Instructions for Form 5471

(Rev. January 2024)

(Use with the December 2023 revision of Form 5471 and separate Schedules G-1 

and Q; the December 2021 revision of separate Schedules E, H, I-1, and M; the 

December 2020 revision of separate Schedules J, P, and R; and the December 2012 

revision of separate Schedule O.)

Information Return of U.S. Persons

With Respect to Certain Foreign Corporations

Department of the Treasury

Internal Revenue Service

Section references are to the Internal 

Revenue Code unless otherwise noted.

Contents Page

Future Developments ............ 1

What’s New .................. 1

General Instructions ............. 1

Purpose of Form ............... 1

Who Must File ................ 1

When and Where To File .......... 2

Categories of Filers ............. 2

Additional Filing Requirements ...... 7

Penalties .................... 8

Other Reporting Requirements ...... 8

Specific Instructions ............. 9

Schedule B ................. 12

Schedule C ................. 13

Schedule F ................. 13

Schedule G ................. 13

Schedule I .................. 19

Instructions for Separate 

Schedules ............... 29

Schedule E ................. 29

Schedule E-1 ................ 32

Schedule G-1 ................ 34

Schedule H ................. 35

Schedule I-1 ................ 37

Schedule J ................. 39

Schedule M ................. 42

Schedule O ................. 43

Schedule P ................. 43

Schedule Q ................. 44

Schedule R ................. 48

Principal Business Activity Codes ... 50

Future Developments

For the latest information about 

developments related to Form 5471, 

its schedules, and its instructions, 

such as legislation enacted after they 

were published, go to IRS.gov/

Form5471.

What’s New

Changes to Form 5471. On page 1 

of the form, new line 1b(3) requests 

the previous reference ID number(s) 

of the foreign corporation, if any.

On page 5 of the form, the question 

on Schedule G, line 18, has been 

deleted and replaced with new 

questions 18a and 18b to better 

reflect Regulations section 1.482-2(a)

(2)(iii)(B).

On page 5, the question on 

Schedule G, line 19a, has been 

reworded to better reflect Regulations 

section 1.385-3. As a result, the 

information requested on line 19b(1) 

has also been reworded.

Changes to separate Schedule G-1. Line 6b was reworded to 

better reflect Regulations section 

1.482-7A.

Changes to separate Schedule Q. 

On page 1 of the schedule, line 1f now 

requests “Other Foreign Personal 

Holding Company Income.” Filers are 

directed to see the instructions for an 

attachment requirement for line 1f.

On page 4 of the schedule, the 

following lines have been shaded 

under column (xv), Loss Allocation.

• Lines 3, 3(1), and 3(2), pertaining to 

the Tested Income Group.

• Lines 4, 4(1), and 4(2), pertaining to 

the Residual Income Group.

Changes to these instructions. 

These instructions have been updated 

for the aforementioned changes to 

Form 5471 and separate Schedule Q. 

No changes were needed to the 

instructions for separate 

Schedule G-1.

In addition, the following changes 

have been made.

The table of questions for Form 

5471, Schedule G, line 14, has been 

amended as follows. If the answer to 

question 22 of that table is “Yes,” for 

tax year 2023, affected Form 5471 

filers will enter code “PRS” on Form 

5471, Schedule G, line 14. For tax 

year 2022, affected Form 5471 filers 

entered “XX” on Form 5471, 

Schedule G, line 14, if the answer to 

question 22 of the table in the 

instructions was “Yes.”

Worksheet A, lines 23 and 25, were 

revised to add a reference to section 

961(c).

Worksheet A, lines 28 and 31, were 

amended.

Worksheet A, line 58, was revised 

to more accurately reflect Regulations 

section 1.951-1(b)(1)(ii)(A).

The instructions for Worksheet A, 

line 1a, were clarified by adding a 

reference to the limitation on section 

954(c)(6) in Regulations section 

1.245A-5.

A new instruction for Worksheet A, 

lines 13b, 13d, 13e, 14b, 15b, 16b, 

18b, and 19b, was added regarding 

allocation and apportionment of 

expenses to better reflect Regulations 

section 1.954-1(c)(1)(i), (ii), and (iv).

A new Worksheet H-1 has been 

added to these instructions. Also, new 

Worksheet H-1 Instructions have been 

provided.

In the instructions for separate 

Schedule Q, line 1, the attachment 

requirement for line 1f has been 

clarified.

General Instructions

Purpose of Form

Form 5471 is used by certain U.S. 

persons who are officers, directors, or 

shareholders in certain foreign 

corporations. The form and schedules 

are used to satisfy the reporting 

requirements of sections 6038 and 

6046, and the related regulations.

Who Must File

Generally, all U.S. persons described 

in Categories of Filers below must 

Jan 25, 2024 Cat. No. 49959G
complete the schedules, statements, 

and/or other information requested in 

the chart, Filing Requirements for 

Categories of Filers, later. Read the 

information for each category carefully 

to determine which schedules, 

statements, and/or information apply.

Note. When a schedule is required 

but all amounts are zero, the schedule 

should still be filed with one or more 

zero amounts. For schedules that are 

completed by category (that is, 

Schedules E, I-1, J, P, and Q), 

inclusion of a single instance of that 

schedule for any separate category 

will meet the requirement.

If the filer is described in more than 

one filing category, do not duplicate 

information. However, complete all 

items that apply. For example, if you 

are the sole owner of a CFC (that is, 

you are described in Categories 4 and 

5a), complete all six pages of Form 

5471 and separate Schedules E, G-1, 

H, I-1, J, M, P, Q, and R.

Note. Complete a separate Form 

5471 and all applicable schedules for 

each applicable foreign corporation.

When and Where To File

Attach Form 5471 to your income tax 

return (or, if applicable, partnership or 

exempt organization return) and file 

both by the due date (including 

extensions) for that return.

Categories of Filers

Category 1 Filers

In general, a Category 1 filer is a 

person who was a U.S. shareholder of 

a foreign corporation that was a 

section 965 specified foreign 

corporation (SFC) at any time during 

the foreign corporation’s tax year 

ending with or within the U.S. 

shareholder’s tax year, and who 

owned that stock on the last day in 

that year in which the foreign 

corporation was a section 965 SFC, 

taking into account the regulations 

under section 965. There are three 

different types of Category 1 filers, 

each described below: Category 1a 

filers, Category 1b filers, and 

Category 1c filers.

Except as otherwise provided in the 

instructions for each type of Category 

1 filer below, the following definitions 

apply for purposes of Category 1.

U.S. shareholder. For purposes of 

Category 1, a U.S. shareholder is a 

U.S. person who owns (directly, 

indirectly, or constructively, within the 

meaning of section 958(a) and (b)) 

10% or more of the total combined 

voting power or value of shares of all 

classes of stock of a section 965 SFC. 

See section 951(b).

U.S. person. For purposes of 

Category 1, a U.S. person is:

1. A citizen or resident of the 

United States;

2. A domestic partnership;

3. A domestic corporation; or

4. An estate or trust that is not a 

foreign estate or trust, as defined in 

section 7701(a)(31).

See section 957(c) for exceptions.

Section 965 SFC. For purposes of 

Category 1, a section 965 SFC is:

1. A controlled foreign corporation 

(CFC) (see Category 5 Filers, later, for 

definition); or

2. Any foreign corporation with 

respect to which one or more 

domestic corporations are U.S. 

shareholders.

However, if a passive foreign 

investment company (PFIC) (as 

defined in section 1297) with respect 

to the shareholder is not a CFC, then 

such corporation is not a section 965 

SFC.

See section 965 and the 

regulations thereunder for exceptions.

Category 1a Filer

A Category 1a filer is a Category 1 

filer that is not a Category 1b or 1c 

filer.

