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2025›Notice 2025-49 provides additional interim guidance on›Specific Instructions

Part VI—Aggregate Pro-Rata Share of Adjusted Net Income or Loss of CFCs Described in…

2025 Inst 4626 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States

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)

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▸Contents — 2025 Inst 4626 (PDF)

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