing foreign corporation with
country code for Country X is XX. respect to the receipt of a PTEP Taxes related to PTEP Group Code
The following entries should be distribution from another lower-tier previously taxed
made on the 2023 Schedule E (Form foreign corporation below the E&P
5471), Part I, Section 1, for CFC1 with distributing foreign corporation. Reclassified section R965a
respect to the General Category Accordingly, there can be no 965(a) PTEP
Income separate category. deemed-paid foreign taxes with Reclassified section R965b
respect to a PTEP distribution from a
• Line 1, column (a): CFC1 lower-tier foreign corporation that is
965(b) PTEP
• Line 1, column (b): 1000123 the lowest foreign-tier foreign General section 959c1
• Line 1, column (d): XX corporation in a chain, and therefore
959(c)(1) PTEP
• Line 1, column (e): 2023/12/31 no such distributions will be reported Reclassified section R951A
• Line 1, column (f): 2023/12/31 in Section 2. See Regulations section 951A PTEP
• Line 1, column (g): 50u 1.960-1(d)(3)(ii)(B). Reclassified section R245Ad
• Line 1, column (i): u 245A(d) PTEP
• Line 1, column (j): 10u Any foreign income taxes paid or
• Line 1, column (k): 1.0000 accrued (but not deemed paid) by the Section 965(a) PTEP 965a
• Line 1, column (l): $10 foreign corporation with respect to a Section 965(b) PTEP 965b
• Line 1, column (m): 10u PTEP distribution from a lower-tier Section 951A PTEP 951A
An amended 2017 tax return foreign corporation (whether or not
such PTEP distribution is reported in Section 245A(d) 245Ad
should be filed by or for the U.S. PTEP
person(s) with respect to which Form Section 2), such as withholding taxes
5471 was required and that return imposed on the PTEP distribution, are Section 951(a)(1)(A) 951a1A
reported in Section 1. PTEP
should include an amended Form
5471. The amended Form 5471
should include an attachment with a Column (a) Column (e)
schedule that looks like the current
version of Schedule E, Part I, Section Enter the name of each lower-tier Enter the year in which the U.S.
1, with the following entries for the foreign corporation that made a PTEP shareholder included income of the
general category of income. distribution with respect to which a lower-tier foreign corporation under
deemed-paid tax is determined in the
• Line 1, column (a): CFC1 current year by the foreign corporation
section 951(a) or section 951A and
• Line 1, column (b): 1000123 with respect to which this Schedule E
established the PTEP account to
• Line 1, column (d): XX (Form 5471) is being completed.
which the distribution is attributed.
• Line 1, column (e): 2017/12/31 This is the annual PTEP account. See
• Line 1, column (f): 2017/12/31 Regulations section 1.960-3(c)(1).
• Line 1, column (g): 15u Column (b)
• Line 1, column (i): u Column (f)
• Line 1, column (j): 1.20u Enter the EIN or reference ID number
• Line 1, column (k): 1.6667 of the lower-tier foreign corporation Enter the PTEP distribution with
• Line 1, column (l): $2 listed in column (a). A reference ID respect to the PTEP group within the
• Line 1, column (m): 1.20u number is required only in cases in annual PTEP account identified in
which no EIN was entered for the column (d) and column (e) in the
Section 2—Taxes Deemed Paid lower-tier foreign corporation. Filers functional currency of the distributing
(Section 960(b)) are permitted to enter both an EIN and lower-tier foreign corporation. If there
The purpose of Section 2 is to track a reference ID number. See Item is a PTEP distribution related to more
deemed-paid foreign income taxes 1b(2)—Reference ID Number, earlier, than one PTEP group within an annual
with respect to current year PTEP for more information about reference PTEP account, complete a separate
distributions from lower-tier foreign ID numbers. line for each PTEP group within an
corporations to the foreign corporation annual PTEP account.
with respect to which this Schedule E Column (c)
(Form 5471) is being completed (“the Column (g)
foreign corporation”). Enter the applicable two-letter code
(from the list at IRS.gov/ Enter the total amount of the lower-tier
Report a PTEP distribution by a CountryCodes). foreign corporation’s PTEP in the
lower-tier foreign corporation in PTEP group within the annual PTEP
Section 2 only if foreign income taxes Column (d) account identified in column (d) and
are deemed paid under section column (e). Enter such amount in the
960(b) by the foreign corporation with Enter the code which describes the
respect to such PTEP distribution. PTEP group classification (as set forth
Instructions for Form 5471 (Rev. 01-2024) 31
functional currency of the distributing which generally applies to certain (section 901(f)), certain taxes used to
lower-tier foreign corporation. taxes paid on dividends if the provide subsidies (section 901(i)), and
minimum holding period is not met taxes for which no credit is allowed
Column (h) with respect to the underlying stock, because of the boycott provisions of
or if the corporation is obligated to section 908.
Enter the total amount of the lower-tier make related payments with respect
foreign corporation’s PTEP group to positions in similar or related Column (i)
taxes with respect to the PTEP group property. Also enter foreign income
within the annual PTEP account taxes disallowed under section 901(l), For each line in this column, enter the
identified in column (d) and column which generally applies to certain total amount for each payor in
(e). Enter this amount in U.S. dollars. taxes paid on gain and income other columns (c) through (h).
To determine the appropriate than dividends if the minimum holding
translation rate, see section 986(a). period is not met with respect to the Line 3
underlying property, or if the Total each amount in column (i) and
Column (i) corporation is obligated to make enter on line 3. All amounts should be
related payments with respect to in functional currency.
Enter the U.S. dollar amount of the positions in similar or related property. Line 4
recipient foreign corporation's income
Translate the line 3 amount from
taxes deemed paid that are properly Column (e)
functional currency to U.S. dollars
attributable to the PTEP distribution
using, in general, the average
reported in column (f) and not In the case of a covered asset exchange rate as defined by section
deemed to have been paid by the acquisition (as defined in section 989(b)(3).
domestic corporation for any prior tax 901(m)(2)), enter the disqualified
year. portion of any tax determined with
respect to the income or gain Schedule E-1
Note. With respect to distributions of attributable to the relevant foreign Use Schedule E-1 (on pages 2 and 3
PTEP resulting from inclusions under assets (section 901(m)). of separate Schedule E) to report the
section 965, report the taxes properly cumulative balance of foreign income
attributable to such PTEP without Note. This rule generally applies to taxes paid or accrued by a CFC by
reduction for the foreign tax credit covered asset acquisitions after separate category of income.
disallowance. December 31, 2010. See Regulations
sections 1.901(m)-1 through Enter amounts in U.S. dollars
Part III—Taxes for Which unless otherwise noted.
1.901(m)-8 for additional information.
Foreign Tax Credit Is Note that the rules contained in these
Disallowed Columns (a), (b), and (c)
regulations have later effective dates.
Use Part III to report taxes for which In columns (a), (b), and (c), report
foreign tax credits are not allowed. only the foreign income taxes the
Column (f)
While not allowed as a credit, such foreign corporation pays or accrues
taxes are taken into account in attributable to the subpart F income
Enter the amount of taxes paid or group, the tested income group, and
determining the foreign corporation’s accrued by the foreign corporation to
E&P. the residual income group,
the United States. No credit is allowed respectively. Use Schedule Q to
Do not enter taxes that do not meet for these taxes because only foreign determine the taxes attributable to
the criteria under Regulations section income taxes paid or accrued to a each income group. Do not include
1.901-2. foreign country or territory of the foreign income taxes paid or accrued
United States are allowed as a credit. by the foreign corporation in its other
See section 901(b). tax years beginning after December
Columns (a) and (b)
31, 2017, or that do not relate to the
See Part I—Taxes for Which a Foreign Column (g) current tax year. Do not include
Tax Credit Is Allowed, earlier, for foreign income taxes that are
instructions regarding these columns. Report foreign income taxes related to disallowed and are reported on
the current tax year that have been Schedule E, Part III. Do not include
Column (c) suspended due to the rules of section taxes paid or accrued by the foreign
909. corporation with respect to its receipt
Enter foreign income taxes that are of a PTEP distribution, even if those
disallowed under section 901(j), Column (h) amounts were included in the total
generally foreign income taxes paid or entered on line 5, column (l), of
accrued to certain sanctioned Enter taxes for which a foreign tax Schedule E, Part I, Section 1. These
countries. credit is disallowed other than those are reported in column (e). Do not
detailed in columns (c) through (g). include taxes deemed paid by the
Column (d) Such taxes may include, but are not foreign corporation with respect to its
limited to, taxes attributable to section receipt of a PTEP distribution. These
Enter foreign income taxes that are 245A(d) income, certain taxes on the are also reported in column (e).
disallowed under section 901(k), purchase or sale of oil and gas

