Identifying Information

Annual Accounting Period Enter, in the space provided below the title of Form 5471, the annual accounting period of the foreign corporation for which you are furnishing information. Except for information contained on Schedule O, report information for the tax year of the foreign corporation that ends with or within your tax year. When filing Schedule O, report acquisitions, dispositions, and organizations or reorganizations that occurred during your tax year.

Section 898 specified foreign corporation (SFC). The annual accounting period of an SFC (as defined in section 898) is generally required to be the tax year of the corporation’s majority U.S. shareholder. If there is more than one majority shareholder, the required tax year will be the tax year that results in the least aggregate deferral of income to all U.S. shareholders of the foreign corporation.

For these purposes, section 898(b) defines an SFC as any foreign corporation:

1. That is treated as a CFC for any purpose under subpart F, and

2. In which more than 50% of the total voting power or value of all classes of stock of the corporation is treated as owned by a U.S. shareholder.

Item A—Identifying Number The identifying number of an individual is his or her social security number (SSN). The identifying number of all others is their EIN. If a U.S. corporation that owns stock in a foreign corporation is a member of a consolidated group, list the common parent as the person filing the return and enter its EIN in item A.

Item B—Category of Filer Complete item B to indicate the category or categories that describe the person filing this return. If more than one category applies, check all boxes that apply. See Categories of Filers , earlier.

Note: If you satisfy the requirements of both Category 4 and Category 5a filers, only check the box for Category 4 and leave the box for Category 5a blank. If you file on behalf of other persons pursuant to the joint filers exception, only check the category or categories that apply to you. See Multiple filers of same information, earlier, for additional information pertaining to the joint filers exception.

Item C—Percentage of Voting Stock Owned Enter the total percentage of the foreign corporation’s voting power you owned directly, indirectly, or constructively at the end of the corporation’s annual accounting period.

Item D—Final Year Check the item D checkbox only if this is the final year of the foreign corporation’s existence as a corporation for federal tax purposes, for example, if a reorganization has occurred, a complete liquidation has occurred, or an election to treat the foreign corporation as a disregarded entity has been made. If this item D is checked, complete Schedule O.

Item E—Excepted Specified Foreign Financial Assets Check the item E checkbox if any excepted specified foreign financial assets are reported on Form 5471. If this is the case, you do not have to also report these assets on Form 8938. It is only necessary to complete Form 8938, Part IV, line 17. For more information, see the Instructions for Form 8938, generally, and in particular, Duplicative Reporting and the specific instructions for Part IV, Excepted Specified Foreign Financial Assets .

Item F—Alternative Information Under Rev. Proc. 2019-40 Check the item F checkbox if Form 5471 has been completed using alternative information (as defined in section 3.01 of Rev. Proc. 2019-40).

Section 5 of Rev. Proc. 2019-40 provides a safe harbor for determining certain items, including taxable income and E&P, of certain CFCs based on alternative information. Specifically, in the case of a foreign-controlled CFC with respect to which there is no related section 958(a) U.S. shareholder, if information satisfying the requirements of Regulations section 1.952-2(a), (b), and (c)(2) and section 964 and the regulations thereunder is

For a tax year of an SFC beginning after November 30, 2025, the SFC may not have a tax year beginning one month earlier than the majority U.S. shareholder year.

For more information, see section 898 and Rev. Proc. 2006-45, 2006-45 I.R.B. 851, available at IRS.gov/irb/ 2006-45_IRB#RP-2006-45, as modified by Rev. Proc. 2007-64, 2007-42 I.R.B. 818, available at IRS.gov/irb/ 2007-42_IRB#RP-2007-64 .

Name of Person Filing This Return The name of the person filing Form 5471 is generally the name of the U.S. person described in the applicable category or categories of filers (see Categories of Filers, earlier). However, in the case of a consolidated return, enter the name of the U.S. parent in the field for “Name of person filing this return.” Be sure to list each U.S. shareholder of the foreign corporation in Schedule B, Part I.

