Part II — 1225 Inst 5471 (PDF)

Category 1a, 1c, 3, 4, 5a, and 5c filers must complete Part II.

Report the direct shareholders of the foreign corporation. In the case of a CFC owned by an FDE, please include the information of the FDE and the regarded entity owner. Indicate the regarded entity owner’s name in parentheses after the FDE’s name. If there is more than one regarded entity owner, use separate lines for each, listing each regarded entity owner in column (a) and reporting the information requested in columns (b), (c), and (d) for each such regarded entity owner.

Category 4 filers should list all direct owners of the CFC. Category 1a, 3, and 5a filers should list all direct owners of the SFC or CFC through which such filer indirectly owns the SFC or CFC as described in section 958(a)(2). Category 1c and 5c filers should list all direct owners of the SFC or CFC from which such filer is attributed ownership in the SFC or CFC as described in section 958(b). If the filer is a direct owner, include the filer’s direct ownership.

Schedule C¶

Report all information in the foreign corporation’s functional currency in accordance with U.S. GAAP and translate using U.S. GAAP translation principles.

If the foreign corporation uses the DASTM under Regulations section 1.985-3, the functional currency column should reflect local hyperinflationary currency amounts computed in accordance with U.S. GAAP. The U.S. dollar column should reflect such amounts translated into dollars under U.S. GAAP translation rules. Differences between this U.S. dollar GAAP column and the U.S. dollar income or loss figured for tax purposes under Regulations section 1.985-3(c) should be accounted for on Schedule H. See Special rules for DASTM , later.

Line 8. Enter foreign currency transaction gain or loss reported on the income statement. For amounts included in Other Comprehensive Income (OCI), see Lines 23 and

24 , later. Enter unrealized gain or loss on line 8a and realized gain or loss on line 8b.

Line 16. Enter transactional taxes excluding items reportable in income tax expense (benefit). Report income taxes on line 21.

Line 20. The term “unusual or infrequently occurring items” is defined by U.S. GAAP (see FASB Accounting Standards Codification (ASC) Topic 220 (Income Statement), Subtopic 220-20 (Unusual or Infrequently Occurring Items) or subsequent guidance). If “prior period adjustments” are not reported separately on the income statement, do not report such amounts on this line item (see ASC 250 (Accounting Changes and Error Corrections) or subsequent guidance).

Line 21. Enter income tax expense (benefit) reported in accordance with U.S. GAAP (ASC 740 (Income Taxes)). Income tax expense (benefit) includes current and deferred income tax expense (benefit). It may also reflect uncertain tax positions (ASC 740-10) and would not include taxes paid in respect of uncertain tax positions recorded in prior years. Enter the current income tax expense (benefit) on line 21a and deferred income tax expense (benefit) on line 21b.

Note: If there is an income tax expense amount on line 21a or 21b, subtract that amount from the line 19 net income or (loss) amount in arriving at line 22 current-year net income or (loss) per the books. If there is an income tax benefit amount on line 21a or 21b, add that amount to the line 19 net income or (loss) amount in arriving at line 22 current-year net income or (loss) per the books.

Lines 23 and 24. Enter amounts defined in ASC 220 (Income Statement—Reporting Comprehensive Income).

Line 23a. Enter foreign currency translation adjustments before the income tax expense (benefit) is allocated.

Line 23b. Enter other comprehensive income such as foreign currency gains or losses on certain hedging transactions, pensions and other post-retirement benefits, and certain investments available for sale.

Line 23c. Enter the income tax expense (benefit) allocated to OCI items in the intraperiod allocation.

Important. Differences between the functional currency amount of income tax expense (benefit) reported on line 21 and the amount of taxes that reduce or increase U.S. E&P should be accounted for on line 2g of Schedule H.

Exceptions & meaning →

Schedule F¶

Report all information in U.S. dollars. Generally, the foreign corporation’s balance sheet is prepared in functional currency and translated to U.S. dollars using U.S. GAAP translation rules. If the foreign corporation uses DASTM, the tax balance sheet on Schedule F should be prepared and translated into U.S. dollars according to Regulations section 1.985-3(d), rather than U.S. GAAP.

Lines 3 and 17. Enter the total asset amount of derivatives on line 3 and total amount of liability on line 17 reported in accordance with ASC 815 (Derivatives and Hedging). Do not net positions.

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

Include all derivatives, both short term and long term.

Exceptions & meaning →

Schedule G¶

Note: Category 1b and 5b filers are not required to file Schedule G for foreign-controlled section 965 SFCs and foreign-controlled CFCs, respectively.

Question 1 If the foreign corporation owned at least a 10% interest, directly or indirectly, in any foreign partnership, attach a statement listing the following information for each foreign partnership.

Name and EIN (if any) of the foreign partnership.
Identify which, if any, of the following forms the foreign partnership filed for its tax year ending with or within the corporation’s tax year: Form 1042, 1065, or
Name of the partnership representative (if any).
Beginning and ending dates of the foreign partnership’s tax year.

Question 3a Check the “Yes” box if the foreign corporation is the tax owner of an FDE or FB. The “tax owner” of an FDE is the person that is treated as owning the assets and liabilities of the FDE for purposes of U.S. income tax law.

If the foreign corporation is the tax owner of an FDE or FB and you are a Category 4, 5a, or 5c filer of Form 5471, you are required to attach Form 8858 to Form 5471. If you are required to attach Form 8858 to Form 5471, the amounts reported on certain schedules on Form 8858 must be included in determining the amounts reported on the equivalent schedules as follows.

IF amounts were reported on...	THEN take those amounts into account (converting from GAAP to tax as necessary) when determining the amounts to be reported on...
Form 8858, Schedule C	Form 5471, Schedule C.
Form 8858, Schedule F	Form 5471, Schedule F.
Form 8858, Schedule H	Schedule H (Form 5471).
Form 8858, Schedule J	Schedules E and E-1 (Form 5471).
Schedule M (Form 8858)	Schedule M (Form 5471).

If the foreign corporation is the tax owner of an FDE or FB and you are not a Category 1b, 4, or 5 filer of Form 5471, you must attach the statement described below in lieu of Form 8858.

Statement in lieu of Form 8858. This statement must list the name of the FDE or FB, country under whose laws the FDE or FB was organized, and EIN (if any) of the FDE or FB.

Question 3b Check the “Yes” box if, during the tax year, the foreign corporation had one or more qualified business units as defined in section 989(a) with a functional currency different than its owner. If “Yes,” for tax years 2025 and

2026, enter the number of Forms 8964-TRA attached to Form 5471.

Questions 4b and 4c Complete lines 4b and 4c if:

The foreign corporation is a related party to the U.S. filer within the meaning of section 59A(g); and
The U.S. filer made or accrued a base erosion payment to, or has a base erosion tax benefit with respect to, the foreign corporation.

The term “base erosion payment” generally means any amount paid or accrued by the U.S. filer to a foreign corporation that is a related party to the U.S. filer within the meaning of section 59A(g) and with respect to which a U.S. deduction is allowed under chapter 1 of the Code. See section 59A(d)(1). Base erosion payments also include amounts received or accrued by the foreign corporation in connection with the acquisition of depreciable or amortizable property (section 59A(d)(2)), reinsurance payments (section 59A(d)(3)), and certain payments relating to expatriated entities (section 59A(d) (4)).

The term “base erosion tax benefit” generally means any U.S. deduction that is allowed under chapter 1 for the tax year with respect to any base erosion payment. See section 59A(c)(2)(A) and (B) for further details.

Questions 5a and 5b If the foreign corporation paid or accrued any interest or royalty (including in the case of a foreign corporation that is a partner in a partnership, the foreign corporation’s allocable share of interest or royalty paid by the partnership) for which a deduction is disallowed under section 267A, check “Yes” for question 5a and enter the total amount for which a deduction is not allowed on line 5b. The amount reported on line 5b should not include disallowed deductions attributable to interest or royalty paid or accrued by a U.S. taxable branch of the foreign corporation; such amounts are reported on Form 1120-F.

Interest or royalty paid or accrued by a foreign corporation (including through a partnership) is subject to section 267A, provided in general that the foreign corporation is a CFC (and there are one or more U.S. tax residents that own, directly or indirectly, at least 10% of the stock of the CFC). Section 267A disallows a deduction for certain interest or royalty paid or accrued pursuant to a hybrid arrangement, to the extent that, under the foreign tax law, there is not a corresponding income inclusion (including long-term deferral). For more detailed instructions, see the instructions for Form 1120, Schedule K, Question 21.

Question 6 Check the “Yes” box on line 6a if the filer is claiming a deduction under section 250 with respect to foreign-derived intangible income (FDII), and enter the amounts requested on lines 6b, 6c, and 6d. Enter U.S. dollar amounts on lines 6b, 6c, and 6d, translated from functional currency at the average exchange rate for the foreign corporation’s tax year (see section 989(b)). See Form 8993 and its instructions for information on the

Instructions for Form 5471 (Rev. 12-2025) 15

section 250 deduction. If no deduction is being claimed, check the “No” box on line 6a and go to line 7.

Question 9a Under section 367(d), a U.S. transferor must report an annual income inclusion attributed to the intangible property transferred to a foreign corporation over the useful life of the property. Check “Yes” if the foreign corporation received any intangible property in a prior year or the current tax year in an exchange under section 351 or section 361 from a U.S. transferor that is required to report a section 367(d) annual income inclusion for the tax year. If “Yes,” complete line 9b.

Question 9b Enter in functional currency the amount of the E&P reduction made by the foreign corporation for the current tax year that equals the amount required to be included in the income of the U.S. transferor. See section 367(d). This amount should also be entered on Schedule H (Form 5471), Current Earnings and Profits, as a net subtraction on line 2i.

Question 10 A foreign corporation may qualify as an expatriated foreign subsidiary under Regulations section 1.7874-12(a)(9) if such foreign corporation is a CFC with respect to which an expatriated entity, as defined in Regulations section 1.7874-12(a)(8), is a U.S. shareholder. Certain transactions involving an expatriated foreign subsidiary and/or its U.S. shareholders may be subject to special rules. If the answer to Question 10 is “Yes,” attach a statement providing the name and EIN of the domestic corporation or partnership, as defined in Regulations section 1.7874-12(a)(6), and the relationship of the foreign corporation to the domestic corporation or partnership.

Question 14 Check the “Yes” box on line 14 if you answer “Yes” to any of the questions in the Schedule G, Line 14 table below. If “Yes,” enter the corresponding code(s) from the table in the entry space provided on line 14 of the form. Enter the applicable corresponding code in capital letters. Enter a space between each code. Also attach the statement described in the table below.

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

Form 5471, Schedule G, Line 14

	Question	See in the Schedule I instructions	If “Yes,” corresponding code to enter on Schedule G, line 14	Code description	If “Yes,” content of statement to be attached to Form 5471
1	During the tax year, was the sum of the CFC’s foreign base company income (determined without regard to deductions) and gross insurance income less than the lesser of 5% of gross income or $1 million?	In other words, is line 7 less than line 8 and less than $1 million?	DM	De minimis	Amount excluded by reason of the de minimis rule (but only to the extent not already included in amounts below)
2	During the tax year, did the CFC receive any item of income that was subject to an effective rate of income tax imposed by a foreign country greater than 90% of the maximum rate of tax specified in section 11?	In other words, is line 13i, 14f, 15f, 16f, 17f, or 18j of Worksheet A greater than zero?	HT	High tax	Sum of the amounts from lines 13g, 14d, 15d, 16d, 18d, and 19d
3	During the tax year, was the CFC’s foreign personal holding company income, foreign base company sales income, foreign base company services income, or full inclusion foreign base company income reduced so as to take into account any deductions (including taxes)?	In other words, is line 13b, 13d, 13e, 14b, 15b, or 18f of Worksheet A greater than zero?	DED	Deductions taken into account	Sum of the amounts from lines 13b, 13d, 13e, 14b, 15b, and 16b
4	During the tax year, did the CFC have any gains or losses that (a) arise out of commodity hedging transactions; (b) are active business gains or losses from the sale of commodities (and substantially all of the corporation’s commodities are property described in section 1221(a)(1), (2), or (8)); or (c) are foreign currency gains or losses (as defined in section 988(b)) attributable to any section 988 transactions?	In other words, are any amounts described in section 954(c)(1)(C)(i), (ii), or (iii) excluded from line 1e of Worksheet A?	AHC	Active/ hedging commodities	Sum of the excluded amounts described in section 954(c)(1) (C)(i), (ii), and (iii)
5	During the tax year, did the CFC have excess foreign currency gains over foreign currency losses (as defined in section 988(b)) attributable to any section 988 transaction directly related to the business needs of the foreign corporation?	In other words, are any amounts excluded from line 1d of Worksheet A by reason of being attributable to a transaction(s) directly related to the business needs of the foreign corporation?	BN	Business needs	Amount excluded
6	During the tax year, did the CFC receive, from a person other than a related person within the meaning of section 954(d)(3), rents or royalties that were derived in the active conduct of a trade or business?	In other words, are any amounts described in section 954(c)(2)(A) excluded from line 1a of Worksheet A?	ARR	Active rents/ royalties	Amount excluded
7	During the tax year, did the CFC derive, in the conduct of a banking business, interest that is export financing interest?	In other words, are any amounts described in section 954(c)(2)(B) excluded from line 1a of Worksheet A?	EF	Certain export financing	Amount excluded
8	During the tax year, was the CFC a regular dealer in property described in section 954(c)(1)(B), forward contracts, option contracts, or similar financial instruments (including notional principal contracts and all instruments referenced to commodities)? If so, did the foreign corporation derive any item of income, gain, deduction, or loss (other than any item described in section 954(c)(1)(A), (E), or (G)) from any transaction entered into in the ordinary course of its trade or business as a regular dealer?	In other words, are any amounts described in section 954(c)(2)(C)(i) excluded from line 1a of Worksheet A?	RD	Regular dealers	Amount excluded

Instructions for Form 5471 (Rev. 12-2025) 17

Form 5471, Schedule G, Line 14 (continued)

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

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

Form 5471, Schedule G, Line 14 (continued)

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

Instructions for Form 5471 (Rev. 12-2025) 19

Form 5471, Schedule G, Line 14 (continued)

	Question	See Worksheet A in the Schedule I instructions	If “Yes,” corresponding code to enter on Schedule G, line 14	Code description	If “Yes,” content of statement to be attached to Form 5471
21	During the tax year, did the subpart F income of the CFC exceed the earnings and profits of such corporation?	In other words, do E&P on line(s) 13g, 14d, 15d, 16d, 17d, and/or 18h of Worksheet A exceed amounts on line(s) 13f, 14c, 15c, 16c, 17c, and/or 18g, respectively?	EP	Earnings & profits limitation	Excess of line(s) 13g, 14d, 15d, 16d, 17d, and/or 18h (as applicable), over line(s) 13f, 14c, 15c, 16c, 17c, and/or 18g (as applicable)
22a	In determining the pro rata share of subpart F income or tested items of the U.S. person filing this return, was the amount of distributions by the CFC during the tax year and described in section 951(a)(2)(B) greater than zero?	In other words, is line 46 of Worksheet A greater than zero?	PRS	Pro rata share	The amounts from lines 46 and 47 of Worksheet A
22b	Was any amount of the dividends paid (or deemed paid) during the tax year by the CFC (with respect to the stock owned by the U.S. person filing this return) described in section 70354(c)(2)(A) of the OBBBA and also treated by the U.S. person filing this return as a dividend for purposes of applying section 951(a)(2)(B) (as unamended by the OBBBA)? See Notice 2025-75.	In other words, does the amount on line 46 of Worksheet A include the amount of any dividends paid (or deemed paid) by the CFC that are also described in section 70354(c)(2)(A) of the OBBBA? See Notice 2025-75.	PRST	Pro Rata Share Transition Rule	The amount of each dividend paid (or deemed paid) by the CFC (with respect to the stock owned by the U.S. person filing this return) that is described in section 70354(c)(2)(A) of the OBBBA but that was nonetheless treated as a dividend by the U.S. person filing this return for purposes of applying section 951(a) (2)(B). See Notice 2025-75. Include a statement describing why the U.S. person filing this return is entitled to treat this amount as a dividend for purposes of section 951(a)(2)(B) after application of the Pro Rata Share Transition Rule. This statement must describe how the U.S. person filing this return determined that the dividend increased the taxable income of a U.S. person subject to federal income tax within the meaning of section 70354(c)(2)(B) of the OBBBA. See Notice 2025-75.
23	Is the U.S. person filing this return relying on any exception(s), exclusion(s), or other provision(s) not listed above to reduce or exclude any amounts reported or reportable as subpart F income (of or with respect to the CFC)?		XX	Other	Amount excluded, reduction amount, or other amount not reported or reportable

Question 15 For the foreign corporation’s annual accounting period with respect to which reporting is being made on this Form 5471, if the foreign corporation is required to file a U.S.

income tax return (for example, Form 1120-F), check the “Yes” box if the foreign corporation has interest expense disallowed under section 163(j). If “Yes,” enter the amount from the current-year Form 8990, line 31.

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

Question 16 For the foreign corporation’s annual accounting period with respect to which reporting is being made on this Form 5471, if the foreign corporation is required to file a U.S. income tax return (for example, Form 1120-F), check the “Yes” box if the foreign corporation has previously disallowed interest expense under section 163(j) carried forward to the current tax year. If “Yes,” enter the amount from the prior-year Form 8990, line 31.