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

 On line 9, report reductions for the Line 2. Use line 2 to reflect income, after foreign income tax, of
portion of such taxes that are deemed adjustments to a U.S. person’s foreign $100 with respect to which it pays $20
paid by a U.S. shareholder with tax credit as a result of redetermined of foreign income tax. Such tax is
respect to an inclusion under section foreign income taxes. If a U.S. person properly attributable to subpart F
951(a) or 951A. On line 15, report has appropriately amended the income of CFC3 and is reported on
reductions for foreign income taxes immediately prior year return, line 4, column (a), of Schedule E-1 of
attributable to the column (b) tested including its Schedule E-1, to CFC3’s Form 5471. During Year 1,
income group that are not deemed redetermine its U.S. tax liability, no Domestic Corporation reports an
paid as a result of the inclusion adjustment should be included on this inclusion under section 951(a)(1) of
percentage or the 80% limitation. line. This line is only applicable if a $100 and deemed paid taxes of $20
Also, on line 15, report any other U.S. person appropriately amended a under section 960(a) as a result of
reductions to the three income groups prior year return and there were subpart F income of CFC3. During
in columns (a), (b), and (c) necessary intervening years between the Year 2, CFC3 distributes $40 to CFC2.
to achieve a zero balance on line 16. amended year return and the current CFC2 pays withholding tax of $4 on
Attach a statement explaining why year return for which an amended the distribution from CFC3. Such tax
such taxes were not deemed paid return was not filed. If so, an is a tax related to previously taxed
under section 960. The balance of adjustment for the prior year amended earnings and profits that were
foreign income taxes paid or accrued return (and its impact on intervening included as subpart F income and is
with respect to the three income years) should be reflected on line 2. reported on line 4, column (e)(x), of
groups that is entered on line 16 Schedule E-1 of CFC2’s Form 5471.
should equal zero after taking into Line 3a. A tax reported on
Schedule E, Part I, Section 1, line 5, Line 5. Report taxes carried over to a
account the reductions. foreign surviving corporation after an
column (l), for which column (c) was
Column (d) checked because such tax was acquisition by a foreign corporation of
Use column (d) to report taxes unsuspended in the current year, the assets of another foreign
suspended under section 909. should be included as a positive corporation in a transaction described
amount in column (a), (b), (c), or (e), in section 381. See Regulations
Columns (e)(i) through (e)(x) as appropriate. Such tax should also section 1.367(b)-7(b)(1) and (d)(1).
Report foreign income taxes paid or be reflected as a negative amount in Line 6. Enter foreign income taxes
accrued with respect to E&P column (d). properly attributable to PTEP and not
described in section 959(c)(1) and (c) previously deemed paid (from
(2). See the instructions for Line 3b. Include as a positive amount
in column (d) foreign income taxes Schedule E, Part I, Section 2, line 5,
Schedule J, Column (e), later, for column (i)). The total reported on
specific information about the ten related to the current tax year that
have been suspended due to the rules Schedule E, Part I, Section 2, line 5,
PTEP group columns. Also see column (i), should be broken out on
Regulations section 1.960-3(c)(2) for of section 909. Such taxes are also
reported on Schedule E, Part III, Schedule E-1, line 6, columns (e)(i)
additional information regarding the through (e)(x), based on the type of
ten PTEP groups. column (g).
PTEP to which such taxes relate.
Line 4. The total reported on
Specific Instructions Related to Schedule E, Part I, Section 1, line 5, Example 2. The facts are the
column (l), should be separated into same as in Example 1, except that, in
Lines 1 Through 16
columns (a) through (e) according to addition, CFC2 distributes $36 to
Line 1a. This amount should equal the type of income or E&P to which CFC1 in Year 3. CFC1 is deemed to
the amount that was reported as the such taxes relate. Therefore, for pay the $4 of withholding tax paid by
balance on line 16 of the prior year example, taxes paid or accrued with CFC2 in Year 2. See section 960(b).
Schedule E-1. respect to the receipt of a PTEP Such tax is attributable to previously
distribution are reported in column (e), taxed subpart F income and is
Line 1b. If the balance on line 16 of
and taxes paid or accrued with reported on line 6, column (e)(x), of
prior year Schedule E-1 was adjusted
respect to current year subpart F Schedule E-1 of CFC1’s Form 5471.
after the filing of the original prior year
income of the foreign corporation are Such tax is also reported as a
Form 5471, such adjustments should
reported in column (a). negative number on line 10, column
be reflected on line 1b. For example, if
(e)(x), of Schedule E-1 of CFC2’s
there were errors in the original Example 1. Domestic Form 5471.
computation of foreign income taxes, Corporation, a U.S. shareholder,
an adjustment would be included on wholly owns the only class of stock of Line 7. Attach a statement with a
this line. See Corrections to Form CFC1, a foreign corporation. CFC1, in description and the amount of any
5471, earlier. Do not include any turn, wholly owns the only class of adjustments required before taking
adjustments required to be reported stock of CFC2, a foreign corporation. into account taxes deemed paid by
on line 7 or 12. Attach a statement CFC2, in turn, wholly owns the only the foreign corporation. Do not include
that includes an explanation and the class of stock of CFC3, a foreign any adjustments required to be
dollar amount of each such corporation. The functional currency reported on line 1b or 12.
adjustment, along with a total that of Domestic Corporation, CFC1, Line 9. A domestic corporation is
equals the amount entered on line 1b. CFC2, and CFC3 is the U.S. dollar. deemed to pay foreign income taxes
During Year 1, CFC3 has subpart F attributable to inclusions under

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

section 951(a)(1). See section 960(a). Example 4. The facts are the which the foreign corporation was a
Amounts reported on line 9 should be same as in Example 1, except that controlled participant (as defined in
negative numbers. during Year 2, CFC2 invests $40 in Regulations section 1.482-7(j)) during
If a domestic corporation includes U.S. property. At the time of the tax year. All amounts should be
an amount in income under section investment in such property, CFC2 reported in U.S. dollars.
951A, such domestic corporation is continues to maintain a $36 balance Name of person filing Form 5471.
deemed to pay foreign income taxes in its section 959(c)(2) PTEP account. The name of the person filing Form
equal to 80% of the product of (a) CFC2 reclassifies such amount as 5471 is generally the name of the U.S.
such domestic corporation’s inclusion section 959(c)(1) PTEP on person described in the applicable
percentage, multiplied by (b) the Schedule J. Accordingly, $4 of foreign category or categories of filers (see
aggregate tested foreign income taxes income taxes related to section 959(c) Categories of Filers, earlier). However,
paid or accrued by the CFC. For the (2) PTEP is reclassified to section in the case of a consolidated return,
computation of such amount, see 959(c)(1) PTEP on line 11, column (e) enter the name of the U.S. parent in
Form 1118, Schedule D. Amounts (iii). A negative $4 will be recorded on the field for “Name of person filing
reported on line 9 should be negative line 11, column (e)(x), and a positive Form 5471.”
numbers. See line 15 with respect to $4 will be recorded on line 11, column
reporting taxes not deemed paid as a (e)(iii). Reference ID number of foreign
result of the inclusion percentage or corporation. If applicable, use the
Line 12. Attach a statement with a
the application of the 80% limitation. reference ID number shown on Form
description and the amount of any
5471, page 1, item 1b(2).
Line 10. A domestic corporation is required adjustments to taxes of the
deemed to pay foreign income taxes foreign corporation not already taken Question 4. Enter the foreign
with respect to distributions of PTEP. into account on this schedule. An corporation’s share of reasonably
See Section 960(b)(1). Amounts example of amounts reported on anticipated benefits (RAB) for the
reported on line 10 should be negative line 12 is taxes attributable to PTEP CSA during the tax year. See
numbers. distributions to shareholders ineligible Regulations section 1.482-7(e) for
to claim a foreign tax credit under rules on a determining and updating
Taxes are deemed paid by a controlled participant’s RAB share. If
section 960(b)(1) (such as foreign
domestic corporation that is a U.S. the foreign corporation applied more
corporations).
shareholder or a foreign corporation than one RAB share during the tax
that is a CFC with respect to Line 15. Enter the reduction to the year in determining its share of
distributions of PTEP that it receives. column (b) tested income group for intangible development costs (IDCs),
Report on line 10, column (e), the tested income taxes not deemed paid. enter the RAB share that was applied
taxes that relate to PTEP of the See Regulations section 1.960-1. This to IDCs incurred at the end of the
foreign corporation that are deemed includes taxes attributable to the year. See Regulations section
paid by a shareholder of the foreign column (b) tested income group that 1.482-7(d) for more information on
corporation, either an upper-tier were not deemed paid as a result of IDCs.
foreign corporation or a U.S. the domestic corporation’s inclusion
shareholder, with respect to a percentage or as a result of the Question 5a. Check the “Yes” box if
distribution of PTEP made by the application of the 80% limit. See the U.S. taxpayer made any platform
foreign corporation. section 960(d). Enter the reduction to contributions as defined in
the three income groups in columns Regulations section 1.482-7(c) to the
Example 3. The facts are the (a), (b), and (c) for other taxes not CSA during the tax year. If “Yes,”
same as in Example 2, except that deemed paid. See Regulations complete lines 5b and 5c.
during Year 4, CFC1 distributes $36 to section 1.960-1. This includes taxes
Domestic Corporation. Domestic Questions 5b and 5c. Enter the
that are properly attributable to a foreign corporation's RAB share of the
Corporation is deemed to pay the $4 subpart F income group but were not
of withholding taxes deemed paid by total present value of all platform
deemed paid because there was no contributions made by the U.S.
CFC1 in Year 3 and paid by CFC2 in subpart F income with respect to that
Year 2. A negative $4 will be recorded taxpayer during the tax year with
income group in the current year. respect to the foreign corporation on
on line 10, column (e)(x), of CFC1’s
Form 5471, Schedule E-1. line 5b. The total present value of all
Note. If necessary, enter negative
platform contributions made by the
See Example 2, earlier, for amounts on line 15 of columns (a),
U.S. taxpayer during the tax year
reporting on line 10, column (e)(x), of (b), and (c) in amounts sufficient to
should be entered even if only a
Schedule E-1 of CFC2's Form 5471 reduce line 16, columns (a), (b), and
portion (or none) of the value of those
with respect to taxes on distributions (c), to zero. Attach a statement
platform contributions was included in
from CFC3 to CFC2. explaining why such taxes were not
the U.S. taxpayer's taxable income as
deemed paid under section 960.
Line 11. Foreign income taxes platform contribution transaction
reclassified from section 959(c)(2) (PCT) payments during the tax year. If
PTEP to section 959(c)(1) PTEP Schedule G-1 possible, include a reasonable
should be reported as negative present value estimate for any PCTs
numbers in columns (e)(vi) through (e) Note. A separate Schedule G-1 must that are priced using a method that
(x) and as positive numbers in be filed for each cost sharing does not involve the calculation of a
columns (e)(i) through (e)(v). arrangement (CSA) as defined in present value. Otherwise, attach a
Regulations section 1.482-7(b) in