Category 1b Filer

A Category 1b filer is a person who is 

an unrelated section 958(a) U.S. 

shareholder (defined below) of a 

foreign-controlled section 965 SFC 

(defined below). This type of Category 

1 filer extends the relief for certain 

Category 5 filers announced in 

section 8.02 of Rev. Proc. 2019-40, 

2019-43 I.R.B. 982, to similarly 

situated Category 1 filers.

Unrelated section 958(a) U.S. 

shareholder. For purposes of 

Category 1b, an unrelated section 

958(a) U.S. shareholder is a U.S. 

shareholder with respect to a 

foreign-controlled section 965 SFC 

who:

1. Owns, within the meaning of 

section 958(a), stock of a 

foreign-controlled section 965 SFC; 

and

2. Is not related (using principles 

of section 954(d)(3)) to the 

foreign-controlled section 965 SFC.

Foreign-controlled section 965 

SFC. For purposes of Category 1b, a 

foreign-controlled section 965 SFC is 

a foreign corporation that is a section 

965 SFC that would not be a section 

965 SFC if the determination were 

made without applying subparagraphs 

(A), (B), and (C) of section 318(a)(3) 

so as to consider a U.S. person as 

owning stock that is owned by a 

foreign person.

Category 1c Filer

A Category 1c filer is a person who is 

a related constructive U.S. 

shareholder (defined below) of a 

foreign-controlled section 965 SFC 

(defined below). This type of Category 

1 filer extends the relief for certain 

Category 5 filers announced in 

section 8.03 of Rev. Proc. 2019-40, 

2019-43 I.R.B. 982, to similarly 

situated Category 1 filers.

Related constructive U.S. shareholder. For purposes of Category 1c, 

a related constructive U.S. 

shareholder is a U.S. shareholder with 

respect to a foreign-controlled section 

965 SFC who:

1. Does not own, within the 

meaning of section 958(a), stock of 

the foreign-controlled section 965 

SFC; and

2. Is related (using principles of 

section 954(d)(3)) to the 

foreign-controlled section 965 SFC.

Foreign-controlled section 965 

SFC. For purposes of Category 1c, 

the term “foreign-controlled section 

965 SFC” has the same meaning as 

provided under Category 1b Filer, 

earlier.

Additional Information for 

Category 1 Filers

When Category 1 reporting is no 

longer required. A Category 1 filer 

must continue to file all information 

required as long as:

2 Instructions for Form 5471 (Rev. 01-2024)
• The section 965 SFC (or 

foreign-controlled section 965 SFC) 

has accumulated earnings and profits 

(E&P) related to section 965 that is 

reportable on Schedule J (Form 

5471), or

• The Category 1 filer has previously 

taxed E&P related to section 965 that 

is reportable on Schedule P (Form 

5471).

Category 1 Filers—Exceptions 

From Filing

Certain constructive owners. 

• A Category 1 filer does not have to 

file Form 5471 if all of the following 

conditions are met.

1. The Category 1 filer does not 

own a direct interest in the foreign 

corporation.

2. The Category 1 filer is required 

to furnish the information requested 

solely because of constructive 

ownership (as determined under 

Regulations section 1.958-2, 

1.6038-2(c), or 1.6046-1(i)) from 

another U.S. person.

3. The U.S. person through which 

the Category 1 filer constructively 

owns an interest in the foreign 

corporation files Form 5471 to report 

all of the information required of the 

Category 1 filer.

• A Category 1 filer does not have to 

file Form 5471 if it:

1. Does not own a direct or 

indirect interest in the foreign 

corporation, and

2. Is required to file Form 5471 

solely because of constructive 

ownership from a nonresident alien.

No statement is required to be 

attached to the tax return of a 

Category 1 filer claiming either 

constructive ownership exception. 

See Regulations section 1.6038-2(j)

(2) and (3), and Regulations section 

1.6038-2(l) for additional information.

No section 958(a) U.S. shareholder. A Category 1 filer does not have to 

file Form 5471 if no U.S. shareholder 

(including the Category 1 filer) owns, 

within the meaning of section 958(a), 

stock in the section 965 SFC on the 

last day in the year of the foreign 

corporation in which it was a section 

965 SFC and the SFC is a 

foreign-controlled section 965 SFC. 

This exception extends the relief for 

Category 5 filers announced in 

section 5.02 of Notice 2018-13, 

2018-6 I.R.B. 341, to similarly situated 

Category 1 filers.

Unrelated constructive U.S. shareholder. A Category 1 filer does not 

have to file Form 5471 if all of the 

following conditions are met.

1. The foreign corporation is a 

foreign-controlled section 965 SFC.

2. The Category 1 filer is a U.S. 

shareholder that does not own stock, 

within the meaning of section 958(a), 

in the foreign-controlled section 965 

SFC.

3. The Category 1 filer is not 

related, using principles of section 

954(d)(3), to the foreign-controlled 

section 965 SFC.

This exception implements the 

relief for certain Category 5 filers 

announced in section 8.04 of Rev. 

Proc. 2019-40, 2019-43 I.R.B. 982, 

and extends it to Category 1 filers.

Other filing exceptions. Certain 

other filing exceptions apply to all 

categories of filers. See Additional 

Filing Exceptions, later.

Category 2 Filer

This category includes a U.S. citizen 

or resident who is an officer or director 

of a foreign corporation in which a 

U.S. person (defined below) has 

acquired (in one or more 

transactions):

1. Stock that meets the 10% stock 

ownership requirement (defined 

below) with respect to the foreign 

corporation, or

2. An additional 10% or more (in 

value or voting power) of the 

outstanding stock of the foreign 

corporation.

A U.S. person has acquired stock 

in a foreign corporation when that 

person has an unqualified right to 

receive the stock, even though the 

stock is not actually issued. See 

Regulations section 1.6046-1(c) and 

(f)(1) for more details.

10% stock ownership requirement. 

For purposes of Category 2, the stock 

ownership threshold is met if a U.S. 

person owns:

1. 10% or more of the total value 

of the foreign corporation's stock, or

2. 10% or more of the total 

combined voting power of all classes 

of stock with voting rights.

See Regulations section 

1.6046-1(i) for additional information.

U.S. person. For purposes of 

Category 2, a U.S. person is:

1. A citizen or resident of the 

United States;

2. A domestic partnership;

3. A domestic corporation; or

4. An estate or trust that is not a 

foreign estate or trust, as defined in 

section 7701(a)(31).

See Regulations section 

1.6046-1(f)(3) for exceptions.

Additional Information for 

Category 2 Filers

Foreign sales corporations (FSCs). 

Category 2 filers who are 

shareholders, officers, and directors 

of an FSC (as defined in section 922, 

as in effect before its repeal) must file 

Form 5471 and a separate 

Schedule O to report changes in the 

ownership of the FSC.

Category 2 Filers—Exceptions 

From Filing

A Category 2 filer does not have to file 

Form 5471 if:

1. Immediately after a reportable 

stock acquisition, three or fewer U.S. 

persons own 95% or more in value of 

the outstanding stock of the foreign 

corporation and the U.S. person 

making the acquisition files a return 

for the acquisition as a Category 3 

filer; or

2. The U.S. person(s) for which 

the Category 2 filer is required to file 

Form 5471 does not directly own an 

interest in the foreign corporation but 

is required to furnish the information 

solely because of constructive stock 

ownership from a U.S. person and the 

person from whom the stock 

ownership is attributed furnishes all of 

the information required of the 

Category 2 filer.

Other filing exceptions. Certain 

other filing exceptions apply to all 

categories of filers. See Additional 

Filing Exceptions, later.