Question 17a Check the “Yes” box on line 17a if there was an extraordinary reduction with respect to any controlling section 245A shareholder of the foreign corporation, as defined in Regulations section 1.245A-5(i)(2), during the tax year of the foreign corporation. See Regulations section 1.245A-5(e)(2)(i) for the definition of extraordinary reduction.

Question 17b If the answer to the question on line 17a was “Yes,” complete the question on line 17b. Check the “Yes” box on line 17b if any controlling section 245A shareholder (as defined in Regulations section 1.245A-5(i)(2)) made an election to close the tax year of the foreign corporation such that no amount is treated as an extraordinary reduction amount or tiered extraordinary reduction amount as to any U.S. shareholder of the foreign corporation. See Regulations section 1.245A-5(e)(3)(i) for further guidance regarding the election to close the tax year. If the “Yes” box on line 17b has been checked and the U.S. shareholder filing the Form 5471 is a controlling section 245A shareholder of the foreign corporation, the U.S. shareholder filing this Form 5471 must attach an Elective Section 245A Year-Closing Statement pursuant to Regulations section 1.245A-5(e)(3)(i)(C) containing the information required under Regulations section 1.245A-5(e)(3)(i)(D).

Question 18a Check the “Yes” box if during the tax year the filer had any loans to or from the foreign corporation to which the safe-haven rate rules of Regulations section 1.482-2(a)(2) (iii)(B) are applicable, and for which the filer used a rate of interest within the relevant safe-haven range of Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to 130% of the applicable federal rate for the relevant term).

Question 18b Check the “Yes” box if during the tax year the filer had any loans to or from the foreign corporation to which the safe-haven rate rules of Regulations section 1.482-2(a)(2) (iii)(B) are applicable, and for which the filer used a rate of interest outside the relevant safe-haven range of Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to 130% of the applicable federal rate for the relevant term).

Questions 19a and 19b Complete lines 19a and 19b only if the filer is a domestic corporation. In completing these lines, do not account for debt instruments that were issued, or distributions or acquisitions that occurred, before April 5, 2016. See Regulations section 1.385-3(g)(3) and 1.385-3(b)(3)(viii).

Question 19a Check the “Yes” box if the filer issued a covered debt instrument in any of the transactions described in Regulations section 1.385-3(b)(2) with respect to the foreign corporation during the tax year. Also check the “Yes” box if the filer issued or refinanced indebtedness owed to a foreign corporation during the 36 months before or after the date of a distribution or acquisition described in Regulations section 1.385-3(b)(3)(i) made by the filer, and either the issuance or refinance of indebtedness, or the distribution or acquisition, occurred during the tax year. Otherwise, check “No.” Apply Regulations section 1.385-3(b)(3)(iii)(E) to determine when a debt instrument is treated as issued for purposes of Regulations section 1.385-3(b)(3)(iii). Apply Regulations section 1.385-3(f) in the case of a controlled partnership within the meaning of Regulations section 1.385-1(c)(1).

Debt that the filer treats as stock pursuant to Regulations section 1.385-3 should still be included when completing line 19a.

Question 19b Provide the total amount of the transactions described in Regulations section 1.385-3(b)(2) (as measured by the fair market value (FMV) of the distribution or, as the case may be, the property exchanged for the debt instrument), and of the distributions and/or acquisitions described in Regulations section 1.385-3(b)(3)(i) (as measured by the FMV of the property distributed and/or acquired).

Provide the total amount (as measured by issue price in the case of an instrument treated as stock upon issuance, or adjusted issue price in the case of an instrument deemed exchanged for stock) of the debt instrument issuances addressed by line 19a. See Regulations sections 1.385-1(d)(1) and 1.385-3(d). The adjusted issue price of a debt instrument is the issue price increased by the amount of original issue discount previously includible in gross income of any holder and decreased by payments other than payments of stated interest. See section 1272(a)(4) and Regulations section 1.1275-1(b) (1).

Questions 20a and 20b Certain jurisdictions have enacted legislation to implement the GloBE Model Rules for the Qualified Domestic Minimum Top-up Tax (QDMTT), Income Inclusion Rule (IIR), and UTPR. See Org. for Econ. Coop. & Dev.

[OECD], Tax Challenges Arising From the Digitalization of the Economy — Global Anti-Base Erosion Model Rules (Pillar Two) (Dec. 14, 2021), at DOI.org/ 10.1787/782bac33-en . Under these rules, if the Effective Tax Rate (ETR) for a jurisdiction is below 15%, Top-up Tax may be imposed. The amount of Top-up Tax is determined by multiplying the Top-up Tax Percentage (the positive excess of 15% over the ETR in the jurisdiction) by the Excess Profits (the positive amount of the Net GloBE Income in such jurisdiction that exceeds a Substance-based Income Exclusion). The Top-up Tax is collected under the QDMTT, IIR, and/or UTPR.

If the foreign corporation paid or accrued any Top-up Tax during the tax year, check the "Yes" box for Question 20a on page 6 of the form and enter the amount of

Instructions for Form 5471 (Rev. 12-2025) 21

QDMTT, IIR, and/or UTPR (or similar tax) paid or accrued during the tax year in the space provided on lines 20b(1), 20b(2), and 20b(3).

For more information, see Notice 2023-80, I.R.B. 2023-52 1583, available at IRS.gov/IRB/ 2023-52_IRB#NOT-2023-80 .

Questions 21a and 21b If, during the tax year, any portion of any increase or decrease to the foreign corporation’s E&P (including previously taxed E&P described in section 959) was attributable to a transaction described in section 304, the filer is required to check the “Yes” box on line 21a and do the following.

Enter on line 21b(1) the change in PTEP described in section 959(c)(1) and (c)(2).
Enter on line 21b(2) the change in other E&P described in section 959(c)(3).

Enter the amounts on lines 21b(1) and 21b(2) in functional currency.

Exceptions & meaning →

Schedule I¶

Use Schedule I to report in U.S. dollars the U.S. shareholder’s pro rata share of income from the foreign corporation reportable under subpart F and other income realized from a corporate distribution.

Certain filers may be able to use alternative information (as defined in section 3.01 of Rev. Proc. 2019-40) to determine certain amounts in this schedule. See Item F—Alternative Information Under Rev. Proc. 2019-40 , earlier, for more details.

Note: A separate Schedule I must be filed by or for each Category 4, 5a, or 5b U.S. shareholder of the foreign corporation with respect to which reporting is furnished on this Form 5471.

Line 1

Subpart F income. U.S. shareholders of CFCs with subpart F income must report that income on their tax returns. For more information, see sections 245A, 951, 952, and 964(e).

Note: Certain current-year deficits of a member of the same chain of corporations may be considered in determining subpart F income. See section 952(c)(1)(C).

Line 1a Corporate U.S. shareholders should enter the foreign-source portion of any subpart F income inclusions attributable to the sale or exchange by a CFC of stock of another foreign corporation that is eligible for the section 245A dividends-received deduction pursuant to section 964(e)(4). Include the amount, if any, that is not eligible for the section 245A dividends-received deduction pursuant to section 964(e)(4) on line 1e. Noncorporate U.S. shareholders should leave line 1a blank.

Line 1b Enter the amount of the U.S. shareholder’s subpart F income inclusion attributable to tiered hybrid dividends received by the CFC. In general, a dividend received by a

CFC from another CFC is a tiered hybrid dividend to the extent of the sum of the receiving CFC’s hybrid deduction accounts with respect to shares of stock of the CFC that pays the dividend. As to a domestic corporation that is a U.S. shareholder with respect to both CFCs, the tiered hybrid dividend is treated as subpart F income of the receiving CFC, and the U.S. shareholder must include in its gross income its pro rata share of the tiered hybrid dividend. See section 245A(e)(2) and Regulations section 1.245A(e)-1(c) for additional information about tiered hybrid dividends.

Line 1c Enter the U.S. shareholder’s subpart F income inclusion attributable to tiered extraordinary disposition amounts resulting from distributions from an extraordinary disposition account of the shareholder filing this Form 5471 and received by the foreign corporation. See Regulations section 1.245A-5(d) for further guidance on tiered extraordinary disposition amounts.

Line 1d Enter the U.S. shareholder’s subpart F income inclusion attributable to tiered extraordinary reduction amounts resulting from extraordinary reductions. See Regulations section 1.245A-5(f) for further guidance on tiered extraordinary reduction amounts.

Lines 1e Through 1h Enter on lines 1e through 1h the amounts from Worksheet A, lines 53, 57, 61, and 67, respectively. However, corporate U.S. shareholders should report on line 1e the amount from Worksheet A, line 53, less the amount, if any, reported on line 1a.

Use Worksheet A to compute the U.S. shareholder’s pro rata share of subpart F income of the CFC, which is reportable on lines 1e through 1h. Do not include any income includible on Form 5471, Schedule I, lines 1a through 1d, or any income includible under section 951A (Schedule I-1 is used to provide information relating to section 951A). Subpart F income reportable on lines 1e through 1h includes the following.

Adjusted net foreign base company income (Worksheet

A, lines 13, 14, 15, and 18).

Important. If the subpart F income of a CFC for any tax year was reduced because of the current E&P limitation, any excess of the E&P of the CFC for any subsequent tax year over the subpart F income of the CFC for the tax year must be recharacterized as subpart F income. As a result, if the foreign corporation has E&P for the tax period covered by this return that is subject to recapture as a result of a prior-year E&P limitation, add the U.S. shareholder’s pro rata share of such recapture amount to the result from Worksheet A, line 67, and include the

• Adjusted net insurance income (Worksheet A, line 16).

Adjusted net related person insurance income

(Worksheet A, line 17).

• International boycott income (Worksheet A, line 19).

Illegal bribes, kickbacks, and other payments (Worksheet A, line 20).

• Income described in section 952(a)(5) (Worksheet A, line 21).

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

combined amount on line 1h (Other subpart F income). See Line 37. Current E&P limitation , later, for a discussion of the current-year E&P limitation. See also Regulations section 1.952-1(f) for further guidance on recharacterization of E&P as subpart F income.

Line 2 Report on line 2 the section 956 amount with respect to the U.S. shareholder. See Worksheet B, line 19.

Line 3 Reserved for future use.

Line 4 Enter the U.S. shareholder’s pro rata share of the factoring income (as defined in section 864(d)(1)) if no subpart F income is reported on line 1a of Worksheet A because of the operation of the de minimis rule (see lines 1a and 10 of Worksheet A and the related instructions under Line 1a and Line 10. De minimis rule, later).

Reporting Amounts on Lines 1 Through 4 on Your Income Tax Return

For a corporate shareholder, enter the result from Form 5471, Schedule I, line 1a on Form 1120, Schedule C, line 16a; enter the result from Form 5471, Schedule I, line 1b on Form 1120, Schedule C, line 16b; and enter the results from remaining Form 5471, Schedule I, lines 1c through 1h, 2, and 4 on Form 1120, Schedule C, line 16c; or on the comparable line of other corporate tax returns. For a noncorporate U.S. shareholder, enter the results on Schedule 1 (Form 1040), line 8n (Other income–section 951(a) inclusion), or on the comparable line of other noncorporate tax returns.

Line 5a Enter the amount of dividends received by the shareholder from the foreign corporation that is eligible for a deduction under section 245A. This amount does not include the amount of dividends that are not eligible for a deduction under section 245A and are instead entered on lines 5b, 5c, and 5d. See section 245A for guidance on computing the amount of a dividend eligible for a deduction.

Note: The corporate U.S. shareholder should include the Form 5471, Schedule I, line 5a amount in column (a) of Form 1120, Schedule C, line 13, or on the comparable line of other corporate income tax returns. In doing so, the corporate U.S. shareholder must determine whether it meets the statutory and regulatory requirements for the section 245A dividends-received deduction.

Line 5b Enter the amount of the dividends received by the shareholder from the foreign corporation that is an extraordinary disposition amount. See Regulations section 1.245A-5(c) for rules for calculating an extraordinary disposition amount.

Note: The corporate U.S. shareholder should include the Form 5471, Schedule I, line 5b amount in column (a) of

Form 1120, Schedule C, line 14, or on the comparable line of other corporate income tax returns.

Line 5c Enter the amount of the dividends received by the shareholder from the foreign corporation that is an extraordinary reduction amount. See Regulations section 1.245A-5(e) for rules for calculating an extraordinary reduction amount.

Note: The corporate U.S. shareholder should include the Form 5471, Schedule I, line 5c amount in column (a) of Form 1120, Schedule C, line 14, or on the comparable line of other corporate income tax returns.

Line 5d Enter the amount of hybrid dividends received by the U.S. shareholder from the foreign corporation. In general, in the case of a domestic corporation that is a U.S. shareholder with respect to a CFC, a dividend received by the domestic corporation from the CFC is a hybrid dividend to the extent of the sum of the U.S. shareholder’s hybrd deduction accounts with respect to shares of stock of the CFC. See section 245A(e) and Regulations section 1.245A(e)-1(b) for additional information about hybrid dividends.

Note: The corporate U.S. shareholder should include the Form 5471, Schedule I, line 5d amount in column (a) of Form 1120, Schedule C, line 14, or on the comparable line of other corporate income tax returns.

Line 5e Enter on line 5e dividends not reported on line 5a, 5b, 5c, or 5d.

Note: The corporate U.S. shareholder should include the Form 5471, Schedule I, line 5e amount on Form 1120, Schedule C, line 14, column (a), or on the comparable line of other corporate income tax returns.

Line 6 If previously taxed E&P (PTEP) were distributed, enter the amount of foreign currency gain or (loss) recognized on the distribution, computed under section 986(c). See Notice 88-71, 1988-2 C.B. 374, for rules for computing section 986(c) gain or (loss), and Regulations section 1.986(c)-1(a) and (b) for rules for computing section 986(c) gain or (loss) recognized with respect to distributions of PTEP within the reclassified section 965(a) PTEP group and the section 965(a) PTEP group. Do not include any foreign currency gain or loss with respect to PTEP within the reclassified section 965(b) PTEP group or the section 965(b) PTEP group. See Regulations section 1.986(c)-1(c).

For a corporate U.S. shareholder, include the gain or (loss) as “Other income” on Form 1120, page 1, line 10, or on the comparable line of other corporate tax returns. For a noncorporate U.S. shareholder, include the result as “Other income” on Schedule 1 (Form 1040), line 8z (Other income), or on the comparable line of other noncorporate tax returns.

Instructions for Form 5471 (Rev. 12-2025) 23

Line 8a Check the “Yes” box on line 8a if the U.S. shareholder completing this form had an extraordinary disposition account with respect to the foreign corporation having a balance greater than zero at any time during the tax year of the foreign corporation. See Regulations section 1.245A-5(c) for rules regarding an extraordinary disposition account.

Line 8b If “Yes” is checked on line 8a, enter on line 8b the U.S. shareholder’s extraordinary disposition account balance at the beginning and end of the foreign corporation’s tax year. Attach a statement detailing any differences between the starting and ending balance of the extraordinary disposition account reported on line 8b.

Line 8c Enter on line 8c the CFC’s total extraordinary disposition account balance with respect to all U.S shareholders of the CFC at the beginning of the CFC year and at the end of the CFC tax year. Attach a statement detailing any differences between the starting and ending balances reported on line 8c.

Line 9 If the foreign corporation is a CFC and the filer is a domestic corporation, enter on line 9 the sum of the hybrid deduction accounts with respect to each share of stock of the CFC that the domestic corporation owns directly or indirectly (within the meaning of section 958(a)(2), and determined by treating a domestic partnership as foreign). The reported amount should reflect the balance of the hybrid deduction accounts as of the close of the tax year of the CFC, and after all adjustments to the hybrid

deduction accounts for the tax year (for example, to reflect hybrid deductions of the CFC or hybrid dividends paid by the CFC). For example, if the CFC is an upper-tier CFC all the stock of which is owned by the filer, then line 9 must reflect the sum of the filer’s hybrid deduction accounts with respect to shares of stock of the upper-tier CFC; if instead the CFC is a lower-tier CFC all the stock of which is owned by the filer through an upper-tier CFC, then line 9 must reflect the sum of the upper-tier CFC’s hybrid deduction accounts with respect to shares of stock of the lower-tier CFC.

A hybrid deduction account with respect to a share of stock of a CFC reflects the amount of hybrid deductions of the CFC that has been allocated to the share. In general, a hybrid deduction is a deduction or other tax benefit allowed to the CFC (or a related person) under a foreign tax law for an amount paid, accrued, or distributed with respect to an instrument of the CFC that is stock for U.S. tax purposes. A hybrid deduction includes a deduction allowed to the CFC under a foreign tax law with respect to equity (such as a notional interest deduction). See Regulations section 1.245A(e)-1(d) for additional information about hybrid deduction accounts.

A domestic corporation that is a U.S. shareholder with respect to a CFC must maintain a hybrid deduction account with respect to each share of stock of the CFC that the domestic corporation owns directly or indirectly through a partnership, trust, or estate. In addition, certain upper-tier CFCs must maintain a hybrid deduction account with respect to each share of the stock of a lower-tier CFC that the upper-tier CFC owns directly or indirectly through a partnership, trust, or estate. See Regulations section 1.245A(e)-1(d) for more on maintenance of hybrid deduction accounts.