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

brief statement of the reason(s) it is reasonably allocable to, the IDA as enter on line 1 the dollar GAAP
not possible to include a present value defined in Regulations section income or (loss) from line 22 of
estimate for one or more PCTs (for 1.482-7(d)(1)(i). This would include Schedule C. Enter on lines 2a through
example, no revenue projections for a stock-based compensation granted in 4 the adjustments made in figuring
PCT that is priced based on a earlier years (which could give rise to current E&P for U.S. tax purposes.
sales-based royalty from a deductions in the current tax year) that Report these amounts in U.S. dollars.
comparable uncontrolled transaction). were not treated as identified with or Enter on line 5b the DASTM gain or
If the U.S. taxpayer engaged in reasonably allocable to the IDA. loss figured under Regulations section
multiple PCTs during the tax year with Questions 7a and 7b. For the tax 1.985-3(d).
the foreign corporation and used year, enter the total amount of IDCs Lines 2a through 2i. Certain
different methods to price the PCTs, for the CSA on line 7a. See adjustments (required by Regulations
check the appropriate boxes on Regulations section 1.482-7(d) for section 1.964-1(b) and (c)) must be
line 5c to indicate which methods more information on IDCs. made to the foreign corporation's
were selected as the best method for line 1 net book income or (loss) to
On line 7b, enter the amount of
one or more of the PCTs reported in determine its current year E&P. These
IDCs allocated to the foreign
the tax year. See Regulations section adjustments may include both positive
corporation for the tax year based on
1.482-7(g) for more information on the and negative adjustments to conform
the foreign corporation’s RAB share.
methods applicable to PCTs. the foreign book income to U.S. GAAP
Questions 6b and 6c. See, and to U.S. tax accounting principles.
generally, Regulations section 1.482-7 Schedule H If the foreign corporation's books are
for more information on determining Use Schedule H to report the foreign maintained in functional currency in
whether stock-based compensation is corporation's current year E&P for accordance with U.S. GAAP, enter on
directly identified with, or reasonably U.S. tax purposes. Enter the amounts line 1 the functional currency GAAP
allocable to, the intangible on lines 1 through 5c in the CFC's income or (loss) from line 22 of
development activity (IDA) under the functional currency. Schedule C, rather than starting with
CSA. See Regulations section foreign book income, and show
Certain filers may be able to use
1.482-7(d)(3) and Notice 2005-99 for GAAP-to-tax adjustments on lines 2a
alternative information (as defined in
more information on determining the through 2i.
section 3.01 of Rev. Proc. 2019-40) to
measurement and timing of determine certain amounts in this Lines 2b and 2c. Generally,
stock-based compensation IDCs, schedule. See Item F—Alternative depreciation, depletion, and
including an election available with Information Under Rev. Proc. amortization allowances must be
respect to options on publicly traded 2019-40, earlier, for more details. based on the historical cost of the
stock and certain other stock-based underlying asset, and depreciation
compensation. If the taxpayer made Note. A separate Worksheet H-1 must be figured according to section
the election described in Regulations must be attached for each person 167. However, if 20% or more of the
section 1.482-7(d)(3)(iii)(B) or Notice described in Categories 4, 5a, 5b, and foreign corporation's gross income is
2005-99, the taxpayer should attach a 5c with respect to which reporting is from U.S. sources, depreciation must
statement to Form 5471 explaining furnished on this Form 5471 that is an be figured on a straight line basis
that the taxpayer made such election applicable corporation within the according to Regulations section
and include in such statement the meaning of section 59(k). Worksheet 1.312-15.
total amount of stock-based H-1 and instructions are provided later
compensation taken into account as in these instructions. Line 2f. Inventories must be taken
an IDC for the tax year pursuant to into account according to the rules of
such election. If the taxpayer attaches Note. Category 5b and 5c filers are sections 471 (incorporating the
the statement described in the not required to file Schedule H for provisions of section 263A) and 472
previous sentence, then in the entry foreign-controlled CFCs. and the related regulations.
space provided for line 6b the Name of person filing Form 5471. Line 2g. See the instructions for
taxpayer should include the total The name of the person filing Form Schedule C, Line 21, earlier. Reflect
amount of stock-based compensation 5471 is generally the name of the U.S. differences between the income tax
taken into account as an IDC, person described in the applicable expense (benefit) reported for book
including stock-based compensation category or categories of filers (see purposes and the income taxes
pursuant to the election described Categories of Filers, earlier). However, deducted or added to E&P. Such
above and any not subject to such in the case of a consolidated return, differences include, for example,
election. enter the name of the U.S. parent in deferred income tax expenses,
Check the appropriate box on the field for “Name of person filing uncertain tax positions, intraperiod
line 6c to indicate whether any Form 5471.” allocations, adjustments made after
stock-based compensation was closing the financial statements
Reference ID number of foreign (post-closing adjustments) and not
granted during the term of the CSA to corporation. If applicable, use the
individuals who performed functions reflected in income tax expense
reference ID number shown on Form (benefit), and the adjustment for a
in business activities that generate 5471, page 1, item 1b(2).
cost-shared intangibles that were not foreign tax redetermination that
treated as directly identified with, or Special rules for DASTM. If the required a redetermination of the U.S.
foreign corporation uses DASTM, tax liability.

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

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

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

 Worksheet H-1
Complete a separate Worksheet H-1 in machine-readable Excel format for each person described in Categories 4, 5a, 5b, and 5c with
respect to which reporting is furnished on this Form 5471 that is an applicable corporation within the meaning of section 59(k).
Filer’s Pro Rata Share of CFC Adjusted Net Income or Loss for Corporate Alternative Minimum Tax
1 Net income (or loss) set forth on the applicable financial statement . . . . . . . . .. . . 1
Net Net
2 Adjustments made to line 1 (see instructions) additions subtractions
a Statements covering different taxable years . . . . . 2a
b Consolidated financial statements . . . . . . . . . 2b
c Consolidated returns . . . . . . . . . . . . . 2c
d Treatment of dividends and other amounts . . . . . . 2d
e Treatment of partnerships . . . . . . . . . . . 2e
f Effectively connected income . . . . . . . . . . 2f
g Adjustments for certain taxes . . . . . . . . . . 2g
h Adjustments with respect to disregarded entities . . . . 2h
i Depreciation . . . . . . . . . . . . . . . . 2i
j Other adjustments (see instructions) . . . . . . . . 2j
3 Total net additions . . . . . . . . . . . . . . 3
4 Total net subtractions . . . . . . . . . . . . . 4
5a Adjusted net income or loss (line 1 plus line 3 minus line 4) . . . . . . . . . . . . . . 5a
b Filer’s pro rata share of line 5a (see instructions) . . . . . . . . . . . . . . . . . . 5b
c Adjusted net income or loss in U.S. dollars (see instructions) . . . . . . . . . . . . . . 5c
d Enter exchange rate used for line 5c . . . . . . . . . . . . . . 5d