Category 3 Filer

This category includes:

1. A U.S. person (defined below) 

who acquires stock in a foreign 

corporation which, when added to any 

stock owned on the date of 

Instructions for Form 5471 (Rev. 01-2024) 3
acquisition, meets the 10% stock 

ownership requirement (defined 

below) with respect to the foreign 

corporation;

2. A U.S. person who acquires 

stock which, without regard to stock 

already owned on the date of 

acquisition, meets the 10% stock 

ownership requirement with respect to 

the foreign corporation;

3. A person who is treated as a 

U.S. shareholder under section 953(c) 

with respect to the foreign corporation;

4. A person who becomes a U.S. 

person while meeting the 10% stock 

ownership requirement with respect to 

the foreign corporation; or

5. A U.S. person who disposes of 

sufficient stock in the foreign 

corporation to reduce his or her 

interest to less than the 10% stock 

ownership requirement.

For more information, see section 

6046 and Regulations section 

1.6046-1.

10% stock ownership requirement. 

For purposes of Category 3, the stock 

ownership threshold is met if a U.S. 

person owns:

1. 10% or more of the total value 

of the foreign corporation's stock, or

2. 10% or more of the total 

combined voting power of all classes 

of stock with voting rights.

See Regulations section 

1.6046-1(i) for additional information.

U.S. person. For purposes of 

Category 3, a U.S. person is:

1. A citizen or resident of the 

United States;

2. A domestic partnership;

3. A domestic corporation; or

4. An estate or trust that is not a 

foreign estate or trust, as defined in 

section 7701(a)(31).

See Regulations section 

1.6046-1(f)(3) for exceptions.

Additional Information for 

Category 3 Filers

Statement required. Category 3 

filers must attach a statement that 

includes:

1. The amount and type of any 

indebtedness the foreign corporation 

has with the related persons 

described in Regulations section 

1.6046-1(b)(11), and

2. The name, address, identifying 

number, and number of shares 

subscribed to by each suscriber to the 

foreign corporation's stock.

Foreign sales corporations (FSCs). 

Category 3 filers who are 

shareholders, officers, and directors 

of an FSC (as defined in section 922, 

as in effect before its repeal) must file 

Form 5471 and a separate 

Schedule O to report changes in the 

ownership of the FSC.

Category 3 Filers—Exception 

From Filing

A Category 3 filer does not have to 

file Form 5471 if all of the following 

conditions are met.

1. The Category 3 filer does not 

own a direct interest in the foreign 

corporation.

2. The Category 3 filer is required 

to furnish the information requested 

solely because of constructive 

ownership (as determined under 

Regulations section 1.958-2, 

1.6038-2(c), or 1.6046-1(i)) from 

another U.S. person.

3. The U.S. person through which 

the Category 3 filer constructively 

owns an interest in the foreign 

corporation files Form 5471 to report 

all of the information required of the 

Category 3 filer.

No statement is required to be 

attached to tax returns for persons 

claiming this constructive ownership 

exception.

Other filing exceptions. Certain 

other filing exceptions apply to all 

categories of filers. See Additional 

Filing Exceptions, later.

Category 4 Filer

This category includes a U.S. person 

(defined below) who had control 

(defined below) of a foreign 

corporation during the annual 

accounting period of the foreign 

corporation.

U.S. person. For purposes of 

Category 4, a U.S. person is:

1. A citizen or resident of the 

United States;

2. A nonresident alien for whom an 

election is in effect under section 

6013(g) to be treated as a resident of 

the United States;

3. An individual for whom an 

election is in effect under section 

6013(h), relating to nonresident aliens 

who become residents of the United 

States during the tax year and are 

married at the close of the tax year to 

a citizen or resident of the United 

States;

4. A domestic partnership;

5. A domestic corporation; and

6. An estate or trust that is not a 

foreign estate or trust, as defined in 

section 7701(a)(31).

See Regulations section 

1.6038-2(d) for exceptions.

Control. For purposes of Category 4, 

a U.S. person has control of a foreign 

corporation if, at any time during that 

person's tax year, it owns stock 

possessing:

1. More than 50% of the total 

combined voting power of all classes 

of stock of the foreign corporation 

entitled to vote, or

2. More than 50% of the total 

value of shares of all classes of stock 

of the foreign corporation.

For purposes of Category 4, a 

person in control of a corporation that, 

in turn, owns more than 50% of the 

combined voting power, or the value, 

of all classes of stock of another 

corporation is also treated as being in 

control of such other corporation.

Example. Corporation A owns 

51% of the voting stock in Corporation 

B. Corporation B owns 51% of the 

voting stock in Corporation C. 

Corporation C owns 51% of the voting 

stock in Corporation D. Therefore, 

Corporation D is controlled by 

Corporation A.

For more details on “control” for 

purposes of Category 4, see section 

6038(e)(2) and Regulations section 

1.6038-2(b) and (c).

Additional Information for 

Category 4 Filers

Foreign sales corporations (FSCs). 

• Category 4 filers who are 

shareholders of an FSC are not 

subject to the subpart F rules with 

respect to the FSC for:

1. Exempt foreign trade income;

2. Deductions that are 

apportioned or allocated to exempt 

foreign trade income;

3. Nonexempt foreign trade 

income (other than section 923(a)(2) 

nonexempt income, within the 

4 Instructions for Form 5471 (Rev. 01-2024)
meaning of section 927(d)(6), as in 

effect before repeal); and

4. Any deductions that are 

apportioned or allocated to the 

nonexempt foreign trade income 

described above.

• Category 4 filers who are 

shareholders of an FSC are subject to 

the subpart F rules for:

1. All other types of FSC income 

(including section 923(a)(2) 

nonexempt income within the 

meaning of section 927(d)(6), as in 

effect before its repeal);

2. Investment income and carrying 

charges (as defined in section 927(c) 

and (d)(1), as in effect before its 

repeal); and

3. All other FSC income that is not 

foreign trade income or investment 

income or carrying charges.

Category 4 Filers—Exceptions 

From Filing

Certain constructive owners. 

• A Category 4 filer does not have to 

file Form 5471 if all of the following 

conditions are met.

1. The Category 4 filer does not 

own a direct interest in the foreign 

corporation.

2. The Category 4 filer is required 

to furnish the information requested 

solely because of constructive 

ownership (as determined under 

Regulations section 1.958-2, 

1.6038-2(c), or 1.6046-1(i)) from 

another U.S. person.

3. The U.S. person through which 

the Category 4 filer constructively 

owns an interest in the foreign 

corporation files Form 5471 to report 

all of the information required of the 

Category 4 filer.

• A Category 4 filer does not have to 

file Form 5471 if it:

1. Does not own a direct or 

indirect interest in the foreign 

corporation, and

2. Is required to file Form 5471 

solely because of constructive 

ownership from a nonresident alien.

No statement is required to be 

attached to the tax return of a 

Category 4 filer claiming either 

constructive ownership exception. 

See Regulations section 1.6038-2(j)

(2) and (3), and Regulations section 

1.6038-2(l) for additional information.

FSCs. Category 4 filers are not 

required to file a Form 5471 (in order 

to satisfy the requirements of section 

6038) if the FSC has filed a Form 

1120-FSC. See Temporary 

Regulations section 1.921-1T(b)(3). 

However, these filers are required to 

file Form 5471 for an FSC, regardless 

of whether it has filed Form 

1120-FSC, if the filer has inclusions 

with respect to the FSC under section 

951(a) (as described above).

Other filing exceptions. Certain 

other filing exceptions apply to all 

categories of filers. See Additional 

Filing Exceptions, later.