Name change. If the name of either the person filing the return or the corporation whose activities are being reported changed within the past 3 years, show the prior name(s) in parentheses after the current name.

Address Enter the filer’s street address. Enter the suite, room, or other unit number in the box for “Room or suite no.” If the post office does not deliver mail to the street address and the U.S. person has a P.O. box, show the box number instead.

Foreign address. Enter the information in the following order: city, province or state, and country. Follow the country’s practice for entering the postal code, if any. Do not abbreviate the country name.

Instructions for Form 5471 (Rev. 12-2025) 11

not readily available to an unrelated section 958(a) U.S. shareholder or an unrelated constructive U.S. shareholder with respect to the foreign-controlled CFC, an amount reported on a Form 5471 may be determined by the unrelated section 958(a) U.S. shareholder or the unrelated constructive U.S. shareholder, as applicable, on the basis of alternative information (without adjustments other than those described in section 3.01(b) and 3.10 of the revenue procedure) with respect to the foreign-controlled CFC. See section 3 of Rev. Proc. 2019-40 for definitions of terms.

Section 6 of Rev. Proc. 2019-40 provides a safe harbor for determining certain items of certain SFCs based on alternative information. Specifically, in the case of an SFC, other than either a foreign-controlled CFC with respect to which there is no related section 958(a) U.S. shareholder or a U.S. controlled CFC, if information satisfying the requirements of section 964 and the regulations thereunder is not readily available to an unrelated section 958(a) U.S. shareholder or an unrelated constructive U.S. shareholder with respect to the SFC, an amount reported on a Form 5471 may be determined by the unrelated section 958(a) U.S. shareholder or the unrelated constructive U.S. shareholder, as applicable, on the basis of alternative information (without adjustments other than those described in sections 3.01(b) and 3.10 of the revenue procedure) with respect to the SFC. See section 3 of Rev. Proc. 2019-40 for definitions of terms.

Item G—Alternative Information Code If the item F checkbox is checked, enter the applicable code from the list provided below.

alternative information only if information described in codes 01 and 02 is not readily available.

For more information, see Rev. Proc. 2019-40 .

Item H—Person(s) on Whose Behalf This Information Return Is Filed One person may file Form 5471 and the applicable schedules for other persons who have the same filing requirements. See Multiple filers of same information, earlier. The person that files the required information on behalf of other persons must complete a joint Form 5471 according to the applicable column(s) of the Filing Requirements for Categories of Filers, earlier. This includes completing item H on page 1 of the form. When completing item H with respect to members of a consolidated group, identify only the direct owners in item H (constructive owners are not required to be listed).

A separate Schedule I must be filed for each person described in Category 4, 5a, or 5b. For each Category 4, 5a, or 5b filer that is required to file a Schedule I, send a copy of their separate Schedule I to them to assist them in completing their tax return.

A separate Schedule H-1 must be attached for each person described in Category 4, 5a, or 5b. For each Category 4, 5a, or 5b filer that is required to file Schedule H-1, send a copy of their separate Schedule H-1 to them to assist them in completing their tax return.

• The name, address, and identifying number of the taxpayer on the return with which the information was or will be filed.

Filing requirements for persons identified in item H. Except for members of the filer’s consolidated return group, all persons identified in item H must attach a statement to their tax returns that includes the following information.

• The name, address, and EIN (or reference ID number) of the foreign corporation(s).

• A statement that their filing requirements with respect to the foreign corporation(s) have been or will be satisfied.

Information described in a code listed above qualifies as alternative information only if information described in any preceding code is not “readily available” (as defined in section 3.04 of Rev. Proc. 2019-40). For example, information described in code 03 above qualifies as

• The IRS Service Center where the return was or will be filed. If the return was or will be filed electronically, enter “ e-file .”

Exception. If the person who is filing Form 5471 on behalf of others is married to a person identified in item H and they are filing Form 1040 jointly, the statement described above does not have to be attached to the jointly filed Form 1040.

