Part II

Section A—General Shareholder Information

If the shareholder’s latest tax return was filed electronically, enter “e-filed” in column (b)(3) instead of a service center.

Section C—Acquisition of Stock

Section C is completed by shareholders who are completing Schedule O because they have acquired sufficient stock in a foreign corporation. If the shareholder acquired the stock in more than one transaction, use a separate line to report each transaction.

Column (d). Enter the method of acquisition (for example, purchase, gift, bequest, trade).

Column (e)(2). Enter the number of shares acquired indirectly (within the meaning of section 958(a)(2)) by the shareholder listed in column (a).

Column (e)(3). Enter the number of shares constructively owned (within the meaning of section 958(b)) by the shareholder listed in column (a).

Section D—Disposition of Stock

Section D must be completed by shareholders who dispose of their interest (in whole or in part) in a foreign corporation.

Column (d). Enter the method of disposition (for example, sale, bequest, gift, trade).

Example. In 1999, Alex, a U.S. citizen, purchased 10,000 shares of common stock of foreign Corporation X.

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

The purchase represented 10% ownership of the foreign corporation.

On July 1, 2025, Alex made a gift of 5,000 shares of foreign Corporation X to his child. Because Alex has reduced his holding in the foreign corporation, he is required to complete Form 5471 and Schedule O. To show the required information about the disposition, Alex completes Section D as follows.

• Enters his name in column (a).

• Enters “common” in column (b).

• Enters “July 1, 2025” in column (c).

• Enters “gift” in column (d).

• Enters “5,000” in column (e)(1).

• Enters “-0-” in column (f) because the disposition was by gift.

• Enters the name and address of his child in column (g).

Section F—Additional Information

Item (b). List the date of any reorganization of the foreign corporation that occurred during the last 4 years while any U.S. person held 10% or more in value or vote (directly or indirectly) of the corporation’s stock. If there is more than one such date, use the most recent date. However, do not enter a date for which information was reported in Section E. Instead, enter the date (if any) of any reorganization prior to that date (if it is within the last 4 years).

Example for item (c). Mr. Lyons, a U.S. person, acquires a 10% ownership in foreign Corporation F. F is the 100% owner of two foreign corporations, FI and FJ. F is also a 50% owner of foreign Corporation FK. In addition, F is 90% owned by foreign Corporation W. Mr. Lyons does not own any of the stock of Corporation W.

Mr. Lyons completes and files Form 5471 and Schedule O for the corporations in which he is a 10%-or-more shareholder. Mr. Lyons is also required to submit a chart if the foreign Corporation is a member of a chain of corporations, and to indicate if he is a 10%-or-more shareholder in any of those corporations. Mr. Lyons would prepare a list showing the corporations as follows.

• Corporation W.

• Corporation F.

• Corporation FI.

• Corporation FJ.

• Corporation FK. Then Mr. Lyons is required to indicate that he is a 10%-or-more shareholder in corporations F, FI, and FJ.

Use Schedule P to report the PTEP in the U.S. shareholder’s annual PTEP accounts with respect to a CFC in the CFC’s functional currency (Part I) and the U.S. shareholder’s U.S. dollar basis in that PTEP (Part II). For purposes of the preceding sentence, a CFC includes an SFC that is only treated as a CFC for limited purposes under section 965(e)(2).

Note: A separate Schedule P must be completed by each Category 1a, 1b, 4, 5a, or 5b filer. Any person that qualifies as a Category 1a, 1b, 4, 5a, or 5b filer, but who is

not filing Form 5471 pursuant to the joint filers exception, must complete Schedule P and attach it to the statement attached to their tax return. See Multiple filers of same information , earlier, for additional information pertaining to the joint filers exception.

If a U.S. shareholder wholly owns the CFC, Schedule P should include the same information reported in column (e) of Schedule J, Part I. If there is more than one U.S. shareholder, the amounts reported on Schedule P with respect to each U.S. shareholder might be different from the amounts reported on Schedule J.

Example. Corporation A, a domestic corporation, owns 50% of the only class of stock of CFC1, and Corporation B, a domestic corporation, owns the remaining 50% of the stock of CFC1. Corporation A wholly owns the only class of stock of CFC2. The functional currency of all corporations is the U.S. dollar. CFC1 has tested income of $100x and CFC2 has tested loss of $30x. See section 951A(c)(2). Neither Corporation A nor Corporation B has any net deemed tangible income return that would reduce the GILTI inclusion of Corporation A or Corporation B. Corporation A has a section 951A inclusion of $20 because its pro rata share of CFC1’s tested income ($50x) is offset by its pro rata share of CFC2’s tested loss ($30x). Corporation B has a section 951A inclusion of $50x. On Schedule P of the Form 5471 with respect to CFC1 filed by Corporation B, Corporation B will report on line 7, column (h), $50x of PTEP as a result of its section 951A inclusion with respect to CFC1. Corporation A will report $20x of PTEP as a result of its section 951A inclusion on its Form 5471, Schedule P, line 7, column (h), with respect to CFC1.

The Form 5471, Schedule J, for CFC1 should include PTEP of $70x with respect to the aggregate section 951A inclusions of Corporation A and Corporation B. However, if Corporation A does not know Corporation B’s section 951A inclusion at the time Corporation A files its Form 5471, Corporation A will only be able to complete Schedule J, Part I, with respect to its PTEP of $20x on line 8, column (e)(viii). Similarly, Corporation B will only be able to complete Schedule J, Part I, with respect to its PTEP of $50x on line 8, column (e)(viii). In the following year, Corporation A and Corporation B should each report the other corporation’s PTEP on Schedule J, Part I, line 1b, column (e)(viii), and the corresponding reduction to CFC1’s E&P described in section 959(c)(3) on Schedule J, Part I, line 1b, column (a).

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 and b. Complete a separate Schedule P for each applicable separate category of income. Enter the appropriate code on line a (at the top of page 1 of Schedule P). To determine the appropriate code, see Categories of Income in the Instructions for Form 1118.

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A foreign corporation may have PTEP in 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).

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 P 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 Schedule P completed for the general category.

Note: For purposes of this Schedule P, 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 P using code “TOTAL” that aggregates all amounts listed for each line and column of all other Schedules P.