Category 5 Filers

In general, a Category 5 filer is a 

person who was a U.S. shareholder 

(defined below) that owned stock in a 

foreign corporation that was a CFC 

(defined below) at any time during the 

foreign corporation’s tax year ending 

with or within the U.S. shareholder’s 

tax year, and who owned that stock on 

the last day in that year in which the 

foreign corporation was a CFC. There 

are three different types of Category 5 

filers, each described below: 

Category 5a filers, Category 5b filers, 

and Category 5c filers.

Except as otherwise provided in the 

instructions for each type of Category 

5 filer below, the following definitions 

apply for purposes of Category 5.

U.S. shareholder. For purposes of 

Category 5, a U.S. shareholder is a 

U.S. person (defined below) who:

1. Owns (directly, indirectly, or 

constructively, within the meaning of 

section 958(a) and (b)) 10% or more 

of the total combined voting power or 

value of shares of all classes of stock 

of a CFC; or

2. Owns (either directly or 

indirectly, within the meaning of 

section 958(a)) any stock of a CFC 

(as defined in sections 953(c)(1)(B) 

and 957(b)), unless the foreign 

corporation has an effective section 

953(c)(3)(C) election in place for the 

tax year.

U.S. person. For purposes of 

Category 5, a U.S. person is:

1. A citizen or resident of the 

United States;

2. A domestic partnership;

3. A domestic corporation; or

4. An estate or trust that is not a 

foreign estate or trust, as defined in 

section 7701(a)(31).

See section 957(c) for exceptions.

In general, a CFC is a foreign 

corporation that has U.S. 

shareholders that own (directly, 

indirectly, or constructively, within the 

meaning of section 958(a) and (b)) on 

any day of the tax year of the foreign 

corporation, more than 50% of:

1. The total combined voting 

power of all classes of its voting stock, 

or

2. The total value of the stock of 

the corporation.

For purposes only of taking into 

account income described in section 

953(a) (relating to insurance income), 

a CFC also includes a foreign 

corporation that is described in 

section 957(b); and for purposes only 

of taking into account related person 

insurance income, a CFC includes a 

foreign corporation described in 

section 953(c)(1)(B).

Category 5a Filer

A Category 5a filer is a Category 5 

filer that is not a Category 5b or 5c 

filer.

Category 5b Filer

A person is a Category 5b filer if they 

are an unrelated section 958(a) U.S. 

shareholder (defined below) of a 

foreign-controlled CFC (defined 

below). This type of Category 5 filer 

implements the relief for certain 

Category 5 filers announced in 

section 8.02 of Rev. Proc. 2019-40, 

2019-43 I.R.B. 982.

Unrelated section 958(a) U.S. 

shareholder. For purposes of 

Category 5b, an unrelated section 

958(a) U.S. shareholder is a U.S. 

shareholder with respect to a 

foreign-controlled CFC who:

1. Owns, within the meaning of 

section 958(a), stock of a 

foreign-controlled CFC; and

2. Is not related (using principles 

of section 954(d)(3)) to the 

foreign-controlled CFC.

Foreign-controlled CFC. For 

purposes of Category 5b, a 

foreign-controlled CFC is a foreign 

corporation that is a CFC that would 

Instructions for Form 5471 (Rev. 01-2024) 5
not be a CFC if the determination 

were made without applying 

subparagraphs (A), (B), and (C) of 

section 318(a)(3) so as to consider a 

U.S. person as owning stock that is 

owned by a foreign person.

Category 5c Filer

A person is a Category 5c filer if they 

are a related constructive U.S. 

shareholder (defined below) of a 

foreign-controlled CFC (defined 

below). This type of Category 5 filer 

implements the relief for certain 

Category 5 filers announced in 

section 8.03 of Rev. Proc. 2019-40, 

2019-43 I.R.B. 982.

Related constructive U.S. shareholder. For purposes of Category 5c, 

a related constructive U.S. 

shareholder is a U.S. shareholder with 

respect to a foreign-controlled CFC 

who:

1. Does not own, within the 

meaning of section 958(a), stock of 

the foreign-controlled CFC; and

2. Is related (using principles of 

section 954(d)(3)) to the 

foreign-controlled CFC.

Foreign-controlled CFC. For 

purposes of Category 5c, the term 

“foreign-controlled CFC” has the same 

meaning as defined in Category 5b 

Filer, earlier.

Additional Information for 

Category 5 Filers

Foreign sales corporations (FSCs). 

• Category 5 filers who are 

shareholders of an FSC are not 

subject to the subpart F rules with 

respect to the FSC for:

1. Exempt foreign trade income;

2. Deductions that are 

apportioned or allocated to exempt 

foreign trade income;

3. Nonexempt foreign trade 

income (other than section 923(a)(2) 

nonexempt income, within the 

meaning of section 927(d)(6), as in 

effect before repeal); and

4. Any deductions that are 

apportioned or allocated to the 

nonexempt foreign trade income 

described above.

• Category 5 filers who are 

shareholders of an FSC are subject to 

the subpart F rules for:

1. All other types of FSC income 

(including section 923(a)(2) 

nonexempt income, within the 

meaning of section 927(d)(6), as in 

effect before its repeal);

2. Investment income and carrying 

charges (as defined in section 927(c) 

and (d)(1), as in effect before its 

repeal); and

3. All other FSC income that is not 

foreign trade income or investment 

income or carrying charges.

Category 5 Filers—Exceptions 

From Filing

Certain constructive owners. 

• A Category 5 filer does not have to 

file Form 5471 if all of the following 

conditions are met.

1. The Category 5 filer does not 

own a direct interest in the foreign 

corporation.

2. The Category 5 filer is required 

to furnish the information requested 

solely because of constructive 

ownership (as determined under 

Regulations section 1.958-2, 

1.6038-2(c), or 1.6046-1(i)) from 

another U.S. person.

3. The U.S. person through which 

the Category 5 filer constructively 

owns an interest in the foreign 

corporation files Form 5471 to report 

all of the information required of the 

Category 5 filer.

• A Category 5 filer does not have to 

file Form 5471 if it:

1. Does not own a direct or 

indirect interest in the foreign 

corporation, and

2. Is required to file Form 5471 

solely because of constructive 

ownership from a nonresident alien.

No statement is required to be 

attached to the tax return of a 

Category 5 filer claiming either 

constructive ownership exception. 

See Regulations section 1.6038-2(j)

(2) and (3), and Regulations section 

1.6038-2(l) for additional information.

No section 958(a) U.S. shareholder. A Category 5 filer does not have to 

file Form 5471 if no U.S. shareholder 

(including the Category 5 filer) owns, 

within the meaning of section 958(a), 

stock in the CFC on the last day in the 

year of the foreign corporation in 

which it was a CFC and the CFC is a 

foreign-controlled CFC. See section 

5.02 of Notice 2018-13, 2018-6 I.R.B. 

341, for additional information.

Unrelated constructive U.S. shareholder. A Category 5 filer does not 

have to file Form 5471 if all of the 

following conditions are met.

1. The foreign corporation is a 

foreign-controlled CFC.

2. The filer is a U.S. shareholder 

that does not own stock, within the 

meaning of section 958(a), in the 

foreign-controlled CFC.

3. The filer is not related, using 

principles of section 954(d)(3), to the 

foreign-controlled CFC.

See section 8.04 of Rev. Proc. 

2019-40, 2019-43 I.R.B. 982, for 

additional information.

FSCs. Category 5 filers are not 

required to file a Form 5471 (in order 

to satisfy the requirements of section 

6038) if the FSC has filed a Form 

1120-FSC. See Temporary 

Regulations section 1.921-1T(b)(3). 

However, these filers are required to 

file Form 5471 for an FSC, regardless 

of whether it has filed Form 

1120-FSC, if the filer has inclusions 

with respect to the FSC under section 

951(a) (as described above).