Worksheet H-1 Instructions inclusions by U.S. shareholders under completed once (for general category
Use Worksheet H-1 to report the section 951A. The information in this income, passive category income, or
CFC’s adjusted net income or loss for schedule will be used by the U.S. both). A Schedule I-1 that includes
corporate alternative minimum tax shareholder(s) of the CFC to file Form passive category income on line 6
(CAMT) purposes. Enter the amounts 8992, U.S. Shareholder Calculation of must include the code for passive
on lines 1 through 5b in the CFC’s Global Intangible Low-Taxed Income category income (PAS) in the entry
functional currency. (GILTI), and may assist in the space for separate category (at the
completion of Form 1118 or Form top of Schedule I-1). This is the case
Lines 2a through 2j. Certain 1116, if applicable. even if the Schedule I-1 also includes
adjustments (required by section general category income. With
56A(c)) must be made to the foreign Enter the amounts on lines 1 respect to a taxpayer completing
corporation’s line 1 net book income through 10c in the CFC's functional Schedule I-1 with respect to a foreign
or (loss) to determine its adjusted net currency. The functional currency corporation with only general category
income or loss for CAMT purposes. amounts entered on lines 6 through income (and no passive category
These adjustments may include both 10c must be converted to U.S. dollars. income) on line 6, the taxpayer should
positive and negative adjustments. Certain filers may be able to use enter the code “GEN” in the entry
Line 2j. Enter the net amount of any alternative information (as defined in space for separate category.
additional adjustments not included section 3.01 of Rev. Proc. 2019-40) to
on lines 2a through 2i. List these determine certain amounts in this Note. The other reporting
additional adjustments on a separate schedule. See Item F—Alternative requirements of a taxpayer that
statement. Attach this statement to Information Under Rev. Proc. includes passive category income
Form 5471. 2019-40, earlier, for more details. with general category income on a
Schedule I-1 do not change because
Line 5b. Enter the filer’s pro rata Name of person filing Form 5471. the taxpayer includes passive
share (determined under rules similar The name of the person filing Form category income with general
to the rules under section 951(a)(2)) 5471 is generally the name of the U.S. category income on a Schedule I-1.
of the amount on line 5a. person described in the applicable For example, the taxpayer may still be
category or categories of filers (see required to complete a Form 1116 or a
Line 5c. Enter the line 5b functional
Categories of Filers, earlier). However, Form 1118, and/or a Form 5471
currency amount translated into U.S.
in the case of a consolidated return, (including Schedule J and
dollars for the CFC’s tax year.
enter the name of the U.S. parent in Schedule P), and separately report
the field for “Name of person filing passive category income and section
Schedule I-1 Form 5471.” 951A category income.
This schedule is used to report Separate category. Schedule I-1 is Line 1. Enter the CFC’s gross
information determined at the CFC no longer completed separately for income. The amount of gross income
level with respect to amounts used in each applicable category of income. entered on line 1 will generally be a
the determination of income Therefore, Schedule I-1 is now
Instructions for Form 5471 (Rev. 01-2024) 37
positive amount. However, if a CFC’s Line 3. Combine lines 2a through 2e. the CFC. See Regulations section
cost of goods sold exceeds its gross The line 3 result can be positive or 1.951A-1(d)(1).
receipts, a negative amount is negative. Qualified business asset
permitted on line 1.
Line 4. Subtract line 3 from line 1 and investment (QBAI). QBAI is the
Line 2. Enter the CFC’s exclusions as enter the result on line 4. The line 4 average of the CFC's aggregate
described in Regulations section result can be positive or negative. For adjusted bases, as of the close of
1.951A-2(c). example: each quarter of its tax year, in
Line 2a. Enter the amount of the specified tangible property used in its
CFC’s income or loss described in Line 1 trade or business in the production of
section 952(b), which is generally
gross tested income, and for which a
income or loss from sources within the
income $1,000 $1,000 $(1,000) $(1,000) deduction is allowable under section
United States that is effectively
Line 3 total 167. Adjusted basis in any property
connected to the conduct of a trade or
exclusions 800 (800) 800 (800) must be determined by using the
business by the CFC in the United
Line 4 alternative depreciation system under
States and not reduced or exempt
(line 1 section 168(g) and allocating
minus
from tax pursuant to an income tax line 3) $200 $1,800 $(1,800) $(200) depreciation deductions with respect
treaty with the United States. to such property ratably to each day
during the period in the tax year to
Line 2b. Enter the amount, if any, Line 5. Enter the deductions which such depreciation relates.
of the CFC’s gross income or loss (including taxes) properly allocable to Specified tangible property and
taken into account in determining the the amount on line 4 (or to which such
CFC’s subpart F income (as defined in dual-use property. Specified
deductions would be allocable if there tangible property means any tangible
section 952). Note that an amount were such gross income). See section
determined under section 956(a) is property used in the production of
951A(c)(2)(A)(ii) and Regulations tested income. If such property was
not considered subpart F income. The section 1.951A-2(c)(3). The amount
amount to be entered is computed used in the production of tested
entered on line 5 will generally be a income and income that is not tested
after application of the high-tax positive amount. However, a negative
exception in section 954(b)(4), but income (that is, dual-use property),
amount is permitted on line 5. the property is treated as specified
before application of the E&P
limitation in section 952(c)(1)(A). Line 6. Subtract line 5 from 4 and tangible property in the same
enter the result on line 6. The line 6 proportion that the amount of tested
Line 2c. Enter the amount, if any, result can be positive or negative. See income determined before allocable
of the CFC’s gross income excluded the line 4 instructions above for deductions (that is, line 4) produced
from foreign base company income examples. This amount must be with respect to the property bears to
(as defined in section 954) and converted from functional currency to the total amount of gross income
insurance income (as defined in U.S. dollars using the average produced with respect to the property.
section 953) by reason of section exchange rate for the year of the CFC.
954(b)(4), the high-tax exception Partnership property. A CFC
See Regulations section 1.951A-1(d) with tested income that is a partner of
(include amounts excluded from (1).
tested income under Regulations a partnership that has depreciable
Report the exchange rate using the tangible property determines its share
section 1.951A-2(c)(7)).
“divide-by convention” specified under of the partnership’s average adjusted
Line 2d. Enter the amount of any Reporting exchange rates on Form basis in the depreciable tangible
dividend income received by the CFC 5471, earlier. property of the partnership based on
from a related person as defined in Line 7. If the CFC has a tested loss the amount of the distributive share of
section 954(d)(3). Do not include the on line 6, enter zero. If the CFC has the gross income produced by the
amounts of any dividend income tested income on line 6, enter only property that is included in the CFC’s
received from a related person that those foreign income taxes that are gross tested income (defined below)
are already included in the amounts properly attributable to the CFC’s relative to the total amount of gross
entered on line 2b or line 2c. tested income group. This amount income produced by the property. The
must be converted from functional partnership’s average adjusted basis
Line 2e. Enter the amount of the
currency to U.S. dollars using the in the depreciable tangible property of
CFC’s taxable income or loss from
average exchange rate for the year of the partnership is generally
sources outside the United States and
the CFC. See section 986. determined based on the average of
its territories from the following.
the adjusted basis in the property as
• The extraction (by the corporation Line 8. If the CFC has a tested loss of the close of each quarter of the
or any other person) of minerals from on line 6, enter zero. If the CFC has partnership’s tax year that ends with
oil or gas wells located outside the tested income on line 6, enter the or within the CFC’s tax year. See
United States and its territories. qualified business asset investment Regulations section 1.951A-3(g).
• The sale or exchange of assets (QBAI) (defined below). This amount
used (by the corporation) in the trade must be converted from functional Gross tested income. For these
or business of extracting minerals currency to U.S. dollars using the purposes, a CFC’s gross tested
from oil or gas wells located outside average exchange rate for the year of income is its gross income less total
the United States and its territories. exclusions (Schedule I-1, line 4).