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

Worksheet A

Summary of U.S. Shareholders Pro Rata Share of Subpart F Income of a CFC (See Worksheet A Instructions, later.) Enter the amounts on lines 1a through 51, 55, 59, and 67 in functional currency.

|1 Gross foreign personal holding company income (determined after the application of section
952(b)):
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 Income equivalent to interest (section 954(c)(1)(E)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1b
c Net income from a notional principal contract (section 954(c)(1)(F)) . . . . . . . . . . . . . . . . . . . . . . . . . 1c
d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D)) . . . . . . . . . . . . 1d
e Excess of gains over losses from commodity transactions (section 954(c)(1)(C)) . . . . . . . . . . . . . . . 1e
f Excess of gains over losses from certain property transactions (section 954(c)(1)(B)) . . . . . . . . . . . . 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3 Gross foreign base company sales income (determined after the application of section 952(b)) (see section
954(d)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4 Gross foreign base company services income (determined after the application of section 952(b)) (see section
954(e)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5 Gross foreign base company income. Add lines 2 through 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6 Gross insurance income (determined after the application of section 952(b)) (see sections 953 and 954 (b)(3)(C) and the
instructions for lines 16 and 17) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7 Gross foreign base company income and gross insurance income. Add lines 5 and 6 . . . . . . . . . . . . . . . . . . . . . . . . . .
8 Enter 5% of total gross income (as computed for income tax purposes) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
9 Enter 70% of total gross income (as computed for income tax purposes) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10 If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 18 . . . . . . . . . . . . . . .
11 If line 7 is more than line 9, enter total gross income (as computed for income tax purposes) . . . . . . . . . . . . . . . . . . . . .
12 Total adjusted gross foreign base company income and insurance income (enter the greater of line 7 or line 11). See
instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13 Adjusted net foreign personal holding company income:
a Enter amount from line 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13a
b Expenses definitely 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 Amount of line 13f excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13g
h Subtract line 13g from line 13f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13h
i Amount of line 13h excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 13i
j Adjusted net foreign personal holding company income. Subtract line 13i from line 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 Amount of line 14c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14d

e Subtract line 14d from line 14c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14e
f Amount of line 14e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 14f
g Adjusted net foreign base company sales income. Subtract line 14f from line 14e . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15 Adjusted net foreign base company services income:
a Enter amount from line 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15a
b Expenses allocated and apportioned to the amount on line 4 under section 954(b)(5) . . . . . . . . . . . . 15b
c Net foreign base company services income. Subtract line 15b from line 15a . . . . . . . . . . . . . . . . . . . 15c
d Amount of line 15c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15d
e Subtract line 15d from line 15c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15e
f Amount of line 15e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 15f
g Adjusted net foreign base company services income. Subtract line 15f from line 15e . . . . . . . . . . . . . . . . . . . . . . . . . . .|1a|Col3|2|Col5|

|---|---|---|---|---|

|1
Gross foreign personal holding company income (determined after the application of section
952(b)):
1a
a Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A) (excluding amounts described
in sections 954(c)(2), (3), and (6)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
b Income equivalent to interest (section 954(c)(1)(E)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1b
c Net income from a notional principal contract (section 954(c)(1)(F)) . . . . . . . . . . . . . . . . . . . . . . . . .
1c
d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D))
. . . . . . . . . . . .
1d
e Excess of gains over losses from commodity transactions (section 954(c)(1)(C))
. . . . . . . . . . . . . . .
1e
f Excess of gains over losses from certain property transactions (section 954(c)(1)(B)) . . . . . . . . . . . .
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
3
Gross foreign base company sales income (determined after the application of section 952(b)) (see section
954(d))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4
Gross foreign base company services income (determined after the application of section 952(b)) (see section
954(e))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
5
Gross foreign base company income. Add lines 2 through 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
Gross insurance income (determined after the application of section 952(b)) (see sections 953 and 954 (b)(3)(C) and the
instructions for lines 16 and 17)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7
Gross foreign base company income and gross insurance income. Add lines 5 and 6
. . . . . . . . . . . . . . . . . . . . . . . . . .
8
Enter 5% of total gross income (as computed for income tax purposes)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
9
Enter 70% of total gross income (as computed for income tax purposes)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10
If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 18
. . . . . . . . . . . . . . .
11
If line 7 is more than line 9, enter total gross income (as computed for income tax purposes) . . . . . . . . . . . . . . . . . . . . .
12
Total adjusted gross foreign base company income and insurance income (enter the greater of line 7 or line 11). See
instructions
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13
Adjusted net foreign personal holding company income:
a Enter amount from line 2
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13a
b Expenses definitely 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 Amount of line 13f excluded pursuant to section 952(c)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13g
h Subtract line 13g from line 13f
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13h
i Amount of line 13h excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .
13i
j Adjusted net foreign personal holding company income. Subtract line 13i from line 13h . . . . . . . . . . . . . . . . . . . . . . . . .
14
Adjusted net foreign base company sales income:
14a
a Enter amount from line 3
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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 Amount of line 14c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14d
e Subtract line 14d from line 14c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14e
f Amount of line 14e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .
14f
g Adjusted net foreign base company sales income. Subtract line 14f from line 14e . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15
Adjusted net foreign base company services income:
15a
a Enter amount from line 4
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
b Expenses allocated and apportioned to the amount on line 4 under section 954(b)(5) . . . . . . . . . . . .
15b
c Net foreign base company services income. Subtract line 15b from line 15a . . . . . . . . . . . . . . . . . . .
15c
d Amount of line 15c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15d
e Subtract line 15d from line 15c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15e
f Amount of line 15e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .
15f
g Adjusted net foreign base company services income. Subtract line 15f from line 15e . . . . . . . . . . . . . . . . . . . . . . . . . . .
|1b||||

Worksheet A ( continued )

Worksheet A ( continued ) (See instructions.)

|16 Adjusted net insurance income (other than related person insurance income):
a Enter amount from line 6 (other than related person insurance income) . . . . . . . . . . . . . . . . . . . . . . 16a
b Expenses allocated and apportioned to the amount on line 16a under section 953 . . . . . . . . . . . . . . 16b
c Net insurance income. Subtract line 16b from line 16a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16c
d Amount of line 16c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16d
e Subtract line 16d from line 16c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16e
f Amount of line 16e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 16f
g Adjusted net insurance income. Subtract line 16f from line 16e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16g
17 Adjusted net related person insurance income:
a Enter amount from line 6 that is related person insurance income . . . . . . . . . . . . . . . . . . . . . . . . . . . 17a
b Expenses allocated and apportioned to the amount on line 17a under section 953 . . . . . . . . . . . . . . 17b
c Net related person insurance income. Subtract line 17b from line 17a . . . . . . . . . . . . . . . . . . . . . . . . 17c
d Amount of line 17c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17d
e Subtract line 17d from line 17c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17e
f Amount of line 17e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 17f
g Adjusted net related person insurance income. Subtract line 17f from line 17e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18 Adjusted net full inclusion foreign base company income:
a Enter the excess, if any, of line 12 over line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18a
b Enter amount from line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18b
c Multiply line 18b by 90% (0.9) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18c
d Amount of lines 13a, 14a, 15a, 16a, and 17a attributable to items excluded pursuant to the high-tax
exception of section 954(b)(4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18d
e If line 18d is more than line 18c, enter zero here and skip the remainder of line 18. If line 18d is less
than or equal to line 18c, enter the amount on line 18a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18e
f Expenses allocated and apportioned to the amount on line 18e under section 954(b)(5) . . . . . . . . . . 18f
g Net full inclusion foreign base company income. Subtract line 18f from line 18e . . . . . . . . . . . . . . . . 18g
h Amount of line 18g excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18h
i Subtract line 18h from line 18g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18i
j Amount of line 18i excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 18j
k Adjusted net full inclusion foreign base company income. Subtract line 18j from line 18i . . . . . . . . . . . . . . . . . . . . . . . .
19 International boycott income (section 952(a)(3)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
20 Illegal bribes, kickbacks, and other payments (section 952(a)(4)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21 Income described in section 952(a)(5) (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22 Subpart F income before application of section 959(b) and section 961(c). Add lines 13j, 14g, 15g, 16g, 17g, 18k, and 19
through 21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
23 Exclusions under section 959(b) and section 961(c) basis that apply to line 13j amount . . . . . . . . . . . 23
24 Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract line 23 from line 13j . . . . . . . . . . .
25 Exclusions under section 959(b) that apply to line 14g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 -0-
26 Section 954(d) subpart F Foreign Base Company Sales Income. Subtract line 25 from line 14g . . . . . . . . . . . . . . .
27 Exclusions under section 959(b) that apply to line 15g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 -0-
28 Section 954(e) subpart F Foreign Base Company Services Income. Subtract line 27 from line 15g . . . . . . . . . . . .
29 Exclusions under section 959(b) that apply to lines 16g, 17g, 18k, 19, 20, and 21 amounts . . . . . . . . 29
30 Other subpart F income. Subtract line 29 from the sum of lines 16g, 17g, 18k, 19, 20, and 21 . . . . . . . . . . . . . . . . . . .
31 Total subpart F income. Add lines 24, 26, 28, and 30 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
32 Shareholder’s pro rata share of line 24 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32
33 Shareholder’s pro rata share of export trade income that applies to line 32 amount (see section

970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33
34 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 33 from line 32 . . . . . . . . .
35 Shareholder’s pro rata share of line 26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
36 Shareholder’s pro rata share of export trade income that applies to line 35 amount (see section
970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36
37 Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 36 from line 35 . . . . . . . . . . . . .
38 Shareholder’s pro rata share of line 28 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
39 Shareholder’s pro rata share of export trade income that applies to line 38 amount (see section
970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39|16a|Col3|17g|Col5|

|---|---|---|---|---|

|16
Adjusted net insurance income (other than related person insurance income):
16a
a Enter amount from line 6 (other than related person insurance income)
. . . . . . . . . . . . . . . . . . . . . .
b Expenses allocated and apportioned to the amount on line 16a under section 953
. . . . . . . . . . . . . .
16b
c Net insurance income. Subtract line 16b from line 16a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
16c
d Amount of line 16c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
16d
e Subtract line 16d from line 16c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
16e
f Amount of line 16e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .
16f
g Adjusted net insurance income. Subtract line 16f from line 16e . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
16g
17
Adjusted net related person insurance income:
17a
a Enter amount from line 6 that is related person insurance income . . . . . . . . . . . . . . . . . . . . . . . . . . .
b Expenses allocated and apportioned to the amount on line 17a under section 953
. . . . . . . . . . . . . .
17b
c Net related person insurance income. Subtract line 17b from line 17a . . . . . . . . . . . . . . . . . . . . . . . .
17c
d Amount of line 17c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
17d
e Subtract line 17d from line 17c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
17e
f Amount of line 17e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .
17f
g Adjusted net related person insurance income. Subtract line 17f from line 17e
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18
Adjusted net full inclusion foreign base company income:
18a
a Enter the excess, if any, of line 12 over line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
b Enter amount from line 7
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18b
c Multiply line 18b by 90% (0.9) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18c
d Amount of lines 13a, 14a, 15a, 16a, and 17a attributable to items excluded pursuant to the high-tax
exception of section 954(b)(4)
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18d
e If line 18d is more than line 18c, enter zero here and skip the remainder of line 18. If line 18d is less
than or equal to line 18c, enter the amount on line 18a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18e
f Expenses allocated and apportioned to the amount on line 18e under section 954(b)(5) . . . . . . . . . .
18f
g Net full inclusion foreign base company income. Subtract line 18f from line 18e
. . . . . . . . . . . . . . . .
18g
h Amount of line 18g excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18h
i Subtract line 18h from line 18g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18i
j Amount of line 18i excluded pursuant to the high-tax exception of section 954(b)(4)
. . . . . . . . . . . . .
18j
k Adjusted net full inclusion foreign base company income. Subtract line 18j from line 18i
. . . . . . . . . . . . . . . . . . . . . . . .
19
International boycott income (section 952(a)(3))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
20
Illegal bribes, kickbacks, and other payments (section 952(a)(4)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
21
Income described in section 952(a)(5) (see instructions) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
22
Subpart F income before application of section 959(b) and section 961(c). Add lines 13j, 14g, 15g, 16g, 17g, 18k, and 19
through 21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
23
Exclusions under section 959(b) and section 961(c) basis that apply to line 13j amount . . . . . . . . . . .
23
24
Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract line 23 from line 13j . . . . . . . . . . .
25
Exclusions under section 959(b) that apply to line 14g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
25
-0-
26
Section 954(d) subpart F Foreign Base Company Sales Income. Subtract line 25 from line 14g . . . . . . . . . . . . . . .
27
Exclusions under section 959(b) that apply to line 15g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
27
-0-
28
Section 954(e) subpart F Foreign Base Company Services Income. Subtract line 27 from line 15g
. . . . . . . . . . . .
29
Exclusions under section 959(b) that apply to lines 16g, 17g, 18k, 19, 20, and 21 amounts
. . . . . . . .
29
30
Other subpart F income. Subtract line 29 from the sum of lines 16g, 17g, 18k, 19, 20, and 21 . . . . . . . . . . . . . . . . . . .
31

Total subpart F income. Add lines 24, 26, 28, and 30
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
32
Shareholder’s pro rata share of line 24
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
32
33
Shareholder’s pro rata share of export trade income that applies to line 32 amount (see section
970(a))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
33
34
Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 33 from line 32
. . . . . . . . .
35
Shareholder’s pro rata share of line 26
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
35
36
Shareholder’s pro rata share of export trade income that applies to line 35 amount (see section
970(a))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
36
37
Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 36 from line 35
. . . . . . . . . . . . .
38
Shareholder’s pro rata share of line 28
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
38
39
Shareholder’s pro rata share of export trade income that applies to line 38 amount (see section
970(a))
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
39|16b||||

26 Instructions for Form 5471

Worksheet A ( continued )

Worksheet A ( continued ) (See instructions.)

Instructions for Form 5471 27

Worksheet A Instructions

Foreign base company income. Foreign base company income generally does not include the following.

Foreign base company shipping or oil related income as defined in former section 954(f) and (g), respectively.
Foreign personal holding company income derived in the active conduct of a banking, finance, or similar business (section 954(h)).
Exempt insurance income under section 953(e) and certain investment income of a qualifying insurance company or a qualifying insurance branch (sections 953(a)(2) and 954(i)).
Certain income derived in the ordinary course of business of a securities dealer (section 954(c)(2)(C)(i)).

Note: Lines 1 through 4, relating to gross foreign personal holding company income, gross foreign base company sales income, and gross foreign base company services income, must be completed after the application of section 952(b). See Regulations section 1.954-1(a)(2).

Line 1. Gross foreign personal holding company in- come. If income is foreign personal holding company income, it is not considered income in any other category of foreign base company income, except as provided in Regulations section 1.954-1(e)(4)(i)(A) through (C).

Line 1b. Income equivalent to interest. Enter any income equivalent to interest, including income from commitment fees (or similar amounts) for loans actually made.

Line 1c. Net income from a notional principal con- tract. Include net income from notional principal contracts (except a contract entered into to hedge inventory property).

Line 1d. Excess of foreign currency gains over for- eign currency losses. Enter the excess of foreign currency gains over foreign currency losses from section 988 transactions. An exception applies to transactions directly related to the business needs of a CFC.

Line 1e. Excess of gains over losses from commodity transactions. Enter the excess of gains over losses from transactions (including futures, forward, and similar transactions) in any commodities. See section 954(c)(1) (C) for exceptions. See section 954(c)(5) for a definition and special rules relating to commodity transactions.

Property that produces the type of income reportable on line 1a;
An interest in a trust, partnership, or REMIC; however, see line 1i, later, for an exception that provides for look-through treatment for certain sales of partnership interests; or
Property that does not produce any income. Do not include the following.
Income, gain, deduction, or loss from any transaction (including a hedging transaction) and transactions involving physical settlement of a regular dealer in property, forward contracts, option contracts, and similar financial instruments (section 954(c)(2)(C)).

Line 1f. Excess of gains over losses from certain property transactions. Enter the excess of gains over losses from the sale or exchange of:

Line 1a. Dividends, interest, royalties, rents, and an- nuities. Do not include:

Interest from conducting a banking business that is “export financing interest” (section 904(d)(2)(G));
Rents and royalties from actively conducting a trade or business received from a person other than a “related person” (as defined in section 954(d)(3)); and
Dividends, interest, rent, or royalty income from related corporate payors described in section 954(c)(3) or (6). However, see section 964(e) for an exception to section 954(c)(3), and see section 964(e)(4) and Regulations section 1.245A-5 for an exception to, and limitation on, section 954(c)(6), respectively.

Interest income includes factoring income arising when a person acquires a trade or service receivable (directly or indirectly) from a related person. The income is treated as interest on a loan to the obligor under section 864(d)(1) and is generally not eligible for the de minimis, export financing, and related party exceptions to the inclusion of subpart F income. Also, a trade or service receivable acquired or treated as acquired by a CFC from a related U.S. person is considered an investment in U.S. property for purposes of section 956 (Worksheet B) if the obligor is a U.S. person.

Note: Section 111 of the Taxpayer Certainty and Disaster Tax Relief Act of 2020 extended the look-through rule of section 954(c)(6). The rule now applies to tax years of foreign corporations beginning after December 31, 2005, and before January 1, 2026, and to tax years of U.S. shareholders with or within which such tax years of the foreign corporations end. Continue to exclude the applicable types of income specified in section 954(c)(6) from Worksheet A, line 1a, for the period specified in the previous sentence.