Other filing exceptions. Certain 

other filing exceptions apply to all 

categories of filers. See Additional 

Filing Exceptions next.

Additional Filing 

Exceptions

Multiple filers of same information. 

With respect to any category of filer, 

one person may file Form 5471 and 

the applicable schedules for other 

persons who have the same filing 

requirements. If you and one or more 

other persons are required to furnish 

information for the same foreign 

corporation for the same period, a 

joint information return that contains 

the required information may be filed 

with your tax return or with the tax 

return of any one of the other persons. 

For example, a U.S. person described 

in Category 5 may file a joint Form 

5471 with a Category 4 filer or another 

Category 5 filer; similarly, a U.S. 

person described in Category 5b may 

file a joint Form 5471 with a Category 

4 or 5a filer or another Category 5b 

filer (but not a Category 5c filer). 

However, for Category 3 filers, the 

required information may only be filed 

6 Instructions for Form 5471 (Rev. 01-2024)
by another person having an equal or 

greater interest (measured in terms of 

value or voting power of the stock of 

the foreign corporation).

The person that files Form 5471 

must complete Form 5471 in the 

manner described in the instructions 

for item H. All persons identified in 

item H must attach a statement to 

their income tax return that includes 

the information described in the 

instructions for item H. See 

Regulations section 1.6038-2(j)(1) 

and (3) for additional information.

Domestic corporations. 

Shareholders are not required to file 

Form 5471 for a foreign insurance 

company that has elected (under 

section 953(d)) to be treated as a 

domestic corporation and has filed a 

U.S. income tax return for its tax year 

under that provision. See Rev. Proc. 

2003-47, 2003-28 I.R.B. 55, available 

at IRS.gov/irb/

2003-28_IRB#RP-2003-47, for 

procedural rules regarding the 

election under section 953(d).

Additional Filing 

Requirements

Section 338 election. If a section 

338 election is made with respect to a 

qualified stock purchase of a foreign 

target corporation for which a Form 

5471 must be filed:

• A purchaser (or its U.S. 

shareholder) must attach a copy of 

Form 8883, Asset Allocation 

Statement Under Section 338, to the 

first Form 5471 for the new foreign 

target corporation (see the 

Instructions for Form 8883 for details);

• A seller (or its U.S. shareholder) 

must attach a copy of Form 8883 to 

the last Form 5471 for the old foreign 

target corporation;

• A U.S. shareholder that files a 

section 338 election on behalf of a 

foreign purchasing corporation that is 

a CFC pursuant to Regulations 

section 1.338-2(e)(3) must attach a 

copy of Form 8023, Elections Under 

Section 338 for Corporations Making 

Qualified Stock Purchases, to the 

Form 5471 filed with respect to the 

purchasing corporation for the tax 

year that includes the acquisition date 

(see the Instructions for Form 8023 for 

details).

Reportable transaction disclosure 

statement. If a U.S. shareholder of a 

CFC is considered to have 

participated in a reportable 

transaction under the rules of 

Regulations section 1.6011-4(c)(3)(i)

(G), the shareholder is required to 

disclose information for each 

reportable transaction. Form 8886, 

Reportable Transaction Disclosure 

Statement, must be filed for each tax 

year indicated in Regulations section 

1.6011-4(c)(3)(i)(G). The following are 

reportable transactions.

1. Any listed transaction, which is 

a transaction that is the same as or 

substantially similar to one of the 

types of transactions that the IRS has 

determined to be a tax avoidance 

transaction and identified by notice, 

regulation, or other published 

guidance as a listed transaction.

2. Any transaction offered under 

conditions of confidentiality for which 

the corporation (or a related party) 

paid an advisor a fee of at least 

$250,000.

3. Certain transactions for which 

the corporation (or a related party) 

has contractual protection against 

disallowance of the tax benefits.

Filing Requirements for Categories of Filers

Table of Required Information

Required Information* 

Category of Filer 

1a 1b 1c 2 3 4 5a 5b 5c

The identifying information on page 

1 of Form 5471 above Schedule A; 

see Specific Instructions

Schedule A

Schedule B, Part I

Schedule B, Part II

Schedules C and F

Separate Schedule E 1 2 1 2

Schedule E-1 (included with 

separate Schedule E)

1 1

Schedule G

Separate Schedule G-1

Separate Schedule H

Schedule I 

Separate Schedule I-1

Separate Schedule J

Separate Schedule M

Separate Schedule O, Part I

Separate Schedule O, Part II

Separate Schedule P

Separate Schedule Q

Separate Schedule R

* See also Additional Filing Requirements.

1

 Schedules E and E-1 are required for an Unrelated section 958(a) U.S. shareholder. only if the filer claims 

deemed paid foreign income taxes of the foreign-controlled section 965 SFC or foreign-controlled CFC 

under section 960 for the filer’s tax year. See Rev. Proc. 2019-40 for more details.

2 Related constructive U.S. shareholder. only need to complete Schedule E (they can leave Schedule E-1 

blank). See Rev. Proc. 2019-40 for more details.

Instructions for Form 5471 (Rev. 01-2024) 7
4. Certain transactions resulting in 

a loss of at least $10 million in any 

single year or $20 million in any 

combination of years.

5. Any transaction identified by the 

IRS by notice, regulation, or other 

published guidance as a “transaction 

of interest.” See Notice 2009-55, 

2009-31 I.R.B. 170, available at 

IRS.gov/irb/

2009-31_IRB#NOT-2009-55.

For more information, see 

Regulations section 1.6011-4. Also, 

see the Instructions for Form 8886.

Penalties. The U.S. shareholder 

may have to pay a penalty if it is 

required to disclose a reportable 

transaction under section 6011 and 

fails to properly complete and file 

Form 8886. Penalties may also apply 

under section 6707A if the U.S. 

shareholder fails to file Form 8886 

with its income tax return, fails to 

provide a copy of Form 8886 to the 

Office of Tax Shelter Analysis (OTSA), 

or files a form that fails to include all 

the information required (or includes 

incorrect information). Other 

penalties, such as an 

accuracy-related penalty under 

section 6662A, may also apply. See 

the Instructions for Form 8886 for 

details on these and other penalties.

Reportable transactions by material advisors. Material advisors to any 

reportable transaction must disclose 

certain information about the 

reportable transaction by filing Form 

8918, Material Advisor Disclosure 

Statement, with the IRS. For details, 

see the Instructions for Form 8918.

Reporting other foreign financial 

assets. If you have other foreign 

financial assets, you may be required 

to file Form 8938, Statement of 

Specified Foreign Financial Assets. 

However, you are not required to 

report any items otherwise reported 

on Form 5471 on that form. See the 

Instructions for Form 8938 for more 

information.

Penalties

Failure to file information required 

by section 6038(a) (Form 5471 and 

Schedule M). 

• A $10,000 penalty is imposed for 

each annual accounting period of 

each foreign corporation for failure to 

furnish the information required by 

section 6038(a) within the time 

prescribed. If the information is not 

filed within 90 days after the IRS has 

mailed a notice of the failure to the 

U.S. person, an additional $10,000 

penalty (per foreign corporation) is 

charged for each 30-day period, or 

fraction thereof, during which the 

failure continues after the 90-day 

period has expired. The additional 

penalty is limited to a maximum of 

$50,000 for each failure.

• Any person who fails to file or report 

all of the information required within 

the time prescribed will be subject to a 

reduction of 10% of the foreign taxes 

available for credit under sections 901 

and 960. If the failure continues 90 

days or more after the date the IRS 

mails notice of the failure to the U.S. 

person, an additional 5% reduction is 

made for each 3-month period, or 

fraction thereof, during which the 

failure continues after the 90-day 

period has expired. See section 

6038(c)(2) for limits on the amount of 

this penalty.