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

Lines 9a through 9d. In general, the field for “Name of person filing PTEP amounts required to be
see Regulations section 1.951A-4(b) Form 5471.” included in column (e). If the person
(1) to determine how to compute the filing Form 5471 is unable to
Reference ID number of foreign
CFC’s tested interest expense. determine whether amounts should
corporation. If applicable, use the
be reported as PTEP, those amounts
Line 9a. Enter the amount of reference ID number shown on Form
should be included in column (a),
interest expense included on line 5. 5471, page 1, item 1b(2).
Post-2017 E&P Not Previously Taxed
See Line 6, earlier, for foreign Lines a and b. Complete a separate (post-2017 section 959(c)(3)
currency translation. Schedule J for each applicable balance). For example, one U.S.
Line 9b. Enter the CFC’s qualified separate category of income. Enter shareholder might not know the
interest expense, as defined in the appropriate code on line a (at the amount of the other U.S.
Regulations section 1.951A-4(b)(1) top of page 1 of Schedule J). To shareholder’s section 951A inclusion
(iii). determine the appropriate code, see that is allocated to the CFC because
Categories of Income in the the first U.S. shareholder does not
Line 9c. Enter the CFC’s tested Instructions for Form 1118. E&P with have information with respect to the
loss QBAI amount, as defined in respect to all categories of income second U.S. shareholder’s net CFC
Regulations section 1.951A-4(b)(1) listed in the Instructions for Form tested income or pro rata share of
(iv). 1118, except foreign branch category QBAI. See the instructions for
income, may need to be reported. A Schedule P, later, for an example.
Line 9d. Subtract the sum of
foreign corporation may have E&P in
line 9b and line 9c from line 9a and Enter the amounts in this schedule
an income group within the general
enter the result on line 9d. in the functional currency of the
category, passive category, or section
Lines 10a through 10c. In general, 901(j) category. See Regulations foreign corporation as reported on
see Regulations section 1.951A-4(b) section 1.960-1(d)(2)(ii). A foreign Form 5471, page 1, item 1h. If the
(2) to determine how to compute the corporation may have PTEP in a foreign corporation is the owner of a
CFC’s tested interest income. PTEP group within any of the separate qualified business unit(s) (QBU) with a
categories of income, except foreign different functional currency, translate
Line 10a. Enter the amount of the E&P of the QBU(s) to the foreign
branch category income. See
interest income included on line 4. corporation’s functional currency.
Regulations section 1.960-3(c)(1).
See Line 6, earlier, for foreign
currency translation. If code 901j is entered on line a, Columns (a), (b), and (c)
enter on line b the country code for Report the opening balance, current
Line 10b. Enter the CFC’s the sanctioned country using the year additions and subtractions, and
qualified interest income, as defined in two-letter code (from the list at the closing balance in the foreign
Regulations section 1.951A-4(b)(2) IRS.gov/CountryCodes). corporation's E&P described in
(iii). section 959(c)(3). In general, this is
Note. A separate Schedule J should E&P of the foreign corporation that
Line 10c. Subtract line 10b from
not be completed for the section 951A has not been included in gross
line 10a and enter the result on
category. Reclassified section 951A income of a U.S. person under section
line 10c.
PTEP and section 951A PTEP that is 951(a)(1) and section 951A.
in the section 951A category should
Schedule J be reported on the general category In column (a), report E&P
Use Schedule J to report a CFC’s Schedule J. described in section 959(c)(3) and
accumulated E&P in its functional earned after the repeal of section 902,
Note. For purposes of this that is, post-2017 E&P not previously
currency, computed under sections
Schedule J, include in each separate taxed (post-2017 section 959(c)(3)
964(a) and 986(b). Also use this
category of income, foreign source balance). The repeal of section 902 is
schedule to report the E&P of
and U.S. source income. effective for tax years of foreign
specified foreign corporations that are
only treated as CFCs for limited Important. In addition to the corporations beginning after
purposes under section 965(e)(2). separate category codes referred to December 31, 2017, and to tax years
above, if you have more than one of of U.S. shareholders in which or with
Note. Category 1b, 1c, 5b, and 5c the categories of income referred to which such tax years of foreign
filers are not required to file above, you must complete and file a corporations end.
Schedule J for foreign-controlled separate Schedule J using code In column (b), report post-1986
section 965 SFCs or “TOTAL” that aggregates all amounts undistributed earnings, as defined
foreign-controlled CFCs. listed for each line and column in Part under section 902(c)(1), and as in
Name of person filing Form 5471. I of all other Schedules J. effect prior to the repeal of section
The name of the person filing Form Part I—Accumulated E&P of 902.
5471 is generally the name of the U.S. Controlled Foreign Corporation Use column (c) to report the
person described in the applicable aggregate amount of the foreign
category or categories of filers (see Check the box at the top of Part I if the
person filing Form 5471 does not have corporation's pre-1987 section 964(a)
Categories of Filers, earlier). However, E&P accumulated since 1962 and not
in the case of a consolidated return, all U.S. shareholders’ information
necessary to complete any one of the previously distributed or deemed
enter the name of the U.S. parent in distributed. These amounts are
Instructions for Form 5471 (Rev. 01-2024) 39
figured in U.S. dollars using the rules investments in U.S. property (section attributable to a distribution of such
of Regulations section 1.964-1(a) 959(c)(1) amounts). PTEP. See section 965(g) and
through (d), and translated into the • Column (e)(v) is PTEP described in Regulations section 1.965-5 for more
foreign corporation's functional the following three subgroups (which information. This is the case for both
currency according to Notice 88-70, are aggregated into a single PTEP direct foreign tax credits (that is, those
1988-2 C.B. 369. group) (section 959(c)(1) amounts). foreign taxes paid or accrued directly
1. PTEP attributable to hybrid by the shareholder upon receipt of the
Column (d) PTEP distribution and allowed as a
dividends under section 245A(e)(2)
Use column (d) to report hovering credit under section 901 or 903) and
and reclassified as investments in
deficits (see section 381(c)(2)(B) and indirect foreign tax credits (that is,
U.S. property.
Regulations section 1.367(b)-7) and those taxes deemed paid by the
suspended taxes (see section 909). 2. PTEP attributable to section
shareholder with respect to taxes
See Specific Instructions Related to 1248 amounts under section 959(e)
originally paid or accrued by the CFC
Lines 1 Through 13, later, for and reclassified as investments in
under section 960(b)). With respect to
additional information pertaining to U.S. property.
direct credits, this reduction applies
reporting amounts in column (d). 3. PTEP attributable to section regardless of whether such individual
1248 amounts from the gain on the made an election under section 962.
Column (e) sale of foreign corporation stock by a Therefore, the reporting on
Use column (e) to report the running CFC and reclassified as investments Schedule J is necessary regardless of
balance of the foreign corporation's in U.S. property. whether the U.S. shareholder made a
PTEP, section 964(a) E&P • Column (e)(vi) is PTEP attributable section 962 election.
accumulated since 1962 that have to section 965(a) inclusions (section
resulted in deemed inclusions under 959(c)(2) amounts). Do not include in Column (f)
subpart F, or amounts treated as column (e)(vi) E&P reported in column Use column (f) to report the opening
PTEP under section 965(b)(4)(A). (e)(vii). and closing balances of the foreign
Pre-1987 U.S. dollar PTEP should be • Column (e)(vii) is E&P treated as corporation's accumulated E&P. This
translated into the foreign PTEP under section 965(b)(4)(A) amount is the sum of post-2017 E&P
corporation's functional currency (section 959(c)(2) amounts). not previously taxed, post-1986
using the rules of Notice 88-70 and • Column (e)(viii) is PTEP attributable undistributed earnings, pre-1987 E&P
added to post-1986 amounts in the to section 951A inclusions (section not previously taxed, and PTEP. Do
appropriate PTEP group. 959(c)(2) amounts). not include column (d) amounts in the
• Columns (e)(i) and (e)(ii) are PTEP • Column (e)(ix) is PTEP described in total reported in column (f).
originally attributable to inclusions the following three subgroups (which
under section 965(a) and E&P treated are aggregated into a single PTEP
Specific Instructions Related to
as PTEP under section 965(b)(4)(A), group) (section 959(c)(2) amounts). Lines 1 Through 13
respectively, and reclassified as Line 1a. Enter the balances for each
1. PTEP attributable to hybrid
investments in U.S. property (section column at the beginning of the tax
dividends under section 245A(e)(2).
959(c)(1) amounts). year. These balances should equal
• Column (e)(iii) is PTEP described in 2. PTEP attributable to section
1248 amounts under section 959(e). the amounts reported as the ending
the following three subgroups (which balances in the prior year Schedule J.
are aggregated into a single PTEP 3. PTEP attributable to section
group) (section 959(c)(1) amounts). 1248 amounts from the gain on the Line 1b. If there is a difference
1. PTEP attributable to sale of foreign corporation stock by a between last year’s ending balance on
investments in U.S. property and not CFC. Schedule J and the amount that
by reason of reclassification. • Column (x) is PTEP attributable to should be last year’s ending balance,
section 951(a)(1)(A) inclusions taking into account modifications on
2. PTEP attributable to inclusions Schedule J, include the difference on
(section 959(c)(2) amounts) not
under section 951(a)(1)(A) (other than line 1b and attach an explanation for
otherwise described in the
inclusions under section 951(a)(1)(A) the difference. If there are multiple
instructions for columns (e)(vi)
described in the instructions for reasons for differences, include the
through (ix).
columns (e)(vi) through (ix)) and explanation and amount of each such
reclassified as investments in U.S. Schedule J reports PTEP by difference on the attachment. Do not
property (for example, PTEP subgroups because those groups may include adjustments required to be
attributable to subpart F income be subject to different rules under reported on line 6 or 12.
inclusions and reclassified as sections 960, 965(g), 245A(e)(3), and
investments in U.S. property). 986(c). The different rules are Lines 1a through 1c. These lines of
applicable for individuals, as well as column (d) account for the balance of
3. PTEP attributable to inclusions
corporations, estates, and trusts. For prior year hovering deficits and
under former section 951(a)(1)(C) and
example, an individual U.S. suspended taxes that have not yet
subpart F income inclusions
shareholder who receives a been deducted. Such amounts are
reclassified as investments in excess
distribution of PTEP originally reported as negative numbers.
passive assets.
• Column (e)(iv) is PTEP originally attributable to inclusions under Line 2a. This line of column (d) is the
attributable to inclusions under section 965(a) may only claim a credit unsuspended taxes under section 909
section 951A and reclassified as for a portion of the foreign taxes as a result of related income taken

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

into account by the foreign nonrecognition transaction. See (1)(A) or section 951A with respect to
corporation, certain U.S. corporate section 381(c)(2)(B) and Regulations the CFC. Report the inclusion as a
owners of the foreign corporation, or a section 1.367(b)-7(d)(2)(i) (post-1986 negative amount in columns (a)
member of such U.S. corporate undistributed earnings) and through (c), as applicable. Report the
owner’s consolidated group. Report 1.367(b)-7(e)(1) (pre-1987 E&P not inclusion as a positive amount in
the unsuspended taxes on line 2a of previously taxed). An amount equal to columns (e)(vi) through (e)(x), as
column (d) as a positive number. the deficit reported in column (a), (b), applicable. Amounts reported as
Report the unsuspended taxes as or (c) of line 5a is included as a positive numbers on line 8 of column
negative numbers on line 2a of positive amount on line 5b of column (e)(viii) should only be reported with
column (a), (b), (c), or (e), as (a), (b), or (c), respectively. An amount respect to negative amounts on line 8
applicable. equal to the total hovering deficits of column (a). The negative amounts
Line 2b. This line of column (d) reported on line 5b of columns (a), (b), could be reported on a different
accounts for foreign income taxes that and (c) is included as a negative Schedule J than the positive amounts
are suspended in the current tax year. number in column (d) of line 5b. if such amounts are reclassified from
Report such amounts as negative Line 6. Attach a statement detailing one separate category to another
numbers. the nature and amount of any separate category.
adjustments not accounted for in the Note. Section 951(a)(1)(A) inclusions
Line 3. Enter the current year E&P (or
E&P determined before reduction for are taken into account for the tax year
deficit in E&P) amount from the
distributions and inclusions (that is, before actual distributions and section
applicable line 5c of Schedule H
adjustments other than those listed on 951(a)(1)(B) inclusions. See section
(Form 5471). For example, if you are
lines 2a through 5b). Do not include 959.
completing Schedule J for the passive
amounts reported on line 1b. An
category (that is, you have entered
“PAS” on line a at the top of page 1 of example of an adjustment entered on Note. The amount included in gross
Schedule J), enter the current year line 6 is the foreign taxes imposed on income of U.S. shareholders of the
receipt of a distribution of PTEP from CFC under section 951A might not be
E&P (or deficit in E&P) amount from
a lower-tier foreign corporation. known if there is more than one U.S.
Schedule H (Form 5471), line 5c(ii), in
the applicable column. Line 3 should Example. Domestic Corporation, a shareholder. In that case, see the
never have an amount entered in U.S. shareholder, wholly owns the example in the instructions for
column (e). only class of stock of CFC1, a foreign Schedule P for reporting information.
Line 4. Report as a positive number corporation. CFC1, in turn, wholly Note. The amount reported in column
E&P attributable to distributions of owns the only class of stock of CFC2, (e)(viii) on line 8 will not necessarily
PTEP from lower-tier foreign a foreign corporation. CFC2, in turn, equal the tested income reported on
corporations. Generally, the E&P of a wholly owns the only class of stock of Schedule I-1. For an example of when
CFC attributable to amounts that are, CFC3, a foreign corporation. The this might occur, see Regulations
or have been, included in the gross functional currency of Domestic section 1.951A-5(b)(2)(ii).
income of a U.S. shareholder under Corporation, CFC1, CFC2, and CFC3
is the U.S. dollar. During Year 1, Line 9. Report actual distributions as
section 951(a) are not, when
Domestic Corporation reports an negative numbers.
distributed through a chain of
ownership described in section inclusion under section 951(a)(1) of
$100 as a result of subpart F income Note. Actual distributions are taken
958(a), also included in the gross into account for the tax year before
income of another CFC in such chain of CFC3. During Year 2, CFC3
distributes $40 to CFC2. CFC2 pays section 951(a)(1)(B) inclusions. See
for purposes of the application of section 959(f)(2). An actual
section 951(a) to such other CFC with withholding tax of $4 on the
distribution from CFC3. Such tax is distribution is first out of PTEP, if any,
respect to such U.S. shareholder. See and then out of the section 959(c)(3)
section 959(b). related to previously taxed subpart F
income. Domestic Corporation reports balance. See section 959(c).
Line 5a. Enter earnings carried over on CFC2’s Form 5471, Schedule J,
to a foreign surviving corporation after Note. The total of all amounts
line 4, column (e)(x), as a positive
an acquisition by a foreign corporation entered in Schedule R (Form 5471),
number, the $40 PTEP distribution.
of the assets of another foreign column (d), must equal the amount on
Domestic Corporation reports on
corporation in a transaction described line 9, column (f), of the Schedule J
line 6, column (e)(x), as a negative
in section 381. See Regulations (Form 5471) that is filed, or if more
number, the $4 of tax on the PTEP
section 1.367(b)-7. The amounts than one Schedule J (Form 5471) is
distribution.
entered on line 5a may be negative or filed, the Schedule J (Form 5471) with
positive. Negative amounts are Line 7. Enter on line 7 E&P as of the code “TOTAL” entered on line a of that
hovering deficits reported in column close of the tax year before actual Schedule J.
(d) of line 5a. distributions or inclusions under
Line 10. Use line 10 to report
section 951(a)(1) or section 951A
Line 5b. If the foreign surviving reclassifications of section 959(c)(2)
during the year.
corporation had a deficit in E&P prior PTEP in columns (e)(vi) through (e)(x)
to a transaction described in section Line 8. Enter amounts included in to section 959(c)(1) PTEP in columns
381, such deficit is recharacterized as gross income of the U.S. (e)(i) through (e)(v). A potential
a hovering deficit after such shareholder(s) under section 951(a) section 951(a)(1)(B) inclusion results