Gains and losses from the sale or exchange of any property that, in the hands of the CFC, is property described in section 1221(a)(1).

Line 1h. Certain amounts received for services under personal service contracts. Enter amounts received:

Under a contract under which the corporation is to furnish personal services if (a) some person other than the corporation has a right to designate (by name or by description) the individual who is to perform the services, or (b) the individual who is to perform the services is designated (by name or by description) in the contract; and
From the sale or other disposition of such a contract.

Note: The above rules apply with respect to amounts received for services under a particular contract only if at some time during the tax year 25% or more in value of the outstanding stock of the corporation is owned, directly or indirectly, by or for the individual who has performed, is to perform, or may be designated (by name or by description) as the one to perform, such services.

Line 1g. Payments in lieu of dividends. Include payments in lieu of dividends that are made as required under section 1058.

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

Line 1i. Certain amounts from sales of partnership interests to which the look-through rule of section 954(c)(4) applies. In the case of any sale by a CFC of an interest in a partnership with respect to which the CFC is a 25% owner (defined below), such CFC is treated for purposes of computing its foreign personal holding company income as selling the proportionate share of the assets of the partnership attributable to such interest. Thus, the sale of a partnership interest by a CFC that meets the ownership threshold constitutes subpart F income only to the extent that a proportionate sale of the underlying partnership assets attributable to the partnership interest would constitute subpart F income. Do not report these amounts on line 1b. Instead, report them on line 1i.

25% owner. For purposes of these rules, a 25% shareholder is a CFC that owns directly 25% or more of the capital or profits interest in a partnership. For purposes of the preceding sentence, if a CFC is a shareholder or partner of a corporation or partnership, the CFC is treated as owning directly its proportionate share of any such capital or profits interest held directly or indirectly by such corporation or partnership. If a CFC is treated as owning a capital or profits interest in a partnership under constructive ownership rules similar to the rules of section 958(b), the CFC is treated as owning such interest, directly or indirectly, for purposes of this definition.

Line 6. Gross insurance income. Enter the CFC’s gross insurance income taken into account in determining insurance income under section 953, determined after the application of section 952(b). See Regulations section 1.954-1(a)(6).

Note: If income is insurance income, it is not considered income in any category of foreign base company income except as provided in Regulations section 1.954-1(e)(4)(i) (A) or (B).

Line 10. De minimis rule. If the sum of foreign base company income (determined without regard to section 954(b)(5)) and gross insurance income (as defined in section 954(b)(3)(C)) for the tax year is less than the lesser of 5% of gross income for income tax purposes, or $1 million, then no portion of the gross income for the tax year is treated as foreign base company income or insurance income. In this case, enter zero on line 10 and skip lines 11 through 19. Otherwise, go to line 11.

Line 11. Full inclusion rule. If the sum of gross foreign base company income (determined without regard to section 954(b)(5)) and gross insurance income for the tax year exceeds 70% of gross income for income tax purposes, the entire gross income for the tax year must (subject to the adjustments described below) be treated as foreign base company income or insurance income, whichever is appropriate. In this case, enter total gross income (for income tax purposes) on line 11. Otherwise, enter zero.

Line 12. Total adjusted gross foreign base company income and insurance income. Enter the greater of line 7 or line 11. However, if line 11 is greater than line 7, reduce the line 11 amount by any portion of such amount

described in section 952(b), and enter the result on line 12.

Line 13. Adjusted net foreign personal holding com- pany income. Adjusted net foreign personal holding company income is calculated by first determining the gross amount of each item of foreign personal holding company income and then allocating and apportioning expenses to such items of income on lines 13b through e. See section 954(b)(5) and Regulations section 1.954-1(c) (1)(i). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c)(1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross foreign personal holding company income, resulting in net foreign personal holding company income, such amount must be reduced for amounts excluded pursuant to section 952(c) on line 13g. See Regulations section 1.954-1(a)(5) and (d)(4)(ii). Finally, to determine adjusted net foreign personal holding company income, any remaining amount of net foreign personal holding company income after applying section 952(c) must be reduced for amounts excluded under the high-tax exception of section 954(b)(4) on line 13i. See Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign corporation’s earnings and profits for the taxable year, the subpart F income includible in the income of the CFC’s U.S. shareholders must be reduced in the manner prescribed in Regulations section 1.952-1(e).

Note: For the definition of “item of income,” see Regulations section 1.954-1(c)(1)(iii).

Line 14. Adjusted net foreign base company sales in- come. Adjusted net foreign base company sales income is calculated by first determining the gross amount of each item of foreign base company sales income and then allocating and apportioning expenses to such items of income on line 14b. For more information, see section 954(b)(5) and Regulations section 1.954-1(c)(1)(i). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c)(1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross foreign base company sales income, resulting in net foreign base company sales income, such amount must be reduced for amounts excluded pursuant to section 952(c) on line 14d. See Regulations section 1.954-1(a)(5) and (d)(4)(ii). Finally, to determine adjusted net foreign base company sales income, any remaining amount of net foreign base company sales income after applying section 952(c) must be reduced for amounts excluded under the

Instructions for Form 5471 (Rev. 12-2025) 29

high-tax exception of section 954(b)(4) on line 14f. See Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Line 15. Adjusted net foreign base company services income. Adjusted net foreign base company services income is calculated by first determining the gross amount of each item of foreign base company services income and then allocating and apportioning expenses to such items of income on line 15b. For more information, see section 954(b)(5) and Regulations section 1.954-1(c)(1) (i). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c)(1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross foreign base company services income, resulting in net foreign base company services income, such amount must be reduced for amounts excluded pursuant to section 952(c) on line 15d. See Regulations section 1.954-1(a)(5) and (d)(4)(ii). Finally, to determine adjusted net foreign base company services income, any remaining amount of net foreign base company services income after applying section 952(c) must be reduced for amounts excluded under the high-tax exception of section 954(b)(4) on line 15f. See Regulations section 1.954-1(a) (5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign corporation’s earnings and profits for the taxable year, the subpart F income includible in the income of the CFC’s United States shareholders must be reduced in the manner prescribed in Regulations section 1.952-1(e).

Note: In determining the amount of a net item of foreign base company income, deductions or loss attributable to disqualified basis and deductions attributable to disqualified payments (Regulations section 1.951A-2(c)(5) or (6)) are not allocated and apportioned to gross foreign base company income.

Line 16. Adjusted net insurance income (other than related person insurance income). In general, insurance income is any income attributable to the issuing (or reinsuring) of any insurance or annuity contract that would (subject to the modifications provided in section 953(b)) be taxed under subchapter L (insurance company tax) if such income were income of a domestic insurance company. However, insurance income does not include exempt insurance income (as defined in section 953(e)).

Adjusted net insurance income is calculated by adjusting the amount of gross insurance income by the amount of the CFC’s gross related person insurance income (defined below) on line 16a. Then, each item of gross insurance income (other than related person insurance income) is reduced by allocating and

apportioning expenses to such items of income on line 16b. For more information, see section 953 and Regulations section 1.954-1(a)(6). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c) (1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross insurance income (other than related person insurance income), resulting in net insurance income (other than net related person insurance income), such amount must be reduced for amounts excluded pursuant to section 952(c) on line 16d. See Regulations section 1.954-1(a)(6) and (d) (4)(ii). Finally, to determine adjusted net insurance income (other than related person insurance income), any remaining amount of net insurance income (other than related person insurance income) after applying section 952(c) must be reduced for amounts excluded under the high-tax exception of section 954(b)(4) on line 16f. See Regulations section 1.954-1(a)(6) and (d)(4)(ii) and (iii).

Line 17. Adjusted net related person insurance in- come. In general, related person insurance income is any insurance income (within the meaning of section 953(a)) attributable to a policy of insurance or reinsurance for which the person insured, directly or indirectly, is a U.S. shareholder (as defined in section 953(c)(1)(A)) in a CFC (as defined in section 953(c)(1)(B)) or a related person (as defined in section 953(c)(6)) to such a shareholder. If a CFC has related person insurance income, the U.S. shareholder’s pro rata share is to be determined under the rules of section 953(c)(5).

Exceptions. The above definition does not apply to any foreign corporation if:

At all times during the foreign corporation’s tax year, less than 20% of the total combined voting power of all classes of stock of the corporation entitled to vote, and less than 20% of the total value of the corporation, is owned, directly or indirectly, under the principles of section 883(c)(4) by persons who are, directly or indirectly, insured under any policy of insurance or reinsurance issued by the corporation or who are related persons to any such person;
The related person insurance income (determined on a gross basis) of the corporation for the tax year is less than 20% of its insurance income for the tax year; or
The corporation:

Elects to treat its related person insurance income for the tax year as income effectively connected with the conduct of a trade or business in the United States,
Elects to waive all treaty benefits (other than from section 884) for related person insurance income, and
Meets any requirement the IRS may prescribe to ensure that any tax on such income is paid.

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

This election will not be effective if the corporation was a disqualified corporation (as defined in section 953(c)(3) (E)) for the tax year for which the election was made or for any prior tax year beginning after 1986. See section 953(c)(3)(D) for special rules for this election. Mutual life insurance companies. The related person insurance income rules also apply to mutual life insurance companies under regulations prescribed by the Secretary. For these purposes, policyholders must be treated as shareholders.

Adjusted net related person insurance income is calculated by first determining the gross amount of each item of related person insurance income and then allocating and apportioning expenses to such items of income on line 17b. For more information, see section 953 and Regulations section 1.954-1(a)(6). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c)(1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross related person insurance income, resulting in net related person insurance income, such amount must be reduced for amounts excluded pursuant to section 952(c) on line 17d. See Regulations section 1.954-1(a)(6) and (d)(4) (ii). Finally, to determine adjusted net related person insurance income, any remaining amount of net related person insurance income after applying section 952(c) must be reduced for amounts excluded under the high tax exception of section 954(b)(4) on line 17f. See Regulations section 1.954-1(a)(6) and (d)(4)(ii) and (iii).

Note: In determining the amount of a net item of insurance or related person insurance income, deductions or loss attributable to disqualified basis and deductions attributable to disqualified payments (Regulations section 1.951A-2(c)(5) or (6)) are not allocated and apportioned to gross insurance income.

Line 18. Adjusted net full inclusion foreign base com- pany income. Under Regulations section 1.954-1(d)(6), gross full inclusion base company income is excluded from a CFC’s subpart F income if more than 90% of the adjusted gross foreign base company income and adjusted gross insurance income of a CFC (determined without regard to Regulations section 1.954-1(b)(1)) is attributable to net amounts excluded from subpart F income pursuant to an election to have the high-tax exception described in section 954(b)(4) and Regulations section 1.954-1(d) apply. Accordingly, this computation is performed on lines 18b through 18e.

If gross full inclusion foreign base company income is not excluded from subpart F as a result of the computations on lines 18b through 18e, adjusted net full

inclusion base company income is calculated by allocating and apportioning expenses to the excess of the CFC’s gross income and its gross foreign base company income and gross insurance income on line 18f. For more information, see section 954(b)(5) and Regulations section 1.954-1(c)(1)(i). Expenses allocated and apportioned to an item of income may reduce the item of income below zero, and any item of income that is less than zero generally cannot offset other items of income. For more information, see Regulations section 1.954-1(c) (1)(ii). Do not enter expenses on these lines of Worksheet A to the extent that their allocation and apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross full inclusion base company income, resulting in net full inclusion base company income, such amount must be reduced for amounts excluded pursuant to section 952(c) on line 18h. See Regulations section 1.954-1(a)(5) and (d) (4)(ii). Finally, to determine adjusted net full inclusion base company income, any remaining amount of net full inclusion base company income after applying section 952(c) must be reduced for amounts excluded under the high-tax exception of section 954(b)(4) on line 18j. See Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Line 19. International boycott income. If a CFC or a member of a controlled group (within the meaning of section 993(a)(3)) that includes the CFC has operations in, or related to, a country (or with the government, a company, or a national of a country) that requires participation in or cooperation with an international boycott as a condition of doing business within such country or with the government, company, or national of that country, a portion of the CFC’s income is included in subpart F income. The amount included is determined by multiplying the CFC’s income (other than income included under section 951 and U.S. source effectively connected business income described in section 952(b)) by the international boycott factor. This factor is a fraction determined on Schedule A (Form 5713).

Special rule. If the shareholder of a CFC can clearly demonstrate that the income earned for the tax year is from specific operations, then, instead of applying the international boycott factor, the addition to subpart F income is the amount specifically from the operations in which there was participation in or cooperation with an international boycott. See Schedule B (Form 5713).

Line 20. Illegal bribes, kickbacks, and other pay- ments. Enter the total of any illegal bribes, kickbacks, or other payments (within the meaning of section 162(c)) paid by or on behalf of the corporation, directly or indirectly, to an official, employee, or agent of a government.

Line 21. Income described in section 952(a)(5). The income of a CFC derived from any foreign country during any period during which section 901(j) applies to such foreign country will be deemed to be income to the U.S.

Instructions for Form 5471 (Rev. 12-2025) 31

shareholders of such CFC. As of the date these instructions were revised, section 901(j) applied to Iran, North Korea, Sudan, and Syria.

Line 46. Certain dividends described in section 951(a)(2)(B). For purposes of determining the amount of

Worksheet B

dividends reported on line 46, do not include any amounts that were not treated as a dividend for purposes of applying section 951(a)(2)(B) due to the application of the Pro Rata Share Transition Rule. See Notice 2025-75.

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 sections 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 U.S. shareholder’s pro rata share of the amount on line 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Section 956(a)(1) amount. Subtract line 5 from line 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Distributions made by the CFC during the tax year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Subtract line 9 from line 8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 Earnings and profits described in section 959(c)(1) after reductions (if any) for current-year distributions . . . . . . . . . . . . 12 Applicable earnings. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12 . . . . . . . . . . . . . . . . . . . . . . . . 14 Section 956(a) amount. Enter the smaller of line 6 or line 13 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Tentative section 956 amount. Subtract line 15 from line 14 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 Section 956 amount. Subtract line 17 from line 16 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1a		2

|1
Amount of U.S. property (as defined in sections 956(c) and (d)) held (directly or indirectly) by the CFC
as of the close of:
1a
a The first quarter of the tax year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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.) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
4
U.S. shareholder’s pro rata share of the amount on line 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
6
Section 956(a)(1) amount. Subtract line 5 from line 4
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
9
Distributions made by the CFC during the tax year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
10
Subtract line 9 from line 8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
11
Earnings and profits described in section 959(c)(1) after reductions (if any) for current-year distributions
. . . . . . . . . . . .
12
Applicable earnings. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
13
Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12
. . . . . . . . . . . . . . . . . . . . . . . .
14
Section 956(a) amount. Enter the smaller of line 6 or line 13
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15
Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder
. . . . . . . . . . . . . . . . . . . . . . . . . . .
16
Tentative section 956 amount. Subtract line 15 from line 14
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18
Section 956 amount. Subtract line 17 from line 16 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .|1b||||

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

Worksheet B Instructions

Use Worksheet B to determine a U.S. shareholder’s pro rata share of earnings of a CFC invested in U.S. property that is subject to tax. Only earnings of a CFC not distributed or otherwise previously taxed are subject to these rules. Thus, the amount of previously untaxed earnings limits the section 956 inclusion. A CFC’s investment in U.S. property in excess of this limit will not be included in the taxable income of the CFC’s U.S. shareholders. PTEP related to prior-year section 956 inclusions (see section 959(c)(1)(A)) and current-year or prior-year subpart F inclusions (see section 959(c)(2)) reduce what would otherwise be the current-year section 956 inclusion.

Note: PTEP resulting from subpart F inclusions (that is, section 959(c)(2) PTEP) that reduced prior-year section 956 or 956A inclusions (see section 959(a) and (c)(1), and Schedule J) should be reclassified as section 959(c)(1) PTEP.

Distributions are also taken into account before the section 956 inclusion is determined. Distributions are generally treated as coming first from, and thus reducing the balances of, the PTEP accounts. Thus, the U.S. shareholders must:

Compute the current-year subpart F income inclusion (potentially increasing the section 959(c)(2) PTEP within the PTEP accounts),
Take into account current distributions (potentially reducing the PTEP accounts and untaxed earnings and profits), and
Compute the current section 956 inclusion (increasing section 959(c)(1) PTEP and potentially decreasing section 959(c)(2) PTEP in the PTEP accounts).

U.S. property is measured on a quarterly average basis. For purposes of Worksheet B, the amount taken into account with respect to U.S. property is generally its adjusted basis for E&P purposes, reduced by any liability to which the property is subject. See section 956(c) and (d) and the regulations under section 956 to determine whether the CFC is treated as holding U.S. property. The amount of U.S. property held (directly or indirectly) by the CFC that was acquired by the foreign corporation before it became a CFC is disregarded (that is, not included), but not in excess of the amount of applicable earnings (as defined in section 956(b)) accumulated during periods before it became a CFC.

If the foreign corporation ceases to be a CFC during the tax year:

The determination of the U.S. shareholder’s pro rata share will be made based upon the stock owned (within the meaning of section 958(a)) by the U.S. shareholder on the last day during the tax year in which the foreign corporation was a CFC;
The CFC’s U.S. property for the tax year will be determined only by taking into account quarters ending on or before such last day (and investments in U.S. property

as of the close of subsequent quarters should be recorded as zero on line 1); and

In determining applicable earnings, current-year E&P will include only E&P that are allocable (on a pro rata basis) to the part of the year during which the foreign corporation was a CFC.