See Regulations sections 1.6038-1(j)

(4) and 1.6038-2(k)(3) for alleviation 

of this penalty in certain cases.

Failure to file information required 

by section 6046 and the related 

regulations (Form 5471 and

Schedule O). Any person who fails 

to file or report all of the information 

requested by section 6046 is subject 

to a $10,000 penalty for each such 

failure for each reportable transaction. 

If the failure continues for more than 

90 days after the date the IRS mails 

notice of the failure, an additional 

$10,000 penalty will apply for each 

30-day period, or fraction thereof, 

during which the failure continues 

after the 90-day period has expired. 

The additional penalty is limited to a 

maximum of $50,000. See section 

6679.

Criminal penalties. Criminal 

penalties under sections 7203, 7206, 

and 7207 may apply for failure to file 

the information required by sections 

6038 and 6046.

Note. Any person required to file 

Form 5471 and Schedule J, M, or O 

who agrees to have another person 

file the form and schedules for them 

may be subject to the above penalties 

if the other person does not file a 

correct and proper form and schedule.

Section 6662(j). Penalties may be 

imposed for undisclosed foreign 

financial asset understatements. No 

penalty will be imposed with respect 

to any portion of an underpayment if 

the taxpayer can demonstrate that the 

failure to comply was due to 

reasonable cause with respect to 

such portion of the underpayment and 

the taxpayer acted in good faith with 

respect to such portion of the 

underpayment. See sections 6662(j) 

and 6664(c) for additional information.

Inapplicability of certain penalties. 

Certain penalties under sections 6038 

and 6662 may be waived for certain 

persons under Rev. Proc. 2019-40. 

See section 7 of Rev. Proc. 2019-40 

for more details.

Other Reporting 

Requirements

Reporting exchange rates on Form 

5471. When translating amounts from 

functional currency to U.S. dollars, 

you must use the method specified in 

these instructions. For example, when 

translating amounts to be reported on 

Schedule E, you must generally use 

the average exchange rate as defined 

in section 986(a). But, regardless of 

the specific method required, all 

exchange rates must be reported 

using a “divide-by convention” 

rounded to at least four places. That 

is, the exchange rate must be 

reported in terms of the amount by 

which the functional currency amount 

must be divided in order to reflect an 

equivalent amount of U.S. dollars. As 

such, the exchange rate must be 

reported as the units of foreign 

currency that equal one U.S. dollar, 

rounded to at least four places. Do 

not report the exchange rate as the 

number of U.S. dollars that equal one 

unit of foreign currency.

Note. You must round the result to 

more than four places if failure to do 

so would materially distort the 

exchange rate or the equivalent 

amount of U.S. dollars.

Example. During its annual 

accounting period, the foreign 

corporation paid income taxes of 

30,255,400 Yen to Japan. The 

Schedule E instructions specify that 

the foreign corporation must translate 

these amounts into U.S. dollars at the 

average exchange rate for the tax year 

8 Instructions for Form 5471 (Rev. 01-2024)
to which the tax relates in accordance 

with the rules of section 986(a). The 

average exchange rate is 108.8593 

Japanese Yen to one U.S. dollar or 

(0.009184) U.S. dollar to one 

Japanese Yen. The foreign 

corporation divides 30,255,400 Yen by 

108.8593 to determine the U.S. dollar 

amount to enter in column (l) of 

Schedule E, Part I, Section 1, line 1. 

Line 1 of Schedule E, Part I, Section 

1, is completed in relevant part as 

follows.

• Enter the name of the payor entity in 

column (a).

• Enter the payor entity’s employer 

identification number (EIN) or 

reference ID number in column (b).

• Enter “JA” in column (d).

• Enter “JPY” in column (i).

• Enter “30,255,400 Yen” in column 

(j).

• Enter “108.8593” in column (k).

• Enter “277,931” in column (l).

Computer-Generated Form 

5471 and Schedules

Generally, all computer-generated 

forms must receive prior approval from 

the IRS and are subject to an annual 

review. However, see the Exception 

below. Requests for approval may be 

submitted electronically to 

substituteforms@irs.gov, or requests 

may be mailed to:

Internal Revenue Service

Attention: Substitute Forms 

Program

SE:W:CAR:MP:P:TP

1111 Constitution Ave. NW

Room 6554

Washington, DC 20224

Exception. If a computer-generated 

Form 5471 and its schedules conform 

to and do not deviate from the official 

form and schedules, they may be filed 

without prior approval from the IRS.

Important. Be sure to attach the 

approval letter to Form 5471. 

However, if the computer-generated 

form is identical to the IRS-prescribed 

form, it does not need to go through 

the approval process, and an 

attachment is not necessary.

Every year, the IRS issues a 

revenue procedure to provide 

guidance for filers of 

computer-generated forms. In 

addition, every year, the IRS issues 

Pub. 1167, General Rules and 

Specifications for Substitute Forms 

and Schedules, which reprints the 

most recent applicable revenue 

procedure. Pub. 1167 is available at 

IRS.gov/Pub. 1167.

Dormant Foreign Corporations

Rev. Proc. 92-70, 1992-2 C.B. 435, 

provides a summary filing procedure 

for filing Form 5471 for a dormant 

foreign corporation (defined in section 

3 of Rev. Proc. 92-70). This summary 

filing procedure will satisfy the 

reporting requirements of sections 

6038 and 6046.

If you elect the summary 

procedure, complete only page 1 of 

Form 5471 for each dormant foreign 

corporation as follows.

• The top margin of the summary 

return must be labeled “Filed Pursuant 

to Rev. Proc. 92-70 for Dormant 

Foreign Corporation.”

• Include filer information such as 

name and address, items A through 

C, and tax year.

• Include corporate information such 

as the dormant corporation's annual 

accounting period (below the title of 

the form) and items 1a, 1b, 1c, and 

1d.

For more information, see Rev. Proc. 

92-70.

File this summary return in the 

manner described under When and 

Where To File, earlier.

Treaty-Based Return Positions

You are generally required to file Form 

8833, Treaty-Based Return Position 

Disclosure Under Section 6114 or 

7701(b), to disclose a return position 

that any treaty of the United States 

(such as an income tax treaty; an 

estate and gift tax treaty; or a 

friendship, commerce, and navigation 

treaty):

• Overrides or modifies any provision 

of the Internal Revenue Code; and

• Causes, or potentially causes, a 

reduction of any tax incurred at any 

time.

See Form 8833 for exceptions.

Failure to make a required 

disclosure may result in a $1,000 

penalty ($10,000 for a C corporation). 

See section 6712.

Section 362(e)(2)(C) Elections

The transferor and transferee in 

certain section 351 transactions may 

make a joint election under section 

362(e)(2)(C) to limit the transferor's 

basis in the stock received instead of 

the transferee's basis in the 

transferred property. The election is 

made by a statement as provided in 

Regulations section 1.362-4(d)(3).

Do not attach the statement 

described above to Form 

5471.

Corrections to Form 5471

If you file a Form 5471 that you later 

determine is incomplete or incorrect, 

file a corrected Form 5471 with an 

amended tax return, using the 

amended return instructions for the 

return with which you originally filed 

Form 5471. Enter “Corrected” at the 

top of the form and attach a statement 

identifying the changes.

Foreign Disregarded Entities 

and Branches

If the foreign corporation for which you 

are furnishing information is the tax 

owner of a foreign disregarded entity 

(FDE) or foreign branch (FB), or a 

partner in a partnership, the amounts 

reported on Form 8858, Schedules 

K-1 and K-3 of Form 1065, or 

Schedules K-1 and K-3 of Form 8865 

must be included in determining the 

amounts reported on Form 5471. 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.