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

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

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

outstanding balance from these Part II • Enters “5,000” in column (e)(1).
transactions should be reported on
Section A—General Shareholder
• Enters “-0-” in column (f) because
the Balance Sheet (Form 5471, the disposition was by gift.
Schedule F, page 4) and possibly also Information • Enters the name and address of his
on Schedule M, lines 31 and 33. son, John, in column (g).
If the shareholder's latest tax return
Accrued payments and receipts. A was filed electronically, enter “e-filed”
corporation that uses an accrual Section F—Additional Information
in column (b)(3) instead of a service
method of accounting must use center. Item (b). List the date of any
accrued payments and accrued reorganization of the foreign
receipts for purposes of computing corporation that occurred during the
Section C—Acquisition of Stock
the total amount to enter on each line last 4 years while any U.S. person
of Schedule M. held 10% or more in value or vote
Section C is completed by
shareholders who are completing (directly or indirectly) of the
Schedule O Schedule O because they have corporation's stock. If there is more
Schedule O is used to report the acquired sufficient stock in a foreign than one such date, use the most
organization or reorganization of a corporation. If the shareholder recent date. However, do not enter a
foreign corporation and the acquisition acquired the stock in more than one date for which information was
or disposition of its stock. transaction, use a separate line to reported in Section E. Instead, enter
report each transaction. the date (if any) of any reorganization
Every U.S. citizen or resident prior to that date (if it is within the last
described in Category 2 must Column (d). Enter the method of 4 years).
complete Part I. Every U.S. person acquisition (for example, purchase,
described in Category 3 must gift, bequest, trade). Example for item (c). Mr. Lyons,
complete Part II. a U.S. person, acquires a 10%
Column (e)(2). Enter the number of ownership in foreign corporation F. F
See Regulations section shares acquired indirectly (within the is the 100% owner of two foreign
1.6046-1(i) for rules on determining meaning of section 958(a)(2)) by the corporations, FI and FJ. F is also a
when U.S. persons constructively own shareholder listed in column (a). 50% owner of foreign corporation FK.
stock of a foreign corporation and are Column (e)(3). Enter the number of In addition, F is 90% owned by foreign
therefore subject to the section 6046 shares constructively owned (within corporation W. Mr. Lyons does not
filing requirements. the meaning of section 958(b)) by the own any of the stock of corporation W.
Name of person filing Form 5471. shareholder listed in column (a). Mr. Lyons completes and files Form
The name of the person filing Form 5471 and Schedule O for the
5471 is generally the name of the U.S. Section D—Disposition of Stock corporations in which he is a
person described in the applicable 10%-or-more shareholder. Mr. Lyons
category or categories of filers (see Section D must be completed by is also required to submit a chart if the
Categories of Filers, earlier). However, shareholders who dispose of their foreign corporation is a member of a
in the case of a consolidated return, interest (in whole or in part) in a chain of corporations, and to indicate
enter the name of the U.S. parent in foreign corporation. if he is a 10%-or-more shareholder in
the field for “Name of person filing any of those corporations.
Column (d). Enter the method of
Form 5471.” disposition (for example, sale, Mr. Lyons would prepare a list
Reference ID number of foreign bequest, gift, trade). showing the corporations as follows.
corporation. Use the reference ID • Corporation W.
Example. In 1999, Mr. Jackson, a • Corporation F.
number shown on Form 5471, page 1, U.S. citizen, purchased 10,000 shares
item 1b(2). • Corporation FI.
of common stock of foreign • Corporation FJ.
Part I corporation X. The purchase • Corporation FK.
represented 10% ownership of the
Column (d). Enter the date the Then Mr. Lyons is required to
foreign corporation.
shareholder first acquired 10% or indicate that he is a 10%-or-more
more (in value or voting power) of the On July 1, 2023, Mr. Jackson made shareholder in corporations F, FI, and
outstanding stock of the foreign a gift of 5,000 shares of foreign FJ.
corporation. corporation X to his son, John.
Because Mr. Jackson has reduced his
Column (e). Enter the date the holding in the foreign corporation, he Schedule P
shareholder acquired (whether in one is required to complete Form 5471 Use Schedule P to report the PTEP in
or more transactions) an additional and Schedule O. To show the required the U.S. shareholder’s annual PTEP
10% or more (in value or voting information about the disposition, Mr. accounts with respect to a CFC in the
power) of the outstanding stock of the Jackson completes Section D as CFC’s functional currency (Part I) and
foreign corporation. follows. the U.S. shareholder’s U.S. dollar
• Enters his name in column (a). basis in that PTEP (Part II). For
• Enters “common” in column (b). purposes of the preceding sentence,
• Enters “July 1, 2023” in column (c). a CFC includes an SFC that is only
• Enters “gift” in column (d).
Instructions for Form 5471 (Rev. 01-2024) 43
treated as a CFC for limited purposes respect to its PTEP of $50x on line 8, “TOTAL” that aggregates all amounts
under section 965(e)(2). column (e)(viii). In the following year, listed for each line and column of all
Corporation A and Corporation B other Schedules P.
Note. A separate Schedule P must should each report the other
be completed by each Category 1a, corporation’s PTEP on Schedule J,
Part I
1b, 4, 5a, or 5b filer. Part I, line 1b, column (e)(viii), and the Enter amounts in the functional
corresponding reduction to CFC1’s currency of the foreign corporation as
If a U.S. shareholder wholly owns
E&P described in section 959(c)(3) on reported on Form 5471, page 1, item
the CFC, Schedule P should include 1h.
the same information reported on Schedule J, Part I, line 1b, column (a).
Schedule J, Part I, column (e). If there Name of person filing Form 5471. Pre-1987 U.S. dollar PTEP should
is more than one U.S. shareholder, the The name of the person filing Form be translated into the foreign
amounts reported on Schedule P with 5471 is generally the name of the U.S. corporation's functional currency
respect to each U.S. shareholder person described in the applicable using the rules of Notice 88-70 and
might be different from the amounts category or categories of filers (see added to post-1986 amounts in the
reported on Schedule J. Categories of Filers, earlier). However, appropriate PTEP category.
Example. Corporation A, a in the case of a consolidated return,
enter the name of the U.S. parent in Part II
domestic corporation, owns 50% of
the only class of stock of CFC1, and the field for “Name of person filing Dollar basis. Enter amounts in U.S.
Corporation B, a domestic Form 5471.” dollars. The U.S. shareholder’s U.S.
corporation, owns the remaining 50% Reference ID number of foreign dollar basis in PTEP is generally equal
of the stock of CFC1. Corporation A corporation. If applicable, use the to the U.S. dollar amount of E&P that
wholly owns the only class of stock of reference ID number shown on Form the U.S. shareholder previously
CFC2. The functional currency of all 5471, page 1, item 1b(2). included in gross income. See section
corporations is the U.S. dollar. CFC1 989(b)(1) and (3); and Regulations
Lines a and b. Complete a separate sections 1.951A-1(d)(1) and
has tested income of $100x and
Schedule P for each applicable 1.965-1(b)(1) and (2).
CFC2 has tested loss of $30x. See
separate category of income. Enter
section 951A(c)(2). Neither The U.S. shareholder’s U.S. dollar
the appropriate code on line a (at the
Corporation A nor Corporation B has basis is used by the U.S. shareholder
top of page 1 of Schedule P). To
any net deemed tangible income to determine the amount of foreign
determine the appropriate code, see
return that would reduce the GILTI currency gain or loss on the PTEP that
Categories of Income in the
inclusion of Corporation A or B. the U.S. shareholder is required to
Instructions for Form 1118.
Corporation A has a section 951A recognize under section 986(c).
inclusion of $20 because its pro rata A foreign corporation may have
PTEP in a PTEP group within any of Columns (a) through (k). Use
share of CFC1’s tested income ($50x)
the separate categories of income, columns (a) through (k) to report the
is offset by its pro rata share of
with the exception of foreign branch opening balance of, current year
CFC2’s tested loss ($30x).
category income. See Regulations additions and subtractions to, and the
Corporation B has a section 951A
section 1.960-3(c)(1). closing balance of, the PTEP in the
inclusion of $50x. On Schedule P of
U.S. shareholder’s annual PTEP
the Form 5471 with respect to CFC1 If code 901j is entered on line a,
accounts with respect to a CFC.
filed by Corporation B, Corporation B enter on line b the country code for
will report on line 7, column (h), $50x the sanctioned country using the Columns (a) through (j) of
of PTEP as a result of its section 951A two-letter code (from the list at Schedule P correspond to
inclusion with respect to CFC1. IRS.gov/CountryCodes). Schedule J, columns (e)(i) through (e)
Corporation A will report $20x of (x). See Schedule J, earlier, for
PTEP as a result of its section 951A Note. A separate Schedule P should specific line instructions.
inclusion on its Form 5471, not be completed for the section 951A Line 1b. If there is a difference
Schedule P, line 7, column (h), with category. Reclassified section 951A between last year’s ending balance on
respect to CFC1. PTEP and section 951A PTEP that is Schedule P and the amount that
in the section 951A category should should be last year’s ending balance,
The Form 5471, Schedule J, for
be reported on the Schedule P taking into account modifications on
CFC1 should include PTEP of $70x
completed for the general category. Schedule P, include the difference on
with respect to the aggregate section
951A inclusions of Corporation A and Note. For purposes of this line 1b and attach an explanation for
Corporation B. However, if Schedule P, include in each separate the difference. If there are multiple
Corporation A does not know category of income, foreign source differences, include the explanation
Corporation B’s section 951A and U.S. source income. and amount of each such difference
inclusion at the time Corporation A on the attachment.
files its Form 5471, Corporation A will Important. In addition to the
only be able to complete Schedule J, separate category codes referred to
Part I, with respect to its PTEP of $20x
Schedule Q
above, if you have more than one of
on line 8, column (e)(viii). Similarly, the categories of income referred to Use Schedule Q to report the CFC’s
Corporation B will only be able to above, you must complete and file a income, deductions, taxes, and assets
complete Schedule J, Part I, with separate Schedule P using code by CFC income groups for purposes
of section 960(a) and (d).