Exceptions & meaning →

Instructions for Separate Schedules¶

Schedule E Use Schedule E, Part I, to report taxes paid, accrued, or deemed paid under section 960(b)(2) by a foreign corporation for which a foreign tax credit is allowed, and use Schedule E, Part III, to report taxes for which a credit may not be taken.

Note: Schedule E must be completed even for noncorporate U.S. shareholders. Certain noncorporate U.S. shareholders may elect under section 962 to be taxed at corporate rates on section 951(a) amounts and the global intangible low-taxed income (GILTI) inclusion for the tax year, so as to be able to claim a credit for certain foreign taxes paid or accrued by the CFC. The information reported on Schedule E is relevant for U.S. shareholders making this election. Also, timely information reporting is important to the extent the U.S. shareholder chooses to amend its return in a later year to make the election under section 962. Schedules E and E-1 are also relevant for noncorporate U.S. shareholders who do not make a section 962 election. Taxes paid or accrued with respect to distributions of PTEP by the U.S. shareholder, while not reported on Form 5471, are subject to different rules regarding creditability and foreign currency gain or loss. See, for example, sections 965(g) and 986(c). Therefore, it is important that the U.S. shareholder track the PTEP groups to follow the different rules for each group.

Name of person filing Form 5471. 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 Form 5471.”

Reference ID number of foreign corporation. If applicable, use the reference ID number shown on Form 5471, page 1, item 1b(2).

Lines a, b, and c. Complete a separate Schedule E for each applicable separate category of income. Enter the appropriate code on line a (above Part I). To determine the appropriate code, see Categories of Income in the Instructions for Form 1118, Foreign Tax Credit—Corporations. Taxes with respect to all categories of income listed in the Instructions for Form 1118, with the exception of foreign branch income, may need to be reported. A foreign corporation may accrue or pay taxes properly attributable to an income group within the general category, passive category, or section 901(j) category. See Regulations section 1.960-1(d)(2)(ii). A foreign corporation may accrue or pay taxes properly attributable to a PTEP group within any of the separate categories of income, with the exception of foreign branch category income. See Regulations section 1.960-3(c)(1).

Instructions for Form 5471 (Rev. 12-2025) 33

If code 901j is entered on line a, enter on line b the country code for the sanctioned country using the two-letter codes (from the list at IRS.gov/CountryCodes ).

If one of the RBT codes is entered on line a, enter on line c the country code for the treaty country using the two-letter code (from the list at IRS.gov/CountryCodes ).

Note: Do not complete a separate Schedule E for taxes assigned to the section 951A category. Taxes paid, accrued, or deemed paid with respect to section 951A PTEP that is in the section 951A category are reported on the Schedule E completed for the general category.

Important. In addition to the separate category codes referred to above, if you have more than one of the categories of income referred to above, you must complete and file a separate Schedule E (including Schedule E-1) using code “TOTAL” that aggregates all amounts listed for each line and column of all other Schedules E and E-1.

Part I—Taxes for Which a Foreign Tax Credit Is Allowed In Part I, Section 1, list income, war profits, and excess profits taxes (income taxes) paid or accrued to each foreign country or U.S. territory for the foreign corporation’s foreign tax year(s) that ends with or within its U.S. tax year.

In Part I, Section 2, report taxes deemed paid under section 960(b)(2) with respect to distributions of PTEP from a lower-tier foreign corporation to the foreign corporation with respect to which this Schedule E (Form 5471) is being completed.

Amounts not reported in Part I. Do not report taxes that are not creditable, including taxes for which a credit is disallowed under section 245A(d) or section 901(j), (k), (l), or (m); or suspended under section 909. Such taxes are reported in Part III. A credit is never allowed for taxes paid or accrued to the United States. Do not report such taxes in Part I. Report them instead in Part III.

Adjustments to foreign income taxes. Adjustments to foreign income taxes paid or accrued in a prior-year should not be reflected on Schedule E in the year of adjustment. Instead, they should be reported in the year to which such taxes relate. This may require an amended return. See section 905(c). Adjustments include additional payments, refunds, and downward adjustments for accrued foreign taxes that are not paid within 2 years after the close of the tax year to which such taxes relate.

Comparison to income tax expense reported on Form 5471, Schedule C. The foreign income taxes reported on Schedule E may differ from the amount reported as income tax expense on line 21a of Schedule C. This is due in part to differences in the accounting for foreign tax redeterminations, disallowed taxes, and foreign income taxes reported in Other Comprehensive Income for U.S. GAAP purposes.

Comparison to income tax expense reported on Schedule H (Form 5471). The taxes added or deducted on line 2g of Schedule H include both foreign income taxes reported in Part I of Schedule E as well as the taxes

reported in Part III of Schedule E that are not creditable foreign income taxes.

Section 1—Taxes Paid or Accrued Directly by Foreign Corporation

Column (a)

Amounts reported on Schedule E may include taxes paid or accrued by the foreign corporation or a pass-through entity (for example, a partnership or disregarded entity) owned by the foreign corporation. If the tax is paid or accrued by the pass-through entity, enter the name of such entity instead of the name of the foreign corporation. If the tax paid or accrued by the foreign corporation is attributable to a branch or qualified business unit (QBU) of the foreign corporation, enter the name of the branch or QBU.

Column (b)

Enter the EIN or reference ID number of the payor entity listed in column (a). A reference ID number is required only in cases in which no EIN was entered for the foreign corporation or pass-through entity owned by the foreign corporation. Filers are permitted to enter both an EIN and a reference ID number. See Item 1b(2)—Reference ID Number, earlier, for more information about reference ID numbers.

Column (c)

Check the box if the foreign income taxes reported in column (j) were paid or accrued by the foreign corporation during prior tax years and were suspended due to the application of the rules of section 909 and that are unsuspended in the current-year because related income is taken into account by the foreign corporation, certain U.S. corporate owners of the foreign corporation, or a member of such U.S. corporate owner’s consolidated group.

Column (d)

Enter the two-letter codes (from the list at IRS.gov/ CountryCodes ) of all foreign countries and U.S. territories to which taxes were paid or accrued. If taxes were paid or accrued to more than one country with respect to the same income, include each tax paid or accrued to a different country on separate lines.

Column (e)

The foreign tax year under foreign tax law may not be the same tax year as the U.S. tax year of the foreign corporation. If the tax is attributable to a pass-through entity owned by a foreign corporation, the foreign tax year of the foreign corporation within which such pass-through entity’s year ends should be reported on this line.

Column (g)

Enter the income reported to the foreign tax authority under foreign tax law. This should be the foreign taxable

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

income base for determining the tax reported in column (j).

Column (h)

Check the box if taxes were paid on U.S. source income.

Column (i)

Enter the three-letter currency code for the local currency in which the tax is payable. Currency codes are available at six-group.com/en/products-services/financial- information/data-standards.html#scrollTo=currency- codes .

Column (j)

Enter the tax paid or accrued in the local currency in which tax is payable and not the functional currency of the payor or foreign corporation. See sections 986(a) and 905(c).

Section 70352 of Public Law 119-21, 139 Stat. 72 (July 4, 2025) (“the OBBBA”) repeals the 1-month deferral election that was permitted under section 898(c)(2) effective for taxable years of specified foreign corporations beginning after November 30, 2025. CFCs affected by this provision will have a “first required year” that will end at the same time as the required year defined in section 898(c) (1).

A Form 5471 should be filed for the first required year of a CFC affected by this provision. For the Form 5471 filed for its first required year, a CFC that paid or accrued foreign income taxes that are subject to the allocation rules provided in Notice 2025-72, 2025-51 I.R.B. 840, or any subsequent guidance issued pursuant to section 70352(c)(1)(C) of the OBBBA must have the amount of each foreign income tax allocated to the first required year listed in column (j) and a statement reflecting all information shown in the table below for each foreign income tax subject to allocation must be attached.

Columns (k) and (l)

Enter the exchange rate in column (k) and the translated dollar amount in column (l).

Translate the taxes entered in column (j) into dollars at the average exchange rate for the tax year to which the tax relates unless one of the exceptions below applies. See section 986(a).

Exceptions. If one of the following exceptions applies, use the exchange rate in effect on the date the foreign corporation paid the tax.

The tax is paid before the beginning of the year to which the tax relates.
Accrued taxes are not paid before the date 2 years after the close of the tax year to which such taxes relate.
There is an election in effect under section 986(a) (1)(D) to translate foreign taxes using the exchange rate in effect on the date of payment.
The foreign corporation reports on the cash basis. See section 986(a).
The foreign tax is denominated in an inflationary currency. See section 986(a)(1)(C).

Report the exchange rate using the “divide-by convention” specified under Reporting exchange rates on Form 5471, earlier.

Column (m)

Enter the tax in functional currency. E&P takes into account foreign income taxes paid or accrued by the foreign corporation. The foreign corporation’s E&P is determined in the foreign corporation’s functional currency. See section 986(b).

Line 5 Report the total of the amounts listed in column (l) on this line 5. This total should also be reported on Schedule E-1, line 4.

Line 6 Report the total of the amounts listed in column (m) on this line 6. This total and the amount reported on line 3 of Schedule E, Part III, are the appropriate reduction to current-year E&P for income taxes. See Schedule H, line 2g.

Example. CFC1, a foreign corporation, with reference ID number 1000123, pays or accrues tax of 10u = $10 to Country X on 50u of Country X foreign source taxable income with respect to CFC1’s foreign tax year ending December 31, 2025. CFC1 has a December 31 tax year end for both foreign and U.S. tax purposes. Also, CFC1 receives in the tax year ending December 31, 2025, a refund of 3u from Country X on 15u of foreign source income with respect to CFC1’s tax year ending December 31, 2017, translated to equal $5, and on which the original liability was $7. Therefore, the revised tax liability is $2. All

Worksheet for Schedule E, Part I, Section 1, Column (j)

Sch. E, Part I, Section 1, column (j), line number	Name of payor entity	EIN or reference ID number of payor entity	Total amount of foreign income tax paid or accrued in first required year	Amount of tax paid or accrued in the first required year allocated to the first required year	Allocation method used
1
2
3
4

Instructions for Form 5471 (Rev. 12-2025) 35

taxes relate to general category income. Also assume for both years that the local currency in which the tax was paid was the same as the foreign corporation’s functional currency. The country code for Country X is XX.

The following entries should be made on the 2025 Schedule E (Form 5471), Part I, Section 1, for CFC1 with respect to the General Category Income separate category.

Line 1, column (a): CFC1
Line 1, column (b): 1000123
Line 1, column (d): XX
Line 1, column (e): 2025/12/31
Line 1, column (f): 2025/12/31
Line 1, column (g): 50u
Line 1, column (i): u
Line 1, column (j): 10u
Line 1, column (k): 1.0000
Line 1, column (l): $10
Line 1, column (m): 10u An amended 2017 tax return should be filed by or for the U.S. person(s) with respect to which Form 5471 was required and that return should include an amended Form

The amended Form 5471 should include an attachment with a schedule that looks like the current version of Schedule E, Part I, Section 1, with the following entries for the general category of income.

Line 1, column (a): CFC1
Line 1, column (b): 1000123
Line 1, column (d): XX
Line 1, column (e): 2017/12/31
Line 1, column (f): 2017/12/31
Line 1, column (g): 15u
Line 1, column (i): u
Line 1, column (j): 1.20u
Line 1, column (k): 1.6667
Line 1, column (l): $2
Line 1, column (m): 1.20u

Section 2—Taxes Deemed Paid (Section 960(b)) The purpose of Section 2 is to track deemed-paid foreign income taxes with respect to current-year PTEP distributions from lower-tier foreign corporations to the foreign corporation with respect to which this Schedule E (Form 5471) is being completed (“the foreign corporation”).

Report a PTEP distribution by a lower-tier foreign corporation in Section 2 only if foreign income taxes are deemed paid under section 960(b) by the foreign corporation with respect to such PTEP distribution.

The only foreign taxes of the distributing foreign corporation that may be treated as deemed paid under section 960(b) are foreign taxes paid, accrued, or deemed paid by the distributing foreign corporation with respect to the receipt of a PTEP distribution from another lower-tier foreign corporation below the distributing foreign corporation. Accordingly, there can be no deemed-paid foreign taxes with respect to a PTEP distribution from a lower-tier foreign corporation that is the lowest foreign-tier foreign corporation in a chain, and therefore no such distributions will be reported in Section 2. See Regulations section 1.960-1(d)(3)(ii)(B).

Any foreign income taxes paid or accrued (but not deemed paid) by the foreign corporation with respect to a PTEP distribution from a lower-tier foreign corporation (whether or not such PTEP distribution is reported in Section 2), such as withholding taxes imposed on the PTEP distribution, are reported in Section 1.

Column (a)

Enter the name of each lower-tier foreign corporation that made a PTEP distribution with respect to which a deemed-paid tax is determined in the current-year by the foreign corporation with respect to which this Schedule E (Form 5471) is being completed.

Column (b)

Enter the EIN or reference ID number of the lower-tier foreign corporation listed in column (a). A reference ID number is required only in cases in which no EIN was entered for the lower-tier foreign corporation. Filers are permitted to enter both an EIN and a reference ID number. See Item 1b(2)—Reference ID Number, earlier, for more information about reference ID numbers.

Column (c)

Enter the applicable two-letter code (from the list at IRS.gov/CountryCodes ).

Section 2—Taxes Deemed Paid (Section 960(b))

Column (d)

Enter the code that describes the PTEP group classification (as set forth in Regulations section 1.960-3(c)(2)). Please enter the applicable PTEP group code from the following list.

PTEP Group Classification

Taxes related to previously taxed E&P	PTEP Group Code
Reclassified section 965(a) PTEP	R965a
Reclassified section 965(b) PTEP	R965b
General section 959(c)(1) PTEP	959c1
Reclassified section 951A PTEP	R951A
Reclassified section 245A(d) PTEP	R245Ad
Section 965(a) PTEP	965a
Section 965(b) PTEP	965b
Section 951A PTEP	951A
Section 245A(d) PTEP	245Ad
Section 951(a)(1)(A) PTEP	951a1A

Column (e)

Enter the year in which the U.S. shareholder included income of the lower-tier foreign corporation under section 951(a) or section 951A and established the PTEP account

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

to which the distribution is attributed. This is the annual PTEP account. See Regulations section 1.960-3(c)(1).

Column (f)

Enter the PTEP distribution with respect to the PTEP group within the annual PTEP account identified in column (d) and column (e) in the functional currency of the distributing lower-tier foreign corporation. If there is a PTEP distribution related to more than one PTEP group within an annual PTEP account, complete a separate line for each PTEP group within an annual PTEP account.

Column (g)

Enter the total amount of the lower-tier foreign corporation’s PTEP in the PTEP group within the annual PTEP account identified in column (d) and column (e). Enter such amount in the functional currency of the distributing lower-tier foreign corporation.

Column (h)

Enter the total amount of the lower-tier foreign corporation’s PTEP group taxes with respect to the PTEP group within the annual PTEP account identified in column (d) and column (e). Enter this amount in U.S. dollars. To determine the appropriate translation rate, see section 986(a).

Column (i)

Enter the U.S. dollar amount of the recipient foreign corporation’s income taxes deemed paid that are properly attributable to the PTEP distribution reported in column (f) and not deemed to have been paid by the domestic corporation for any prior tax year.

Note: With respect to distributions of PTEP resulting from inclusions under section 965, report the taxes properly attributable to such PTEP without reduction for the foreign tax credit disallowance.

Part III—Taxes for Which Foreign Tax Credit Is Disallowed Use Part III to report taxes for which foreign tax credits are not allowed. While not allowed as a credit, such taxes are taken into account in determining the foreign corporation’s E&P.

Do not enter taxes that do not meet the criteria under Regulations section 1.901-2.

Columns (a) and (b)

See Part I—Taxes for Which a Foreign Tax Credit Is Allowed , earlier, for instructions regarding these columns.

Column (c)

Enter foreign income taxes that are disallowed under section 901(j), generally foreign income taxes paid or accrued to certain sanctioned countries.

Column (d)

Enter foreign income taxes that are disallowed under section 901(k), which generally applies to certain taxes paid on dividends if the minimum holding period is not met with respect to the underlying stock, or if the corporation is obligated to make related payments with respect to positions in similar or related property. Also enter foreign income taxes disallowed under section 901(l), which generally applies to certain taxes paid on gain and income other than dividends if the minimum holding period is not met with respect to the underlying property, or if the corporation is obligated to make related payments with respect to positions in similar or related property.

Column (e)

In the case of a covered asset acquisition (as defined in section 901(m)(2)), enter the disqualified portion of any tax determined with respect to the income or gain attributable to the relevant foreign assets (section 901(m)).

Note: This rule generally applies to covered asset acquisitions after December 31, 2010. See Regulations sections 1.901(m)-1 through 1.901(m)-8 for additional information. Note that the rules contained in these regulations have later effective dates.

Column (f)

Enter the amount of taxes paid or accrued by the foreign corporation to the United States. No credit is allowed for these taxes because only foreign income taxes paid or accrued to a foreign country or territory of the United States are allowed as a credit. See section 901(b).

Column (g)

Report foreign income taxes related to the current tax year that have been suspended due to the rules of section 909.