Specific Instructions

Important. If the information required 

in a given section exceeds the space 

provided within that section, do not 

enter “See attached” in the section 

and then attach all of the information 

on additional sheets. Instead, 

complete all entry spaces in the 

section and attach the remaining 

information on additional sheets. The 

additional sheets must conform with 

the IRS version of that section.

Identifying Information

Annual Accounting Period

Enter, in the space provided below the 

title of Form 5471, the annual 

accounting period of the foreign 

corporation for which you are 

furnishing information. Except for 

information contained on Schedule O, 

report information for the tax year of 

the foreign corporation that ends with 

CAUTION

!

Instructions for Form 5471 (Rev. 01-2024) 9
or within your tax year. When filing 

Schedule O, report acquisitions, 

dispositions, and organizations or 

reorganizations that occurred during 

your tax year.

Section 898 specified foreign corporation (SFC). The annual 

accounting period of an SFC (as 

defined in section 898) is generally 

required to be the tax year of the 

corporation's majority U.S. 

shareholder. If there is more than one 

majority shareholder, the required tax 

year will be the tax year that results in 

the least aggregate deferral of income 

to all U.S. shareholders of the foreign 

corporation.

For these purposes, section 898(b) 

defines an SFC as any foreign 

corporation:

1. That is treated as a CFC for any 

purpose under subpart F, and

2. In which more than 50% of the 

total voting power or value of all 

classes of stock of the corporation is 

treated as owned by a U.S. 

shareholder.

For more information, see section 

898 and Rev. Proc. 2006-45, 2006-45 

I.R.B. 851, available at IRS.gov/irb/

2006-45_IRB#RP-2006-45, as 

modified by Rev. Proc. 2007-64, 

2007-42 I.R.B. 818, available at 

IRS.gov/irb/

2007-42_IRB#RP-2007-64.

Name of Person Filing This 

Return

The name of the person filing Form 

5471 is generally the name of the U.S. 

person described in the applicable 

category or categories of filers (see 

Categories of Filers, earlier). However, 

in the case of a consolidated return, 

enter the name of the U.S. parent in 

the field for “Name of person filing this 

return.” Be sure to list each U.S. 

shareholder of the foreign corporation 

in Schedule B, Part I.

Name change. If the name of either 

the person filing the return or the 

corporation whose activities are being 

reported changed within the past 3 

years, show the prior name(s) in 

parentheses after the current name.

Address

Include the suite, room, or other unit 

number after the street address. If the 

post office does not deliver mail to the 

street address and the U.S. person 

has a P.O. box, show the box number 

instead.

Foreign address. Enter the 

information in the following order: city, 

province or state, and country. Follow 

the country's practice for entering the 

postal code, if any. Do not abbreviate 

the country name.

Item A—Identifying Number

The identifying number of an 

individual is his or her social security 

number (SSN). The identifying 

number of all others is their EIN. If a 

U.S. corporation that owns stock in a 

foreign corporation is a member of a 

consolidated group, list the common 

parent as the person filing the return 

and enter its EIN in item A.

Item B—Category of Filer

Complete item B to indicate the 

category or categories that describe 

the person filing this return. If more 

than one category applies, check all 

boxes that apply. See Categories of 

Filers, earlier.

Note. If you satisfy the requirements 

of both Category 4 and Category 5a 

filers, only check the box for Category 

4 and leave the box for Category 5a 

blank.

Item C—Percentage of Voting 

Stock Owned

Enter the total percentage of the 

foreign corporation's voting power you 

owned directly, indirectly, or 

constructively at the end of the 

corporation's annual accounting 

period.

Item D—Final Year

Check the item D checkbox only if this 

is the final year of the foreign 

corporation's existence as a 

corporation for federal tax purposes, 

for example, if a reorganization has 

occurred, a complete liquidation has 

occurred, or an election to treat the 

foreign corporation as a disregarded 

entity has been made. If this item D is 

checked, complete Schedule O.

Item E—Excepted Specified 

Foreign Financial Assets

Check the item E checkbox if any 

excepted specified foreign financial 

assets are reported on Form 5471. If 

this is the case, you do not have to 

also report these assets on Form 

8938. It is only necessary to complete 

Form 8938, Part IV, line 17. For more 

information, see the Instructions for 

Form 8938, generally, and in 

particular, Duplicative Reporting and 

the specific instructions for Part IV, 

Excepted Specified Foreign Financial 

Assets.

Item F—Alternative Information 

Under Rev. Proc. 2019-40

Check the item F checkbox if Form 

5471 has been completed using 

alternative information (as defined in 

section 3.01 of Rev. Proc. 2019-40).

Section 5 of Rev. Proc. 2019-40 

provides a safe harbor for determining 

certain items, including taxable 

income and E&P, of certain CFCs 

based on alternative information. 

Specifically, in the case of a 

foreign-controlled CFC with respect to 

which there is no related section 

958(a) U.S. shareholder, if information 

satisfying the requirements of 

Regulations section 1.952-2(a), (b), 

and (c)(2) and section 964 and the 

regulations thereunder is not readily 

available to an unrelated section 

958(a) U.S. shareholder or an 

unrelated constructive U.S. 

shareholder with respect to the 

foreign-controlled CFC, an amount 

reported on a Form 5471 may be 

determined by the unrelated section 

958(a) U.S. shareholder or the 

unrelated constructive U.S. 

shareholder, as applicable, on the 

basis of alternative information 

(without adjustments other than those 

described in section 3.01(b) and 3.10 

of the revenue procedure) with 

respect to the foreign-controlled CFC. 

See section 3 of Rev. Proc. 2019-40 

for definitions of terms.

Section 6 of Rev. Proc. 2019-40 

provides a safe harbor for determining 

certain items of certain SFCs based 

on alternative information. Specifically, 

in the case of an SFC, other than 

either a foreign-controlled CFC with 

respect to which there is no related 

section 958(a) U.S. shareholder or a 

U.S. controlled CFC, if information 

satisfying the requirements of section 

964 and the regulations thereunder is 

not readily available to an unrelated 

section 958(a) U.S. shareholder or an 

unrelated constructive U.S. 

shareholder with respect to the SFC, 

an amount reported on a Form 5471 

may be determined by the unrelated 

section 958(a) U.S. shareholder or the 

unrelated constructive U.S. 

shareholder, as applicable, on the 

10 Instructions for Form 5471 (Rev. 01-2024)
basis of alternative information 

(without adjustments other than those 

described in sections 3.01(b) and 

3.10 of the revenue procedure) with 

respect to the SFC. See section 3 of 

Rev. Proc. 2019-40 for definitions of 

terms.

Item G—Alternative Information 

Code

If the item F checkbox is checked, 

enter the applicable code from the list 

provided below.

01

Audited separate-entity financial 

statements of the foreign corporation that 

are prepared in accordance with U.S. 

generally accepted accounting principles 

(U.S. GAAP).

02

Audited separate-entity financial 

statements of the foreign corporation that 

are prepared on the basis of international 

financial reporting standards (IFRS).

03

Audited separate-entity financial 

statements of the foreign corporation that 

are prepared on the basis of the generally 

accepted accounting principles of the 

jurisdiction in which the foreign 

corporation is organized (“local-country 

GAAP”).

04

Unaudited separate-entity financial 

statements of the foreign corporation that 

are prepared in accordance with U.S. 

GAAP.

05

Unaudited separate-entity financial 

statements of the foreign corporation that 

are prepared on the basis of IFRS.

06

Unaudited separate-entity financial 

statements of the foreign corporation that 

are prepared on the basis of local-country 

GAAP.

07 Separate-entity records used by the 

foreign corporation for tax reporting.