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

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

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

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

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

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

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

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

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

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

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

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

Principal Business Activity Codes Using the list of activities and codes below, use one of the manufacturing codes
determine from which activity the company derives (311110-339900).
This list of principal business activities and their the largest percentage of its “total receipts.” If the
associated codes is designed to classify an company purchases raw materials and supplies Enter on page 1, Item 1f, the six-digit code
enterprise by the type of activity in which it is them to a subcontractor to produce the finished selected from the list below. In item 1g, enter a
engaged to facilitate the administration of the product, but retains title to the product, the brief description of the company's business
Internal Revenue Code. These principal business company is considered a manufacturer and must activity.
activity codes are based on the North American
Industry Classification System.

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

50
Principal Business Activity Codes (Continued)
Merchant Wholesalers, Nondurable Gasoline Stations & Fuel Dealers 488210 Support Activities for Rail Securities, Commodity Contracts,
Goods 457100 Gasoline Stations (including Transportation and Other Financial Investments
424100 Paper & Paper Products convenience stores with gas) 488300 Support Activities for Water and Related Activities
424210 Drugs & Druggists' Sundries 457210 Fuel Dealers (including Transportation 523150 Investment Banking &
Heating Oil & Liquefied 488410 Motor Vehicle Towing Securities Intermediation
424300 Apparel, Piece Goods, &
Notions Petroleum) 488490 Other Support Activities for 523160 Commodity Contracts
Clothing and Accessories Retailers Road Transportation Intermediation
424400 Grocery & Related Products
458110 Clothing & Clothing 488510 Freight Transportation 523210 Securities & Commodity
424500 Farm Product Raw Materials Exchanges
Accessories Retailers Arrangement
424600 Chemical & Allied Products 523900 Other Financial Investment
458210 Shoe Retailers 488990 Other Support Activities for
424700 Petroleum & Petroleum Transportation Activities (including portfolio
Products 458310 Jewelry Retaileres management & investment
458320 Luggage & Leather Goods Couriers and Messengers advice)
424800 Beer, Wine, & Distilled
Alcoholic Beverages Retailers 492110 Couriers & Express Delivery Insurance Carriers and Related
Sporting, Hobby, Book, Musical Services Activities
424910 Farm Supplies
Instrument & Miscellaneous 492210 Local Messengers & Local 524110 Direct Life, Health, & Medical
424920 Book, Periodical, & Retailers Delivery
Newspapers Insurance Carriers
459110 Sporting Goods Retailers Warehousing and Storage 524120 Direct Insurance (except Life,
424930 Flower, Nursery Stock, &
Florists' Supplies 459120 Hobby, Toy, & Game Retailers 493100 Warehousing & Storage Health & Medical) Carriers
459130 Sewing, Needlework, & Piece (except lessors of 524210 Insurance Agencies &
424940 Tobacco Products & mini-warehouses &
Electronic Cigarettes Goods Retailers Brokerages
self-storage units)
424950 Paint, Varnish, & Supplies 459140 Musical Instrument & 524290 Other Insurance Related
Supplies Retailers Information Activities (including
424990 Other Miscellaneous
Nondurable Goods 459210 Book Retailers & News Motion Picture and Sound third-party administration of
Dealers (including Recording Industries insurance and pension funds)
Wholesale Trade Agents and newsstands)
Brokers 512100 Motion Picture & Video Funds, Trusts, and Other Financial
459310 Florists Industries (except video Vehicles
425120 Wholesale Trade Agents &
Brokers 459410 Office Supplies & Stationery rental) 525100 Insurance & Employee
Retailers 512200 Sound Recording Industries Benefit Funds
Retail Trade 459420 Gift, Novelty, & Souvenir 525910 Open-End Investment Funds
Publishing Industries
Motor Vehicle and Parts Dealers Retailers (Form 1120-RIC, U.S. Income
513110 Newspaper Publishers Tax Return for Regulated
441110 New Car Dealers 459510 Used Merchandise Retailers 513120 Periodical Publishers Investment Companies)
441120 Used Car Dealers 459910 Pet & Pet Supplies Retailers 513130 Book Publishers 525920 Trusts, Estates, & Agency
441210 Recreational Vehicle Dealers 459920 Art Dealers 513140 Directory & Mailing List Accounts
441222 Boat Dealers 459930 Manufactured (Mobile) Home Publishers 525990 Other Financial Vehicles
441227 Motorcycle, ATV, & All other Dealers 513190 Other Publishers (including mortgage REITs
Motor Vehicle Dealers 459990 All Other Miscellaneous 513210 Software Publishers and closed-end investment
441300 Automotive Parts, Retailers (including tobacco, funds)“Offices of Bank
candle, & trophy retailers) Broadcasting & Content Providers Holding Companies” and
Accessories, & Tire Retailers & Telecommunications
Nonstore Retailers “Offices of Other Holding
Building Material and Garden 516100 Radio & Television Companies” are located
Equipment and Supplies Dealers various Nonstore retailers sell all Broadcasting Stations under Management of
444110 Home Centers types of merchandise using Companies (Holding
such methods as Internet, 516210 Media Streaming, Social
444120 Paint & Wallpaper Retailers Networks, & Other Content Companies) below.
mail-order catalogs,
444140 Hardware Retailers interactive television, or direct Providers Real Estate and Rental and
444180 Other Building Material sales. These types of 517000 Telecommunications Leasing
Dealers Retailers should select the (including Wired, Wireless,
PBA associated with their Satellite, Cable & Other Real Estate
444200 Lawn & Garden Equipment &
Supplies Retailers primary line of products sold. Program Distribution, 531110 Lessors of Residential
For example, establishments Resellers, Agents & Other Buildings & Dwellings
Food and Beverage Retailers primarily selling prescription Telecommunications, & (including equity REITs)
445110 Supermarkets and Other and non-prescription drugs, Internet Service Providers) 531120 Lessors of Nonresidential
Grocery Retailers (except select PBA code 456110 Data Processing, Web Search Buildings (except
Convenience) Pharmacies & Drug Retailers. Portals, & Other Information Mini-warehouses) (including
445131 Convenience Retailers Transportation and Services equity REITs)
445132 Vending Machine Operators Warehousing 518210 Computing Infrastructure 531130 Lessors of Mini-warehouses
445230 Fruit & Vegetable Retailers Providers, Data Processing, & Self-Storage Units
Air, Rail, and Water Transportation Web Hosting & Related (including equity REITs)
445240 Meat Retailers 481000 Air Transportation Services
445250 Fish & Seafood Retailers 531190 Lessors of Other Real Estate
482110 Rail Transportation 519200 Web Search Portals, Property (including equity
445291 Baked Goods Retailers 483000 Water Transportation Libraries, Archives, & Other REITs)
445292 Confectionery & Nut Retailers Info. Services 531210 Offices of Real Estate Agents
Truck Transportation
445298 All Other Specialty Food Finance and Insurance & Brokers
Retialers 484110 General Freight Trucking,
Local Depository Credit Intermediation 531310 Real Estate Property
445320 Beer, Wine, & Liquor Managers
Retailers 484120 General Freight Trucking, 522110 Commercial Banking
Long-distance 531320 Offices of Real Estate
Furniture and Home Furnishings 522130 Credit Unions Appraisers
Retailers 484200 Specialized Freight Trucking 522180 Savings Institutions & Other 531390 Other Activities Related to
449110 Furniture Retailers Transit and Ground Passenger Depository Credit Real Estate
Transportation Intermediation
449121 Floor Covering Retailers Rental and Leasing Services
485110 Urban Transit Systems Nondepository Credit
449122 Window Treatment Retailers Intermediation 532100 Automotive Equipment Rental
485210 Interurban & Rural Bus & Leasing
449129 All Other Home Furnishings Transportation 522210 Credit Card Issuing
Retailers 532210 Consumer Electronics &
485310 Taxi Service 522220 Sales Financing Appliances Rental
Electronics and Appliance Retailers 485320 Limousine Service 522291 Consumer Lending 532281 Formal Wear & Costume
449210 Electronic & Appliance 485410 School & Employee Bus
Retailers (including 522292 Real Estate Credit (including Rental
computers) Transportation mortgage bankers & 532282 Video Tape & Disc Rental
485510 Charter Bus Industry originators)
General Merchandise Retailers 532283 Home Health Equipment
485990 Other Transit & Ground 522299 Intl, Secondary Market, & Rental
455110 Department Stores Passenger Transportation Other Nondepos. Credit
455210 Warehouse Clubs, Intermediation 532284 Recreational Goods Rental
Supercenters,& Other Pipeline Transportation 532289 All Other Consumer Goods
486000 Pipeline Transportation Activities Related to Credit
General Merch. Retailers Intermediation Rental
Health and Personal Care Retailers Scenic & Sightseeing 522300 Activities Related to Credit 532310 General Rental Centers
456110 Pharmacies & Drug Retailers Transportation Intermediation (including loan 532400 Commercial & Industrial
456120 Cosmetics, Beauty Supplies, 487000 Scenic & Sightseeing brokers, check clearing, & Machinery & Equipment
& Perfume Retailers Transportation money transmitting) Rental & Leasing
456130 Optical Goods Retailers Support Activities for
Transportation
456190 Other Health & Personal Care 488100 Support Activities for Air
Retailers Transportation