Column (h)

Enter taxes for which a foreign tax credit is disallowed other than those detailed in columns (c) through (g). Such taxes may include, but are not limited to, taxes attributable to section 245A(d) income, certain taxes on the purchase or sale of oil and gas (section 901(f)), certain taxes used to provide subsidies (section 901(i)), and taxes for which no credit is allowed because of the boycott provisions of section 908.

Column (i)

For each line in this column, enter the total amount for each payor in columns (c) through (h).

Line 3 Total each amount in column (i) and enter on line 3. All amounts should be in functional currency.

Instructions for Form 5471 (Rev. 12-2025) 37

Line 4 Translate the line 3 amount from functional currency to U.S. dollars using, in general, the average exchange rate as defined by section 989(b)(3).

Exceptions & meaning →

Schedule E-1¶

Use Schedule E-1 (on pages 2 and 3 of separate Schedule E) to report the cumulative balance of foreign income taxes paid or accrued by a CFC by separate category of income.

Enter amounts in U.S. dollars unless otherwise noted.

Columns (a), (b), and (c) In columns (a), (b), and (c), report only the foreign income taxes the foreign corporation pays or accrues attributable to the subpart F income group, the tested income group, and the residual income group, respectively. Use Schedule Q to determine the taxes attributable to each income group. Do not include foreign income taxes paid or accrued by the foreign corporation in its other tax years beginning after December 31, 2017 or that do not relate to the current tax year. Do not include foreign income taxes that are disallowed and are reported on Schedule E, Part III. Do not include taxes paid or accrued by the foreign corporation with respect to its receipt of a PTEP distribution, even if those amounts were included in the total entered on line 5, column (I) of Schedule E, Part I, Section 1. These are reported in column (e). Do not include taxes deemed paid by the foreign corporation with respect to its receipt of a PTEP distribution. These are also reported in column (e).

On line 9, report reductions for the portion of such taxes that are deemed paid by a U.S. shareholder with respect to an inclusion under section 951(a) or 951A. On line 15, report reductions for foreign income taxes attributable to the column (b) tested income group that are not deemed paid as a result of the inclusion percentage or the 80% limitation. Also, on line 15, report any other reductions to the three income groups in columns (a), (b), and (c) necessary to achieve a zero balance on line 16. Attach a statement explaining why such taxes were not deemed paid under section 960. The balance of foreign income taxes paid or accrued with respect to the three income groups that is entered on line 16 should equal zero after taking into account the reductions.

Column (d) Use column (d) to report taxes suspended under section 909.

Columns (e)(i) Through (e)(x) Report foreign income taxes paid or accrued with respect to E&P described in section 959(c)(1) and (c)(2). See the instructions for Schedule J, Column (e), later, for specific information about the 10 PTEP group columns. Also see Regulations section 1.960-3(c)(2) for additional information regarding the 10 PTEP groups.

Specific Instructions Related to Lines 1 Through 16

Line 1a. This amount should equal the amount that was reported as the balance on line 16 of the prior-year Schedule E-1.

Line 1b. If the balance on line 16 of prior-year Schedule E-1 was adjusted after the filing of the original prior-year Form 5471, such adjustments should be reflected on line 1b. For example, if there were errors in the original computation of foreign income taxes, an adjustment would be included on this line. See Corrections to Form 5471 , earlier. Do not include any adjustments required to be reported on line 7 or line 12. Attach a statement that includes an explanation and the dollar amount of each such adjustment, along with a total that equals the amount entered on line 1b.

Line 2. Use line 2 to reflect adjustments to a U.S. person’s foreign tax credit as a result of redetermined foreign income taxes. If a U.S. person has appropriately amended the immediately prior-year return, including its Schedule E-1, to redetermine its U.S. tax liability, no adjustment should be included on this line. This line is only applicable if a U.S. person appropriately amended a prior-year return and there were intervening years between the amended-year return and the current-year return for which an amended return was not filed. If so, an adjustment for the prior-year amended return (and its impact on intervening years) should be reflected on line 2.

Line 3a. A tax reported in column (l) of Schedule E, Part I, Section 1, line 5, for which column (c) was checked because such tax was unsuspended in the current-year, should be included as a positive amount in column (a), (b), (c), or (e), as appropriate. Such tax should also be reflected as a negative amount in column (d).

Line 3b. Include as a positive amount in column (d) foreign income taxes related to the current tax year that have been suspended due to the rules of section 909. Such taxes are also reported on Schedule E, Part III, column (g).

Line 4. The total reported on line 5, column (l) of Schedule E, Part I, Section 1, should be separated into columns (a) through (e) according to the type of income or E&P to which such taxes relate. Therefore, for example, taxes paid or accrued with respect to the receipt of a PTEP distribution are reported in column (e), and taxes paid or accrued with respect to current-year subpart F income of the foreign corporation are reported in column (a).

Example 1. Domestic Corporation, a U.S. shareholder, wholly owns the only class of stock of CFC1, a foreign corporation. CFC1, in turn, wholly owns the only class of stock of CFC2, a foreign corporation. CFC2, in turn, wholly owns the only class of stock of CFC3, a foreign corporation. The functional currency of Domestic Corporation, CFC1, CFC2, and CFC3 is the U.S. dollar. During Year 1, CFC3 has subpart F income, after foreign income tax, of $100 with respect to which it pays $20 of foreign income tax. Such tax is properly attributable to subpart F income of CFC3 and is reported on line 4, column (a) of Schedule E-1 of CFC3’s Form 5471. During

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

Year 1, Domestic Corporation reports an inclusion under section 951(a)(1) of $100 and deemed paid taxes of $20 under section 960(a) as a result of subpart F income of CFC3. During Year 2, CFC3 distributes $40 to CFC2. CFC2 pays withholding tax of $4 on the distribution from CFC3. Such tax is a tax related to previously taxed earnings and profits that were included as subpart F income and is reported on line 4, column (e)(x), of Schedule E-1 of CFC2’s Form 5471.

Line 5. Report taxes carried over to a foreign surviving corporation after an acquisition by a foreign corporation of the assets of another foreign corporation in a transaction described in section 381. See Regulations section 1.367(b)-7(b)(1) and (d)(1).

Line 6. Enter foreign income taxes properly attributable to PTEP and not previously deemed paid (from Schedule E, Part I, Section 2, line 5, column (i)). The total reported on Schedule E, Part I, Section 2, line 5, column (i), should be broken out on Schedule E-1, line 6, columns (e)(i) through (e)(x), based on the type of PTEP to which such taxes relate.

Example 2. The facts are the same as in Example 1, except that, in addition, CFC2 distributes $36 to CFC1 in Year 3. CFC1 is deemed to pay the $4 of withholding tax paid by CFC2 in Year 2. See section 960(b). Such tax is attributable to previously taxed subpart F income and is reported on line 6, column (e)(x), of Schedule E-1 of CFC1’s Form 5471. Such tax is also reported as a negative number on line 10, column (e)(x), of Schedule E1 of CFC2’s Form 5471.

Line 7. Attach a statement with a description and the amount of any adjustments required before taking into account taxes deemed paid by the foreign corporation. Do not include any adjustments required to be reported on line 1b or line 12.

Line 9. A domestic corporation is deemed to pay foreign income taxes attributable to inclusions under section 951(a)(1). See section 960(a). Amounts reported on line 9 should be negative numbers.

If a domestic corporation includes an amount in income under section 951A, such domestic corporation is deemed to pay foreign income taxes equal to 80% of the product of (a) such domestic corporation’s inclusion percentage, multiplied by (b) the aggregate tested foreign income taxes paid or accrued by the CFC. For the computation of such amount, see Form 1118, Schedule D. Amounts reported on line 9 should be negative numbers. See line 15 with respect to reporting taxes not deemed paid as a result of the inclusion percentage or the application of the 80% limitation.

Line 10. A domestic corporation is deemed to pay foreign income taxes with respect to distributions of PTEP. See section 960(b)(1). Amounts reported on line 10 should be negative numbers.

Taxes are deemed paid by a domestic corporation that is a U.S. shareholder or a foreign corporation that is a CFC with respect to distributions of PTEP that it receives. Report in column (e), line 10, the taxes that relate to PTEP of the foreign corporation that are deemed paid by a shareholder of the foreign corporation, either an upper-tier

foreign corporation or a U.S. shareholder, with respect to a distribution of PTEP made by the foreign corporation.

Example 3. The facts are the same as in Example 2, except that during Year 4, CFC1 distributes $36 to Domestic Corporation. Domestic Corporation is deemed to pay the $4 of withholding taxes deemed paid by CFC1 in Year 3 and paid by CFC2 in Year 2. A negative $4 will be reported on line 10, column (e)(x), of CFC1’s Schedule E-1.

See Example 2 , earlier, for reporting on line 10, column (e)(x), of Schedule E-1 of CFC2’s Form 5471 with respect to taxes on distributions from CFC3 to CFC2.

Line 11. Foreign income taxes reclassified from section 959(c)(2) PTEP to section 959(c)(1) PTEP should be reported as negative numbers in columns (e)(vi) through (e)(x) and as positive numbers in columns (e)(i) through (e)(v).

Example 4. The facts are the same as in Example 1, except that during Year 2, CFC2 invests $40 in U.S. property. At the time of investment in such property, CFC2 continues to maintain a $36 balance in its section 959(c) (2) PTEP account. CFC2 reclassifies such amount as section 959(c)(1) PTEP on Schedule J. Accordingly, $4 of foreign income taxes related to section 959(c)(2) PTEP is reclassified to section 959(c)(1) PTEP on line 11, column (e)(iii). A negative $4 will be recorded on line 11, column (e)(x), and a positive $4 will be recorded on line 11, column (e)(iii).

Line 12. Attach a statement with a description and the amount of any required adjustments to taxes of the foreign corporation not already taken into account on this schedule. An example of amounts reported on line 12 is taxes attributable to PTEP distributions to shareholders ineligible to claim a foreign tax credit under section 960(b) (1) (such as foreign corporations).

Line 15. Enter the reduction to the column (b) tested income group for tested income taxes not deemed paid. See Regulations section 1.960-1. This includes taxes attributable to the column (b) tested income group that were not deemed paid as a result of the domestic corporation’s inclusion percentage or as a result of the application of the 80% limit. See section 960(d). Enter the reduction to the three income groups in columns (a), (b), and (c) for other taxes not deemed paid. See Regulations section 1.960-1. This includes taxes that are properly attributable to a subpart F income group but were not deemed paid because there was no subpart F income with respect to that income group in the current-year.

Note: If necessary, enter negative amounts on line 15 of columns (a), (b), and (c) in amounts sufficient to reduce line 16, columns (a), (b), and (c), to zero. Attach a statement explaining why such taxes were not deemed paid under section 960.

Exceptions & meaning →

Schedule G-1¶

Note: A separate Schedule G-1 must be filed for each cost sharing arrangement (CSA) as defined in Regulations section 1.482-7(b) in which the foreign corporation was a controlled participant (as defined in Regulations section

Instructions for Form 5471 (Rev. 12-2025) 39

1.482-7(j)) during the tax year. All amounts should be reported in U.S. dollars.

Reference ID number of foreign corporation. If applicable, use the reference ID number shown on Form 5471, page 1, item 1b(2).

Question 4. Enter the foreign corporation’s share of reasonably anticipated benefits (RAB) for the CSA during the tax year. See Regulations section 1.482-7(e) for rules on determining and updating controlled participant’s RAB share. If the foreign corporation applied more than one RAB share during the tax year in determining its share of intangible development costs (IDCs), enter the RAB share that was applied to IDCs incurred at the end of the year. See Regulations section 1.482-7(d) for more information on IDCs.

Question 5a. Check the “Yes” box if the U.S. taxpayer made any platform contributions as defined in Regulations section 1.482-7(c) to the CSA during the tax year. If “Yes,” complete lines 5b and 5c.

Questions 5b and 5c. Enter the foreign corporation’s RAB share of the total present value of all platform contributions made by the U.S. taxpayer during the tax year with respect to the foreign corporation on line 5b. The total present value of all platform contributions made by the U.S. taxpayer during the tax year should be entered even if only a portion (or none) of the value of those platform contributions was included in the U.S. taxpayer’s taxable income as platform contribution transaction (PCT) payments during the tax year. If possible, include a reasonable present value estimate for any PCTs that are priced using a method that does not involve the calculation of a present value. Otherwise, attach a brief statement of the reason(s) it is not possible to include a present value estimate for one or more PCTs (for example, no revenue projections for a PCT that is priced based on a sales-based royalty from a comparable uncontrolled transaction).

If the U.S. taxpayer engaged in multiple PCTs during the tax year with the foreign corporation and used different methods to price the PCTs, check the appropriate boxes on line 5c to indicate which methods were selected as the best method for one or more of the PCTs reported in the tax year. See Regulations section 1.482-7(g) for more information on the methods applicable to PCTs.

Questions 6b and 6c. See, generally, Regulations section 1.482-7 for more information on determining whether stock-based compensation is directly identified with, or reasonably allocable to, the intangible development activity (IDA) under the CSA. See Regulations section 1.482-7(d)(3) and Notice 2005-99 for more information on determining the measurement and timing of stock-based compensation IDCs, including an election available with respect to options on publicly traded stock and certain other stock-based

compensation. If the taxpayer made the election described in Regulations section 1.482-7(d)(3)(iii)(B) or Notice 2005-99, the taxpayer should attach a statement to Form 5471 explaining that the taxpayer made such election and include in such statement the total amount of stock-based compensation taken into account as an IDC for the tax year pursuant to such election. If the taxpayer attaches the statement described in the previous sentence, then in the entry space provided for line 6b the taxpayer should include the total amount of stock-based compensation taken into account as an IDC, including stock-based compensation pursuant to the election described above and any not subject to such election.

Check the appropriate box on line 6c to indicate whether any stock-based compensation was granted during the term of the CSA to individuals who performed functions in business activities that generate cost-shared intangibles that were not treated as directly identified with, or reasonably allocable to, the IDA as defined in Regulations section 1.482-7(d)(1)(i). This would include stock-based compensation granted in earlier years (which could give rise to deductions in the current tax year) that were not treated as identified with or reasonably allocable to the IDA.

Questions 7a and 7b. For the tax year, enter the total amount of IDCs for the CSA on line 7a. See Regulations section 1.482-7(d) for more information on IDCs.

On line 7b, enter the amount of IDCs allocated to the foreign corporation for the tax year based on the foreign corporation’s RAB share.

Exceptions & meaning →

Schedule H¶

Use Schedule H to report the foreign corporation’s current-year E&P for U.S. tax purposes. Enter the amounts on lines 1 through 5c in the CFC’s functional currency.

Note: A separate Schedule H-1 must be attached for each person described in Categories 4, 5a, and 5b with respect to which reporting is furnished on this Form 5471 that is an applicable corporation within the meaning of section 59(k).

Note: Category 5b filers are not required to file Schedule H for foreign-controlled CFCs.

Reference ID number of foreign corporation. If applicable, use the reference ID number shown on Form 5471, page 1, item 1b(2).

Special rules for DASTM. If the foreign corporation uses DASTM, enter on line 1 the dollar GAAP income or (loss)

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

from line 22 of Schedule C. Enter on lines 2a through 4 the adjustments made in figuring current E&P for U.S. tax purposes. Report these amounts in U.S. dollars. Enter on line 5b the DASTM gain or loss figured under Regulations section 1.985-3(d).

Lines 2a through 2i. Certain adjustments (required by Regulations section 1.964-1(b) and (c)) must be made to the foreign corporation’s line 1 net book income or (loss) to determine its current-year E&P. These adjustments may include both positive and negative adjustments to conform the foreign book income to U.S. GAAP and to U.S. tax accounting principles. If the foreign corporation’s books are maintained in functional currency in accordance with U.S. GAAP, enter on line 1 the functional currency GAAP income or (loss) from line 22 of Schedule C, rather than starting with foreign book income, and show GAAP-to-tax adjustments on lines 2a through 2i.

Lines 2b and 2c. Generally, depreciation, depletion, and amortization allowances must be based on the historical cost of the underlying asset, and depreciation must be figured according to section 167. However, if 20% or more of the foreign corporation’s gross income is from U.S. sources, depreciation must be figured on a straight-line basis according to Regulations section 1.312-15.

Line 2f. Inventories must be taken into account according to the rules of sections 471 (incorporating the provisions of section 263A) and 472 and the related regulations.

Line 2g. See the instructions for Schedule C, Line 21, earlier. Reflect differences between the income tax expense (benefit) reported for book purposes and the income taxes deducted or added to E&P. Such differences include, for example, deferred income tax expenses, uncertain tax positions, intraperiod allocations, adjustments made after closing the financial statements (post-closing adjustments) and not reflected in income tax expense (benefit), and the adjustment for a foreign tax redetermination that required a redetermination of the U.S. tax liability.

Line 2h. Enter the adjustment to foreign currency gains or losses. Attach a statement with a description of the gains or losses.

In the case of section 988 losses, determine whether Form 8886 needs to be completed, as described under Additional Filing Requirements, earlier.

Line 2i. Enter the net amount of any additional adjustments not included on lines 2a through 2h. List these additional adjustments on a separate statement. Attach this statement to Form 5471. Schedule H is only prepared for the general, passive, and section 901(j) categories of income. For example, if U.S. GAAP income reported on Schedule C contains items related to PTEP, include the necessary adjustments on line 2i of Schedule H for the appropriate category of income (general or passive) and attach a statement that itemizes and explains those adjustments. Report adjustments for foreign taxes related to the PTEP on line 2g. This adjustment is necessary because foreign taxes imposed on PTEP distributions do not reduce current-year E&P. Foreign taxes imposed on PTEP distributions reduce PTEP and are reported on Schedule J, line 6.

