Section I—Pro-Rata Share of Adjusted Net
Income or Loss of CFCs Described in Section
56A(c)(3)
Column (a). Enter the name of the CFC.
Column (b). Enter the EIN or reference ID number of the
CFC.
Column (c). Enter the country code for the country in
which the CFC was incorporated. See IRS.gov/
CountryCodes .
Column (d). Enter the pro-rata share of items taken into
account in computing the adjusted net income or loss of a
CFC as reported on each CFC’s Schedule H-1 (Form
5471) in U.S. dollars. See section 56A(c)(3). In
determining the adjusted net income or loss of a CFC,
disregard CFC federal income taxes, and income, war
profits, and excess profits taxes (within the meaning of
section 901) with respect to a foreign country or U.S.
territory taken into account on the CFC’s AFS. See section
56A(c)(5).
Section II—Section 56A(c)(3)(B) Negative
Adjustment
Line 1. In general, enter the amount from Section I,
line 42. However, if the applicable corporation relies on the
specified proposed regulations and does not choose to
have the benefits of subpart A of part III of subchapter N of
chapter 1 for the tax year, then reduce the amount on
Section I, line 42 by the amount of the reduction described
in Proposed Regulations section 1.56A-6(b)(2) and enter
the result here.
Line 2. Enter the aggregate amount of available CFC
adjustment carryovers as defined in Proposed
Regulations section 1.56A-6(b)(6). A CAMT entity that is a
U.S. shareholder of one or more CFCs makes a single
adjustment to the CAMT entity’s AFSI for its tax year that
is equal to the aggregate of the CAMT entity’s pro-rata
share of the adjusted net income or loss of each such
CFC. If a prior tax year aggregate adjustment is negative
with respect to a tax year of a U.S. shareholder, such loss
is carried forward to the future tax years and may reduce
the current tax year aggregate pro-rata share of CFC’s
adjusted net income from the total of Part VI, Section I.
Attach a statement summarizing the amount of CFC
adjustment carryover generated in each prior year, the
amount of each such CFC adjustment carryover that has
been used in prior years, and the amount of such CFC
adjustment carryovers available to be used in the current
year, as illustrated below.
|
(A) CFC Adjustment Carryover Generated |
(B) Amount of Carryover From (A) Used in Prior Years |
(C) Amount of Carryover From (A) Available for Use |
| 20X1 |
100x |
70x |
30x |
| 20X2 |
0 |
n/a |
n/a |
| 20X3 |
40x |
0 |
40x |
Note: The amount entered on Line 2 should equal the
sum of the amounts reported in column (C) above.
Line 3. Combine lines 1 and 2. If more than zero, enter
the total on line 3 and on Part II, line 2e, and Part IV,
Section I, line 3f. If zero or less, enter zero (-0-) on line 3
and on Part II, line 2e, and Part IV, Section I, line 3f, and go
to line 4.
Line 4. Combine lines 1 and 2. If less than zero, enter
the combined total as a negative number. If zero or more,
enter -0-.
14 Instructions for Form 4626 (2025)