Caution: All persons identified in item H must complete a separate Schedule P (Form 5471) if the person is a U.S. shareholder described in Category 1a, 1b, 4, 5a, or 5b. In such a case, the Schedule P must be attached to the statement described above.

Item 1b(2)—Reference ID Number A reference ID number (defined below) is required in item 1b(2) only in cases where no EIN was entered in item 1b(1) for the foreign corporation. However, filers are permitted to enter both an EIN in item 1b(1) and a reference ID number in item 1b(2). If applicable, enter the

12 Instructions for Form 5471 (Rev. 12-2025)

reference ID number you have assigned to the foreign corporation identified in item 1a.

A “reference ID number” is a number established by or on behalf of the U.S. person identified at the top of page 1 of the form that is assigned to a foreign corporation with respect to which Form 5471 reporting is required. These numbers are used to uniquely identify the foreign corporation in order to keep track of the corporation from tax year to tax year.

The reference ID number must meet the requirements set forth below.

Note: Because reference ID numbers are established by or on behalf of the U.S. person filing Form 5471, there is no need to apply to the IRS to request a reference ID number or for permission to use these numbers.

Note: The reference ID number assigned to a foreign corporation on Form 5471 generally has relevance only on Form 5471, its schedules, and any other form that is attached to or associated with Form 5471, and generally should not be used with respect to that foreign corporation on any other IRS forms. However, the foreign corporation’s reference ID number should also be entered on Form 8858 if the foreign corporation is listed as a tax owner of an FDE or FB on Form 8858. See the instructions for Form 8858, line 3c(2), for more information. Also, if a U.S. shareholder is required to file Schedule A (Form 8992) or Schedule B (Form 8992) with respect to the CFC, the reference ID number on Form 5471 and the reference ID number used on Schedule A (Form 8992) or Schedule B (Form 8992) for that CFC must be the same.

Requirements. The reference ID number that is entered in item 1b(2) must be alphanumeric (defined below) and no special characters or spaces are permitted. The length of a given reference ID number is limited to 50 characters.

• In the case of an entity classification election that is made on behalf of a foreign corporation on Form 8832, Regulations section 301.6109-1(b)(2)(v) requires the foreign corporation to have an EIN for this election. For the first year that Form 5471 is filed after an entity classification election is made on behalf of the foreign corporation on Form 8832, the new EIN must be entered in item 1b(1) of Form 5471 and the old reference ID number must be entered in item 1b(2). In subsequent years, the Form 5471 filer may continue to enter both the EIN in item 1b(1) and the reference ID number in item 1b(2), but must enter at least the EIN in item 1b(1). You must correlate the reference ID numbers as follows: Enter the new reference ID number in item 1b(2) and enter the previous reference ID number(s) in item 1b(3). If there is more than one old reference ID number, you must enter a space between each such number. As indicated above, the length of a given reference ID number is limited to 50 characters and each number must be alphanumeric and no special characters are permitted.

Note: This correlation requirement applies only to the first year the new reference ID number is used and it applies only on Form 5471, page 1, items 1b(2) and 1b(3). On all separate schedules for Form 5471, please enter only the current reference ID number in the applicable entry space.

Item 1b(3)—Previous Reference ID Number(s), if Any See Correlation issues , earlier.

Items 1f and 1g—Principal Business Activity Enter the principal business activity code number and the description of the activity from the list at the end of these instructions.

Item 1h—Functional Currency The foreign corporation’s functional currency is determined under section 985. Enter the applicable three-character alphabet code for the foreign corporation’s functional currency using the ISO 4217 standard. These codes are available at six-group.com/en/products- services/financial-information/data- standards.html#scrollTo=currency-codes . Click on List One (XLS).

Regulations sections 1.6038-2(h) and 1.6046-1(g) require that certain amounts be reported in U.S. dollars and/or in the foreign corporation’s functional currency. The specific instructions for the affected schedules state these requirements.

Special rules apply for foreign corporations that use the U.S. dollar approximate separate transactions method of accounting (DASTM) under Regulations section 1.985-3. See Schedule C, Schedule F , and Schedule H , later.