Example. Domestic Corporation, a U.S. shareholder, wholly owns the only class of stock of CFC1, a foreign corporation. CFC1, in turn, wholly owns the only class of stock of CFC2, a foreign corporation. During Year 1, Domestic Corporation reports an inclusion under section 951(a)(1) of $100 as a result of subpart F income of CFC2. During Year 2, CFC2 distributes $40 to CFC1. CFC1 pays withholding tax of $4 on the distribution from CFC2. Such tax is related to previously taxed subpart F income. On Domestic Corporation’s financial statements, Domestic Corporation reports the $4 withholding tax as current income tax expense. Domestic Corporation reports on CFC1’s Form 5471, Schedule H, line 2g, a positive adjustment for the $4 of tax on the PTEP distribution.

Line 5b. DASTM gain or (loss), reflecting unrealized exchange gain or loss, should be entered on line 5b only for foreign corporations that use DASTM.

Line 5c. The line 5c current-year E&P amount may include amounts with respect to the general category, passive category, or section 901(j) category. See Regulations section 1.960-1(d)(2). Enter on lines 5c(i), 5c(ii), 5c(iii)(A), 5c(iii)(B), 5c(iii)(C), and 5c(iii)(D), as applicable, the portion of the line 5c current-year E&P amount with respect to each applicable category of income. If applicable for lines 5c(iii)(A), 5c(iii)(B), 5c(iii) (C), and 5c(iii)(D), also enter the country code for the sanctioned country using the two-letter code (from the list at IRS.gov/CountryCodes ).

Note: The amounts reported on line 5c include both foreign source and U.S. source income.

Line 5d. Enter the line 5c functional currency amount translated into U.S. dollars at the average exchange rate for the foreign corporation’s tax year. See section 989(b). Report the exchange rate using the “divide-by convention” specified under Reporting Exchange Rates on Form 5471 , earlier. If the foreign corporation uses DASTM, enter on line 5d the same amount entered on line 5c.

Line 5e. Enter the exchange rate used in computing line 5d. Report the exchange rate using the “divide-by convention” specified under Reporting Exchange Rates on Form 5471 , earlier.

Blocked income. The E&P of the foreign corporation, as reflected on Schedule H, must not be reduced by all or any part of such E&P that could not have been distributed by the foreign corporation due to currency or other restrictions or limitations imposed under the laws of any foreign country.

Exceptions & meaning →

Schedule H-1¶

Use Schedule H-1 to report the CFC’s adjusted net income or loss for corporate alternative minimum tax (CAMT) purposes. Enter the amounts on lines 1 through 2m in the currency in which the item originates (that is, applicable financial statement (AFS) currency, functional currency, or U.S. dollars).

Item a. The AFS currency is the currency in which the applicable financial statements are denominated, which is not necessarily the functional currency. See the Form

Instructions for Form 5471 (Rev. 12-2025) 41

4626 instructions for determination of applicable financial statements.

Item b. The exchange rate used to convert from AFS currency to U.S. dollars is the weighted average exchange rate. See Proposed Regulations section 1.56A-1(e). Report the exchange rate using the “divide-by convention” specified under Reporting Exchange Rates on Form 5471 , earlier.

Line 1. Enter the net income or (loss) set forth on the applicable financial statement in AFS currency and, if not already in U.S. dollars, convert to U.S. dollars using the weighted average exchange rate. See Proposed Regulations section 1.56A-1(e).

Lines 2a through 2m. Certain adjustments (required by section 56A(c)) must be made to the foreign corporation’s line 1 net book income or (loss) to determine its adjusted net income or loss for CAMT purposes. These adjustments may include both positive and negative adjustments.

For adjustments denominated in AFS currency, the AFS currency amount of the item is reported in the AFS Currency column and translated into U.S. dollars at the weighted average exchange rate for the year, and the U.S. dollar amount of the item is reported in the U.S. Dollars column. For adjustments denominated in functional currency, the functional currency amount of the item is reported in the Functional Currency column, and the translated U.S. dollar amount of the item is reported in the U.S. Dollars column. For adjustments already denominated in U.S. dollars, report the amount directly in the U.S. Dollars column.

For example, assume CFC1 has an adjustment item related to consolidated financial statements of 100x local currency, or LC, where LC is the currency in which the AFS are denominated. Assume the weighted average exchange rate for the year at issue is 1 LC : 1.1 USD. With respect to that adjustment item, CFC1 will report the following on line 2b: 100x in the AFS Currency column, nothing in the Functional Currency column, and 110x in the U.S. Dollars column.

Line 2a. Appropriate adjustments to applicable financial statement income (AFSI) are made when the AFS reporting year covers a period other than the CFC’s tax year. See Proposed Regulations section 1.59A-3.

Line 2b. Enter the aggregate adjustment needed to:

Exclude any items of income, expense, gain, and loss resulting from the reporting CFC’s ownership of stock of a foreign corporation, including acquiring or disposing of such stock, reflected in the CFC’s financial statement income (FSI); and
Include any items of income, deduction, gain, and loss resulting from the CFC’s ownership of stock of a foreign corporation, including acquiring or transferring such stock, for regular tax purposes (taking into account section 961(c) of the Code). See Proposed Regulations section 1.59A-6(c)(2).

Line 2g. Enter the adjustment(s) needed to exclude dividends resulting from the CFC’s ownership of stock of a foreign corporation reflected in the CFC’s FSI and include dividends for regular tax purposes except for CAMT

excluded dividends as defined in Proposed Regulations section 1.59A-6(c)(2)(iii)(B). Where the CFC owns stock of a foreign corporation through a partnership, see Proposed Regulations section 1.59A-6(c)(2)(iv).

Line 2h. Enter the adjustment(s) needed to include the CFC’s distributive share of all partnership investment AFSI. See Proposed Regulations section 1.59A-5.

Line 2i. If the CFC is itself an applicable corporation, enter here as a reduction (or increase) the amount of the CFC’s income (or loss) determined by taking into account Proposed Regulations section 1.56A-7 (that is, income (or loss) effectively connected with the conduct of a trade or business within the United States). See Proposed Regulations section 1.59A-6(c)(3).

Line 2j. Enter the adjustment(s) needed to disregard any applicable income taxes taken into account in the CFC’s AFS. See Proposed Regulations section 1.59A-8(b).

Line 2k. If the CFC owns a disregarded entity, enter the adjustment(s) needed to treat the CFC and the disregarded entity as a single CAMT entity for CAMT purposes. See Proposed Regulations section 1.59A-9.

Line 2l. Enter an adjustment which is the difference between the section 167 depreciation deductions on section 168 property and the depreciation expense included in the CFC’s AFS for such property. The adjustment is negative if the section 167 depreciation deduction on section 168 property exceeds the depreciation expense included in the CFC’s AFS for such property. The adjustment is positive if the depreciation expense included in the CFC’s AFS for section 168 property exceeds the section 167 depreciation deductions on such property. See Proposed Regulations section 1.56A-15.

Line 2m. To the extent not otherwise reflected on lines 2a through 2l, enter here any adjustments made to AFSI to arrive at adjusted net income or loss. See Proposed Regulations section 1.59A-6(c)(1).

Line 5. Enter the filer’s pro rata share (determined under rules similar to the rules under section 951(a)(2)) of the amount on line 5. See Proposed Regulations section 1.59A-6(b)(1).

Exceptions & meaning →

Schedule I-1¶

This schedule is used to report information determined at the CFC level with respect to amounts used in the determination of income inclusions by U.S. shareholders under section 951A. The information in this schedule will be used by the U.S. shareholder(s) of the CFC to file Form 8992, U.S. Shareholder Calculation of Global Intangible Low-Taxed Income (GILTI), and may assist in the completion of Form 1118 or Form 1116, if applicable.

Enter the amounts on lines 1 through 10c in the CFC’s functional currency. The functional currency amounts entered on lines 6 through 10c must be converted to U.S. dollars.

Certain filers may be able to use alternative information (as defined in section 3.01 of Rev. Proc. 2019-40) to determine certain amounts in this schedule. See Item

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

F—Alternative Information Under Rev. Proc. 2019-40, earlier, for more details.

Separate category. Schedule I-1 is no longer completed separately for each applicable category of income. Therefore, Schedule I-1 is now completed once (for general category income, passive category income, or both). A Schedule I-1 that includes passive category income on line 6 must include the code for passive category income (PAS) in the entry space for separate category (at the top of Schedule I-1). This is the case even if the Schedule I-1 also includes general category income. With respect to a taxpayer completing Schedule I-1 with respect to a foreign corporation with only general category income (and no passive category income) on line 6, the taxpayer should enter the code “GEN” in the entry space for separate category.

Note: The other reporting requirements of a taxpayer that includes passive category income with general category income on a Schedule I-1 do not change because the taxpayer includes passive category income with general category income on a Schedule I-1. For example, the taxpayer may still be required to complete a Form 1116 or a Form 1118, and/or a Form 5471 (including Schedule J and Schedule P), and separately report passive category income and section 951A category income.

Line 1. Enter the CFC’s gross income. The amount of gross income entered on line 1 will generally be a positive amount. However, if a CFC’s cost of goods sold exceeds its gross receipts, a negative amount is permitted on line 1.

line 4. The line example:	4 result ca	an be posit	tive or negati	ive. For
Line 1 gross income	$1,000	$1,000	$(1,000)	$(1,000)
Line 3 total exclusions	$800	$(800)	$800	$(800)
Line 4 (line 1 minus line 3)	$200	$1,800	$(1,800)	$(200)

Line 2. Enter the CFC’s exclusions as described in Regulations section 1.951A-2(c).

Line 2a. Enter the amount of the CFC’s income or loss described in section 952(b), which is generally income or loss from sources within the United States that is effectively connected to the conduct of a trade or business by the CFC in the United States and not reduced or exempt from tax pursuant to an income tax treaty with the United States.

Line 2b. Enter the amount, if any, of the CFC’s gross income or loss taken into account in determining the CFC’s subpart F income (as defined in section 952). Note that an amount determined under section 956(a) is not considered subpart F income. The amount to be entered is computed after application of the high-tax exception in section 954(b)(4), but before application of the E&P limitation in section 952(c)(1).

Line 2c. Enter the amount, if any, of the CFC’s gross income excluded from foreign base company income (as defined in section 954) and insurance income (as defined in section 953) by reason of section 954(b)(4), the high-tax exception (include amounts excluded from tested income under Regulations section 1.951A-2(c)(7)).

Line 2d. Enter the amount of any dividend income received by the CFC from a related person as defined in section 954(d)(3). Do not include the amounts of any dividend income received from a related person that are already included in the amounts entered on line 2b or line 2c.

Line 2e. Enter the amount of the CFC’s taxable income or loss from sources outside the United States and its territories from the following.

The extraction (by the corporation or any other person) of minerals from oil or gas wells located outside the United States and its territories.
The sale or exchange of assets used (by the corporation) in the trade or business of extracting minerals from oil or gas wells located outside the United States and its territories.

Line 3. Combine lines 2a through 2e. The line 3 result can be positive or negative.

Line 4. Subtract line 3 from line 1 and enter the result on

Line 5. Enter the deductions (including taxes) properly allocable to the amount on line 4 (or to which such deductions would be allocable if there were such gross income). See section 951A(c)(2)(A)(ii) and Regulations section 1.951A-2(c)(3). The amount entered on line 5 will generally be a positive amount. However, a negative amount is permitted on line 5.

Line 6. Subtract line 5 from line 4 and enter the result on line 6. The line 6 result can be positive or negative. See the line 4 instructions above for examples. This amount must be converted from functional currency to U.S. dollars using the average exchange rate for the year of the CFC. See Regulations section 1.951A-1(d)(1).

Report the exchange rate using the “divide-by convention” specified under Reporting exchange rates on Form 5471, earlier.

Line 7. If the CFC has a tested loss on line 6, enter zero. If the CFC has tested income on line 6, enter only those foreign income taxes that are properly attributable to the CFC’s tested income group. This amount must be converted from functional currency to U.S. dollars using the average exchange rate for the year of the CFC. See section 986.

Line 8. If the CFC has a tested loss on line 6, enter zero. If the CFC has tested income on line 6, enter the qualified business asset investment (QBAI) (defined below). This amount must be converted from functional currency to U.S. dollars using the average exchange rate for the year of the CFC. See Regulations section 1.951A-1(d)(1).

Qualified business asset investment (QBAI). QBAI is the average of the CFC’s aggregate adjusted bases, as

Instructions for Form 5471 (Rev. 12-2025) 43

of the close of each quarter of its tax year, in specified tangible property used in its trade or business in the production of tested income, and for which a deduction is allowable under section 167. Adjusted basis in any property must be determined by using the alternative depreciation system under section 168(g) and allocating depreciation deductions with respect to such property ratably to each day during the period in the tax year to which such depreciation relates.

Specified tangible property and dual-use property. Specified tangible property means any tangible property used in the production of tested income. If such property was used in the production of tested income and income that is not tested income (that is, dual-use property), the property is treated as specified tangible property in the same proportion that the amount of tested income determined before allocable deductions (that is, line 4) produced with respect to the property bears to the total amount of gross income produced with respect to the property.

Partnership property. A CFC with tested income that is a partner of a partnership that has depreciable tangible property determines its share of the partnership’s average adjusted basis in the depreciable tangible property of the partnership based on the amount of the distributive share of the gross income produced by the property that is included in the CFC’s gross tested income (defined below) relative to the total amount of gross income produced by the property. The partnership’s average adjusted basis in the depreciable tangible property of the partnership is generally determined based on the average of the adjusted basis in the property as of the close of each quarter of the partnership’s tax year that ends with or within the CFC’s tax year. See Regulations section 1.951A-3(g).

Gross tested income. For these purposes, a CFC’s gross tested income is its gross income less total exclusions (Schedule I-1, line 4).

Lines 9a through 9d. In general, see Regulations section 1.951A-4(b)(1) to determine how to compute the CFC’s tested interest expense.

Line 9a. Enter the amount of interest expense included on line 5. See Line 6 , earlier, for foreign currency translation.

Line 9b. Enter the CFC’s qualified interest expense, as defined in Regulations section 1.951A-4(b)(1)(iii).

Line 9c. Enter the CFC’s tested loss QBAI amount, as defined in Regulations section 1.951A-4(b)(1)(iv).

Line 9d. Subtract the sum of line 9b and line 9c from line 9a and enter the result on line 9d.

Lines 10a through 10c. In general, see Regulations section 1.951A-4(b)(2) to determine how to compute the CFC’s tested interest income.

Line 10a. Enter the amount of interest income included on line 4. See Line 6 , earlier, for foreign currency translation.

Line 10b. Enter the CFC’s qualified interest income, as defined in Regulations section 1.951A-4(b)(2)(iii).

Line 10c. Subtract line 10b from line 10a and enter the result on line 10c.

Exceptions & meaning →

Schedule J¶

Use Schedule J to report a CFC’s accumulated E&P in its functional currency, computed under sections 964(a) and 986(b). Also, use this schedule to report the E&P of specified foreign corporations that are only treated as CFCs for limited purposes under section 965(e)(2).

Note: Categories 1b, 1c, 5b, and 5c filers are not required to file Schedule J for foreign-controlled section 965 SFCs or foreign-controlled CFCs.

Reference ID number of foreign corporation. If applicable, use the reference ID number shown on Form 5471, page 1, item 1b(2).

Lines a and b. Complete a separate Schedule J for each applicable separate category of income. Enter the appropriate code on line a (at the top of page 1 of Schedule J). To determine the appropriate code, see Categories of Income in the Instructions for Form 1118. E&P with respect to all categories of income listed in the Instructions for Form 1118, except foreign branch category income, may need to be reported. A foreign corporation may have E&P in an income group within the general category, passive category, or section 901(j) category. See Regulations section 1.960-1(d)(2)(ii). A foreign corporation may have PTEP in a PTEP group within any of the separate categories of income, except foreign branch category income. See Regulations section 1.960-3(c)(1). If code 901j is entered on line a, enter on line b the country code for the sanctioned country using the two-letter code (from the list at IRS.gov/CountryCodes ).

Note: A separate Schedule J should not be completed for the section 951A category. Reclassified section 951A PTEP and section 951A PTEP that is in the section 951A category should be reported on the general category Schedule J.

Note: For purposes of this Schedule J, include in each separate category of income, foreign source and U.S. source income.

Important. In addition to the separate category codes referred to above, if you have more than one of the categories of income referred to above, you must complete and file a separate Schedule J using code “TOTAL” that aggregates all amounts listed for each line and column in Part I of all other Schedules J.

Part I—Accumulated E&P of Controlled Foreign Corporation Check the box at the top of Part I if the person filing Form 5471 does not have all U.S. shareholders’ information necessary to complete any one of the PTEP amounts required to be included in column (e). If the person filing

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

Form 5471 is unable to determine whether amounts should be reported as PTEP, those amounts should be included in column (a), Post-2017 E&P Not Previously Taxed (post-2017 section 959(c)(3) balance). For example, one U.S. shareholder might not know the amount of the other U.S. shareholder’s section 951A inclusion that is allocated to the CFC because the first U.S. shareholder does not have information with respect to the second U.S. shareholder’s net CFC tested income or pro rata share of QBAI. See Schedule P, later, for an example.