51
Principal Business Activity Codes (Continued)
Lessors of Nonfinancial Intangible 561210 Facilities Support Services Home Health Care Services Other Services
Assets (except copyrighted works) 561300 Employment Services 621610 Home Health Care Services Repair and Maintenance
533110 Lessors of Nonfinancial 561410 Document Preparation Other Ambulatory Health Care
Intangible Assets (except 811110 Automotive Mechanical &
Services Services Electrical Repair &
copyrighted works)
561420 Telephone Call Centers 621900 Other Ambulatory Health Maintenance
Professional, Scientific, and 561430 Business Service Centers Care Services (including 811120 Automotive Body, Paint,
Technical Services (including private mail centers ambulance services & blood Interior, & Glass Repair
& copy shops) & organ banks)
Legal Services 811190 Other Automotive Repair &
561440 Collection Agencies Hospitals Maintenance (including oil
541110 Offices of Lawyers 622000 Hospitals
561450 Credit Bureaus change & lubrication shops &
541190 Other Legal Services Nursing and Residential Care car washes)
Accounting, Tax Preparation, 561490 Other Business Support
Services (including Facilities 811210 Electronic & Precision
Bookkeeping, and Payroll Services repossession services, court 623000 Nursing & Residential Care Equipment Repair &
541211 Offices of Certified Public reporting, & stenotype Facilities Maintenance
Accountants services) Social Assistance 811310 Commercial & Industrial
541213 Tax Preparation Services 561500 Travel Arrangement & 624100 Individual & Family Services Machinery & Equipment
541214 Payroll Services Reservation Services (except Automotive &
624200 Community Food & Housing, Electronic) Repair &
541219 Other Accounting Services 561600 Investigation & Security & Emergency & Other Relief
Services Maintenance
Architectural, Engineering, and Services
561710 Exterminating & Pest Control 811410 Home & Garden Equipment &
Related Services 624310 Vocational Rehabilitation Appliance Repair &
541310 Architectural Services Services Services Maintenance
541320 Landscape Architecture 561720 Janitorial Services 624410 Childcare Services 811420 Reupholstery & Furniture
Services 561730 Landscaping Services Repair
Arts, Entertainment, and
541330 Engineering Services 561740 Carpet & Upholstery Cleaning 811430 Footwear & Leather Goods
Services Recreation
541340 Drafting Services Repair
561790 Other Services to Buildings & Performing Arts, Spectator Sports, 811490 Other Personal & Household
541350 Building Inspection Services and Related Industries
Dwellings Goods Repair & Maintenance
541360 Geophysical Surveying & 711100 Performing Arts Companies
Mapping Services 561900 Other Support Services Personal and Laundry Services
(including packaging & 711210 Spectator Sports (including
541370 Surveying & Mapping (except labeling services, & 812111 Barber Shops
sports clubs & racetracks)
Geophysical) Services convention & trade show 812112 Beauty Salons
711300 Promoters of Performing Arts,
541380 Testing Laboratories & organizers) Sports, & Similar Events 812113 Nail Salons
Services Waste Management and 812190 Other Personal Care Services
711410 Agents & Managers for
Specialized Design Services Remediation Services Artists, Athletes, Entertainers, (including diet & weight
541400 Specialized Design Services 562000 Waste Management & & Other Public Figures reducing centers)
(including interior, industrial, Remediation Services 711510 Independent Artists, Writers, 812210 Funeral Homes & Funeral
graphic, & fashion design) & Performers Services
Educational Services
Computer Systems Design and Museums, Historical Sites, and 812220 Cemeteries & Crematories
Related Services 611000 Educational Services
(including schools, colleges, Similar Institutions 812310 Coin-Operated Laundries &
541511 Custom Computer & universities) 712100 Museums, Historical Sites, & Drycleaners
Programming Services Similar Institutions 812320 Drycleaning & Laundry
541512 Computer Systems Design Health Care and Social Services (except
Amusement, Gambling, and
Services Assistance Recreation Industries Coin-Operated)
541513 Computer Facilities Offices of Physicians and Dentists 713100 Amusement Parks & Arcades 812330 Linen & Uniform Supply
Management Services 812910 Pet Care (except Veterinary)
621111 Offices of Physicians (except 713200 Gambling Industries
541519 Other Computer Related mental health specialists) Services
Services 713900 Other Amusement &
621112 Offices of Physicians, Mental Recreation Industries 812920 Photofinishing
Other Professional, Scientific, and Health Specialists (including golf courses, skiing 812930 Parking Lots & Garages
Technical Services facilities, marinas, fitness
621210 Offices of Dentists 812990 All Other Personal Services
541600 Management, Scientific, & centers, & bowling centers)
Technical Consulting Offices of Other Health Religious, Grantmaking, Civic,
Services Practitioners Accommodation and Food Professional, and Similar
621310 Offices of Chiropractors Services Organizations
541700 Scientific Research &
Development Services 621320 Offices of Optometrists Accommodation 813000 Religious, Grantmaking,
621330 Offices of Mental Health Civic, Professional, & Similar
541800 Advertising, Public Relations, 721110 Hotels (except Casino Hotels) Organizations (including
& Related Services Practitioners (except & Motels
Physicians) condominium and
541910 Marketing Research & Public 721120 Casino Hotels homeowners associations)
Opinion Polling 621340 Offices of Physical,
Occupational & Speech 721191 Bed & Breakfast Inns Other
541920 Photographic Services 721199 All Other Traveler
Therapists, & Audiologists 999000 Unclassified Establishments
541930 Translation & Interpretation Accommodation
Services 621391 Offices of Podiatrists (unable to classify)
621399 Offices of All Other 721210 RV (Recreational Vehicle)
541940 Veterinary Services Parks & Recreational Camps
Miscellaneous Health
541990 All Other Professional, Practitioners 721310 Rooming & Boarding Houses,
Scientific, & Technical Dormitories & Workers’
Services Outpatient Care Centers
Camps
621410 Family Planning Centers
Management of Companies Food Services and Drinking Places
621420 Outpatient Mental Health &
(Holding Companies) Substance Abuse Centers 722300 Special Food Services
(including food service
551111 Offices of Bank Holding 621491 HMO Medical Centers contractors & caterers)
Companies 621492 Kidney Dialysis Centers 722410 Drinking Places (Alcoholic
551112 Offices of Other Holding 621493 Freestanding Ambulatory Beverages)
Companies Surgical & Emergency 722511 Full Service Restaurants
Administrative and Support and Centers
722513 Limited Service Restaurants
Waste Management and 621498 All Other Outpatient Care
Centers 722514 Cafeterias, Grill buffets, &
Remediation Services Buffets
Medical and Diagnostic
Administrative and Support Laboratories 722515 Snack & Nonalcoholic
Services Beverage Bars
621510 Medical & Diagnostic
561110 Office Administrative Laboratories
Services

52