Enter the amounts in this schedule in the functional currency of the foreign corporation as reported on Form 5471, page 1, item 1h. If the foreign corporation is the owner of a qualified business unit(s) (QBU) with a different functional currency, translate the E&P of the QBU(s) to the foreign corporation’s functional currency.

Columns (a), (b), and (c) Report the opening balance, current-year additions and subtractions, and the closing balance in the foreign corporation’s E&P described in section 959(c)(3). In general, this is E&P of the foreign corporation that has not been included in gross income of a U.S. person under section 951(a)(1) and section 951A.

In column (a), report E&P described in section 959(c) (3) and earned after the repeal of section 902, that is, post-2017 E&P not previously taxed (post-2017 section 959(c)(3) balance). The repeal of section 902 is effective for tax years of foreign corporations beginning after December 31, 2017, and to tax years of U.S. shareholders in which or with which such tax years of foreign corporations end.

In column (b), report post-1986 undistributed earnings, as defined under section 902(c)(1), and as in effect prior to the repeal of section 902.

Use column (c) to report the aggregate amount of the foreign corporation’s pre-1987 section 964(a) E&P accumulated since 1962 and not previously distributed or deemed distributed. These amounts are figured in U.S. dollars using the rules of Regulations section 1.964-1(a) through (d), and translated into the foreign corporation’s functional currency according to Notice 88-70, 1988-2 C.B. 369.

Column (d) Use column (d) to report hovering deficits (see section 381(c)(2)(B) and Regulations section 1.367(b)-7) and suspended taxes (see section 909). See Specific Instructions Related to Lines 1 Through 13 , later, for additional information pertaining to reporting amounts in column (d).

Column (e) Use column (e) to report the running balance of the foreign corporation’s PTEP, section 964(a) E&P accumulated since 1962 that have resulted in deemed inclusions under subpart F, or amounts treated as PTEP under section 965(b)(4)(A). Pre-1987 U.S. dollar PTEP should be translated into the foreign corporation’s functional currency using the rules of Notice 88-70 and

added to post-1986 amounts in the appropriate PTEP group.

Column (e)(ix) is PTEP described in the following three subgroups (which are aggregated into a single PTEP group) (section 959(c)(2) amounts).

PTEP attributable to hybrid dividends under section 245A(e)(2).
PTEP attributable to section 1248 amounts under section 959(e).
PTEP attributable to section 1248 amounts from the gain on the sale of foreign corporation stock by a CFC.

Column (x) is PTEP attributable to section 951(a)(1)(A) inclusions (section 959(c)(2) amounts) not otherwise described in the instructions for columns (e)(vi) through (ix).

Schedule J reports PTEP by subgroups because those groups may be subject to different rules under sections 960, 965(g), 245A(e)(3), and 986(c). The different rules are applicable for individuals, as well as corporations,

Columns (e)(i) and (e)(ii) are PTEP originally attributable to inclusions under section 965(a) and E&P treated as PTEP under section 965(b)(4)(A), respectively, and reclassified as investments in U.S. property (section 959(c)(1) amounts).
Column (e)(iii) is PTEP described in the following three subgroups (which are aggregated into a single PTEP group) (section 959(c)(1) amounts).

PTEP attributable to investments in U.S. property and not by reason of reclassification.
PTEP attributable to inclusions under section 951(a) (1)(A) (other than inclusions under section 951(a)(1)(A) described in the instructions for columns (e)(vi) through (ix)) and reclassified as investments in U.S. property (for example, PTEP attributable to subpart F income inclusions and reclassified as investments in U.S. property).
PTEP attributable to inclusions under former section 951(a)(1)(C) and subpart F income inclusions reclassified as investments in excess passive assets.

Column (e)(iv) is PTEP originally attributable to inclusions under section 951A and reclassified as investments in U.S. property (section 959(c)(1) amounts).
Column (e)(v) is PTEP described in the following three subgroups (which are aggregated into a single PTEP group) (section 959(c)(1) amounts).

PTEP attributable to hybrid dividends under section 245A(e)(2) and reclassified as investments in U.S. property.
PTEP attributable to section 1248 amounts under section 959(e) and reclassified as investments in U.S. property.
PTEP attributable to section 1248 amounts from the gain on the sale of foreign corporation stock by a CFC and reclassified as investments in U.S. property.

Column (e)(vi) is PTEP attributable to section 965(a) inclusions (section 959(c)(2) amounts). Do not include in column (e)(vi) E&P reported in column (e)(vii).
Column (e)(vii) is E&P treated as PTEP under section 965(b)(4)(A) (section 959(c)(2) amounts).
Column (e)(viii) is PTEP attributable to section 951A inclusions (section 959(c)(2) amounts).

Instructions for Form 5471 (Rev. 12-2025) 45

estates, and trusts. For example, an individual U.S. shareholder who receives a distribution of PTEP originally attributable to inclusions under section 965(a) may only claim a credit for a portion of the foreign taxes attributable to a distribution of such PTEP. See section 965(g) and Regulations section 1.965-5 for more information. This is the case for both direct foreign tax credits (that is, those foreign taxes paid or accrued directly by the shareholder upon receipt of the PTEP distribution and allowed as a credit under section 901 or 903) and indirect foreign tax credits (that is, those taxes deemed paid by the shareholder with respect to taxes originally paid or accrued by the CFC under section 960(b)). With respect to direct credits, this reduction applies regardless of whether such individual made an election under section 962. Therefore, the reporting on Schedule J is necessary regardless of whether the U.S. shareholder made a section 962 election.

Column (f) Use column (f) to report the opening and closing balances of the foreign corporation’s accumulated E&P. This amount is the sum of post-2017 E&P not previously taxed, post-1986 undistributed earnings, pre-1987 E&P not previously taxed, and PTEP. Do not include column (d) amounts in the total reported in column (f).

Specific Instructions Related to Lines 1 Through 13

Line 1a. Enter the balances for each column at the beginning of the tax year. These balances should equal the amounts reported as the ending balances in the prior-year Schedule J.

Line 1b. If there is a difference between last year’s ending balance on Schedule J and the amount that should be last year’s ending balance, taking into account modifications on Schedule J, include the difference on line 1b and attach an explanation for the difference. If there are multiple reasons for differences, include the explanation and amount of each such difference on the attachment. Do not include adjustments required to be reported on line 6 or line 12.

Lines 1a through 1c. These lines of column (d) account for the balance of prior-year hovering deficits and suspended taxes that have not yet been deducted. Such amounts are reported as negative numbers.

Line 2a. This line of column (d) is the unsuspended taxes under section 909 as a result of related income taken into account by the foreign corporation, certain U.S. corporate owners of the foreign corporation, or a member of such U.S. corporate owner’s consolidated group. Report the unsuspended taxes on line 2a of column (d) as a positive number. Report the unsuspended taxes as negative numbers on line 2a of column (a), (b), (c), or (e), as applicable.

Line 2b. This line of column (d) accounts for foreign income taxes that are suspended in the current tax year. Report such amounts as negative numbers.

Line 3. Enter the current-year E&P (or deficit in E&P) amount from the applicable line 5c of Schedule H (Form 5471). For example, if you are completing Schedule J for

the passive category (that is, you have entered “PAS” on line a at the top of page 1 of Schedule J), enter the current-year E&P (or deficit in E&P) amount in the applicable column of Schedule H (Form 5471), line 5c(ii). Line 3 should never have an amount entered in column (e).

Line 4. Report as a positive number E&P attributable to distributions of PTEP from lower-tier foreign corporations. Generally, the E&P of a CFC attributable to amounts that are, or have been, included in the gross income of a U.S. shareholder under section 951(a) are not, when distributed through a chain of ownership described in section 958(a), also included in the gross income of another CFC in such chain for purposes of the application of section 951(a) to such other CFC with respect to such U.S. shareholder. See section 959(b).

Line 5a. Enter earnings carried over to a foreign surviving corporation after an acquisition by a foreign corporation of the assets of another foreign corporation in a transaction described in section 381. See Regulations section 1.367(b)-7. The amounts entered on line 5a may be negative or positive. Negative amounts are hovering deficits reported in column (d) of line 5a.

Line 5b. If the foreign surviving corporation had a deficit in E&P prior to a transaction described in section 381, such deficit is recharacterized as a hovering deficit after such nonrecognition transaction. See section 381(c)(2)(B) and Regulations section 1.367(b)-7(d)(2)(i) (post-1986 undistributed earnings) and 1.367(b)-7(e)(1) (pre-1987 E&P not previously taxed). An amount equal to the deficit reported on line 5a of column (a), (b), or (c) is included as a positive amount on line 5b of column (a), (b), or (c), respectively. An amount equal to the total hovering deficits reported on columns (a), (b), and (c), line 5b is included as a negative number in column (d) of line 5b.

Line 6. Attach a statement detailing the nature and amount of any adjustments not accounted for in the E&P determined before reduction for distributions and inclusions (that is, adjustments other than those listed on lines 2a through 5b). Do not include amounts reported on line 1b. An example of an adjustment entered on line 6 is the foreign taxes imposed on receipt of a distribution of PTEP from a lower-tier foreign corporation.

Example. Domestic Corporation, a U.S. shareholder, wholly owns the only class of stock of CFC1, a foreign corporation. CFC1, in turn, wholly owns the only class of stock of CFC2, a foreign corporation. CFC2, in turn, wholly owns the only class of stock of CFC3, a foreign corporation. The functional currency of Domestic Corporation, CFC1, CFC2, and CFC3 is the U.S. dollar. During Year 1, Domestic Corporation reports an inclusion under section 951(a)(1) of $100 as a result of subpart F income of CFC3. During Year 2, CFC3 distributes $40 to CFC2. CFC2 pays withholding tax of $4 on the distribution from CFC3. Such tax is related to previously taxed subpart F income. Domestic Corporation reports in column (e)(x) of CFC2’s Form 5471, Schedule J, line 4, as a positive number, the $40 PTEP distribution. Domestic Corporation reports on line 6, column (e)(x), as a negative number, the $4 of tax on the PTEP distribution.

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

Line 7. Enter on line 7 E&P as of the close of the tax year before actual distributions or inclusions under section 951(a)(1) or section 951A during the year.

Line 8. Enter amounts included in gross income of the U.S. shareholder(s) under section 951(a)(1)(A) or section 951A with respect to the CFC. Report the inclusion as a negative amount in columns (a) through (c), as applicable. Report the inclusion as a positive amount in columns (e) (vi) through (e)(x), as applicable. Amounts reported as positive numbers on line 8, column (e)(viii), should only be reported with respect to negative amounts on line 8 of column (a). The negative amounts could be reported on a different Schedule J than the positive amounts if such amounts are reclassified from one separate category to another separate category.

Note: Section 951(a)(1)(A) inclusions are taken into account for the tax year before actual distributions and section 951(a)(1)(B) inclusions. See section 959.

Note: The amount included in gross income of U.S. shareholders of the CFC under section 951A might not be known if there is more than one U.S. shareholder. In that case, see the example in the instructions for Schedule P for reporting information.

Note: The amount reported in column (e)(viii) on line 8 will not necessarily equal the tested income reported on Schedule I-1. For an example of when this might occur, see Regulations section 1.951A-5(b)(2)(ii).

Line 9. Report actual distributions as negative numbers.

Note: Actual distributions are taken into account for the tax year before section 951(a)(1)(B) inclusions. See section 959(f)(2). An actual distribution is first out of PTEP, if any, and then out of the section 959(c)(3) balance. See section 959(c).

Note: The total of all amounts entered in column (d) of Schedule R (Form 5471), must equal the amount on line 9, column (f), of the Schedule J (Form 5471), that is filed, or if more than one Schedule J (Form 5471) is filed, the Schedule J (Form 5471) with code “TOTAL” entered on line a of that Schedule J.

Line 10. Use line 10 to report reclassifications of section 959(c)(2) PTEP in columns (e)(vi) through (e)(x) to section 959(c)(1) PTEP in columns (e)(i) through (e)(v). A potential section 951(a)(1)(B) inclusion results in a reclassification of section 959(c)(2) PTEP, if any, to section 959(c)(1) PTEP before reclassification out of the section 959(c)(3) E&P balance. See section 959(a)(2) and (f)(1). The amounts reclassified are reported as negative numbers in columns (e)(vi) through (e)(x) and positive numbers in columns (e)(i) through (e)(v), as applicable.

Line 11. Use this line to report E&P not previously taxed, which is treated as earnings invested in U.S. property and, therefore, reclassified to section 959(c)(1) PTEP (column (e)(iii)). The amounts reclassified are reported as negative numbers in columns (a) through (c) and positive numbers in column (e)(iii), as applicable.

Line 12. Attach a statement detailing the nature and amount of any adjustments in E&P not accounted for on

lines 8 through 11. Do not include adjustments required to be reported on line 1b or line 6.

Line 13. The hovering deficit offset included in column (d) is reported as a positive number. The same amount entered in column (d) is reported as a negative number on line 13 of column (a) or (b), as appropriate. See section 381(c)(2)(B) and Regulations section 1.367(b)-7(d)(2)(ii).

Exceptions & meaning →

Schedule M¶

Every U.S. person described in Category 4 must file Schedule M to report the transactions that occurred during the foreign corporation’s annual accounting period ending with or within the U.S. person’s tax year.

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 U.S. person filing Schedule M.

Important. In translating the amounts from functional currency to U.S. dollars, use the average exchange rate for the foreign corporation’s tax year. See section 989(b). Report the exchange rate in the entry space provided at the top of Schedule M using the “divide-by convention” specified under Reporting exchange rates on Form 5471 , earlier.

Reference ID number of foreign corporation. Use the reference ID number shown on Form 5471, page 1, item 1b(2).

Lines 4 and 19. Report on these lines platform contribution transaction payments received and paid by the foreign corporation (without giving effect to any netting of payments). See Regulations section 1.482-7(b)(1)(ii).

Lines 5 and 20. Report on these lines cost-sharing transaction payments received and paid by the foreign corporation (without giving effect to any netting of payments). See Regulations section 1.482-7(b)(1)(i). The corporation is required to complete line 5 only if the corporation itself incurred intangible development costs. If the corporation does not itself incur intangible development costs, then it should only report cost-sharing transaction payments made on line 20.

Lines 9 and 24. Report on line 9 the sum of tiered hybrid dividends received by the foreign corporation during its tax year. Report on line 24 the sum of hybrid dividends or tiered hybrid dividends paid by the foreign corporation during its tax year.

Lines 10 and 25. Report on these lines dividends received and paid by the foreign corporation not previously taxed under subpart F in the current-year or in any prior-year.

Lines 13 and 28. Report on these lines loan guarantee fees received (line 13) and loan guarantee fees paid (line 28). See section 482.

Instructions for Form 5471 (Rev. 12-2025) 47

Lines 14 and 29. Report on these lines “other amounts received” (line 14) and “other amounts paid” (line 29).

If an amount is entered on line 14, you must attach a statement that includes the following information. Column (a) of the attached statement should provide a description of the type of other amounts received during the annual accounting period. Columns (b) through (f) should provide dollar amounts of the specified other amounts received during the annual accounting period by the foreign corporation from the persons listed in the headings for columns (b) through (f). These headings must comport to those used on the Schedule M (Form 5471) to which this statement is attached. The attached statement must include a “totals” line that ties into the amounts reported in each column of line 14.

If an amount is entered on line 29, you must attach a statement that includes the following information. Column (a) of the attached statement should provide a description of the type of other amount paid during the annual accounting period. Columns (b) through (f) should provide dollar amounts of the specified other amounts paid during the annual accounting period by the foreign corporation to the persons listed in the headings for columns (b) through (f). These headings must comport to those used on the Schedule M (Form 5471) to which this statement is attached. The attached statement must include a “totals” line that ties into the amounts reported in each column of line 29.

Lines 31 and 33. Report on these lines the largest aggregate outstanding accounts receivable and payable balances during the year with the related parties described in columns (b) through (f). Report only accounts receivable or payable arising in connection with the provision of services or the sale or processing of property. Only net accounts receivable and payable to the extent that the CFC’s books net the accounts payable against the receivable as payment of the accounts receivable.

Lines 32 and 34. Report on these lines the largest outstanding balances during the year of gross amounts borrowed from, and gross amounts loaned to, the related parties described in columns (b) through (f). Do not enter aggregate cash flows, year-end loan balances, average balances, or net balances. Do not include an account receivable or payable balance arising in connection with the provision of services or the sale or processing of property if the amount of such balance does not, at any time during the tax year, exceed what is ordinary and necessary to carry on the trade or business. Any outstanding balance from these transactions should be reported on the Balance Sheet (Form 5471, Schedule F, page 4) and possibly also on Schedule M, lines 31 and 33.

Accrued payments and receipts. A corporation that uses an accrual method of accounting must use accrued payments and accrued receipts for purposes of computing the total amount to enter on each line of Schedule M.

Exceptions & meaning →

Schedule O¶

is used to report the organization or reorganization of a foreign corporation and the acquisition or disposition of its stock.

Every U.S. citizen or resident described in Category 2 must complete Part I. Every U.S. person described in Category 3 must complete Part II.

See Regulations section 1.6046-1(i) for rules on determining when U.S. persons constructively own stock of a foreign corporation and are therefore subject to the section 6046 filing requirements.

Reference ID number of foreign corporation. Use the reference ID number shown on Form 5471, page 1, item 1b(2).

Exceptions & meaning →