08

Separate-entity records used by the 

foreign corporation for internal 

management controls or regulatory or 

other similar purposes. 

Information described in a code 

listed above qualifies as alternative 

information only if information 

described in any preceding code is 

not “readily available” (as defined in 

section 3.04 of Rev. Proc. 2019-40). 

For example, information described in 

code 03 above qualifies as alternative 

information only if information 

described in codes 01 and 02 is not 

readily available.

For more information, see Rev. 

Proc. 2019-40.

Item H—Person(s) on Whose 

Behalf This Information Return 

Is Filed

One person may file Form 5471 and 

the applicable schedules for other 

persons who have the same filing 

requirements. See Multiple filers of 

same information, earlier. The person 

that files the required information on 

behalf of other persons must 

complete a joint Form 5471 according 

to the applicable column(s) of the 

Filing Requirements for Categories of 

Filers, earlier. This includes 

completing item H on page 1 of the 

form. When completing item H with 

respect to members of a consolidated 

group, identify only the direct owners 

in item H (constructive owners are not 

required to be listed).

A separate Schedule I must be filed 

for each person described in Category 

4, 5a, or 5b. For each Category 4, 5a, 

or 5b filer that is required to file a 

Schedule I, send a copy of their 

separate Schedule I to them to assist 

them in completing their tax return.

A separate Worksheet H-1 must be 

attached for each person described in 

Category 4, 5a, 5b, or 5c. For each 

Category 4, 5a, 5b, or 5c filer that is 

required to file Worksheet H-1, send a 

copy of their separate Worksheet H-1 

to them to assist them in completing 

their tax return.

Note. New Worksheet H-1 may be 

found later in these instructions. See 

Worksheet H-1 and Worksheet H-1 

Instructions, later.

Filing requirements for persons 

identified in item H. Except for 

members of the filer's consolidated 

return group, all persons identified in 

item H must attach a statement to 

their tax returns that includes the 

following information.

• The name, address, and EIN (or 

reference ID number) of the foreign 

corporation(s).

• A statement that their filing 

requirements with respect to the 

foreign corporation(s) have been or 

will be satisfied.

• The name, address, and identifying 

number of the taxpayer on the return 

with which the information was or will 

be filed.

• The IRS Service Center where the 

return was or will be filed. If the return 

was or will be filed electronically, enter 

“e-file.”

Exception. If the person who is filing 

Form 5471 on behalf of others is 

married to a person identified in item 

H and they are filing Form 1040 jointly, 

the statement described above does 

not have to be attached to the jointly 

filed Form 1040.

All persons identified in item H 

must complete a separate 

Schedule P (Form 5471) if the 

person is a U.S. shareholder 

described in Category 1a, 1b, 4, 5a, or 

5b. In such a case, the Schedule P 

must be attached to the statement 

described above.

Item 1b(2)—Reference ID 

Number

A reference ID number (defined 

below) is required in item 1b(2) only in 

cases where no EIN was entered in 

item 1b(1) for the foreign corporation. 

However, filers are permitted to enter 

both an EIN in item 1b(1) and a 

reference ID number in item 1b(2). If 

applicable, enter the reference ID 

number you have assigned to the 

foreign corporation identified in item 

1a.

A “reference ID number” is a 

number established by or on behalf of 

the U.S. person identified at the top of 

page 1 of the form that is assigned to 

a foreign corporation with respect to 

which Form 5471 reporting is 

required. These numbers are used to 

uniquely identify the foreign 

corporation in order to keep track of 

the corporation from tax year to tax 

year.

The reference ID number must 

meet the requirements set forth below.

Note. Because reference ID numbers 

are established by or on behalf of the 

U.S. person filing Form 5471, there is 

no need to apply to the IRS to request 

a reference ID number or for 

permission to use these numbers.

Note. The reference ID number 

assigned to a foreign corporation on 

Form 5471 generally has relevance 

only on Form 5471, its schedules, and 

any other form that is attached to or 

associated with Form 5471, and 

generally should not be used with 

respect to that foreign corporation on 

any other IRS forms. However, the 

foreign corporation’s reference ID 

number should also be entered on 

Form 8858 if the foreign corporation is 

CAUTION

!

Instructions for Form 5471 (Rev. 01-2024) 11
listed as a tax owner of an FDE or FB 

on Form 8858. See the instructions for 

Form 8858, line 3c(2), for more 

information. Also, if a U.S. shareholder 

is required to file Schedule A (Form 

8992) or Schedule B (Form 8992) with 

respect to the CFC, the reference ID 

number on Form 5471 and the 

reference ID number used on 

Schedule A (Form 8992) or 

Schedule B (Form 8992) for that CFC 

must be the same.

Requirements. The reference ID 

number that is entered in item 1b(2) 

must be alphanumeric (defined below) 

and no special characters or spaces 

are permitted. The length of a given 

reference ID number is limited to 50 

characters.

The same reference ID number 

must be used consistently from tax 

year to tax year with respect to a given 

foreign corporation. If for any reason a 

reference ID number falls out of use 

(for example, the foreign corporation 

no longer exists due to disposition or 

liquidation), the reference ID number 

used for that foreign corporation 

cannot be used again for another 

foreign corporation for purposes of 

Form 5471 reporting.

For these purposes, the term 

“alphanumeric” means the entry can 

be alphabetical, numeric, or any 

combination of the two.

Taxpayers no longer have the 

option of entering “FOREIGNUS” or 

“APPLIED FOR” in a column that 

requests an EIN or reference ID 

number with respect to a foreign 

entity. Instead, if the foreign entity 

does not have an EIN, the taxpayer 

must enter a reference ID number that 

uniquely identifies the foreign entity.

Correlation issues. There are some 

situations that warrant correlation of a 

new reference ID number with a 

previous reference ID number when 

assigning a new reference ID number 

to a foreign corporation. For example:

• In the case of a merger or 

acquisition, a Form 5471 filer must 

use a reference ID number that 

correlates the previous reference ID 

number with the new reference ID 

number assigned to the foreign 

corporation; or

• In the case of an entity 

classification election that is made on 

behalf of a foreign corporation on 

Form 8832, Regulations section 

301.6109-1(b)(2)(v) requires the 

foreign corporation to have an EIN for 

this election. For the first year that 

Form 5471 is filed after an entity 

classification election is made on 

behalf of the foreign corporation on 

Form 8832, the new EIN must be 

entered in item 1b(1) of Form 5471 

and the old reference ID number must 

be entered in item 1b(2). In 

subsequent years, the Form 5471 filer 

may continue to enter both the EIN in 

item 1b(1) and the reference ID 

number in item 1b(2), but must enter 

at least the EIN in item 1b(1).

You must correlate the reference ID 

numbers as follows: Enter the new 

reference ID number in item 1b(2) and 

enter the previous reference ID 

number(s) in item 1b(3). If there is 

more than one old reference ID 

number, you must enter a space 

between each such number. As 

indicated above, the length of a given 

reference ID number is limited to 50 

characters and each number must be 

alphanumeric and no special 

characters are permitted.

Note. This correlation requirement 

applies only to the first year the new 

reference ID number is used and it 

applies only on Form 5471, page 1, 

items 1b(2) and 1b(3). On all separate 

schedules for Form 5471, please 

enter only the current reference ID 

number in the applicable entry space.

Item 1b(3)—Previous Reference 

ID Number(s), if Any

See Correlation issues, earlier.

Items 1f and 1g—Principal 

Business Activity

Enter the principal business activity 

code number and the description of 

the activity from the list at the end of 

these instructions.

Effective beginning with tax 

year 2022, several changes 

were made to the principal 

business activities and codes listed at 

the end of these instructions. See the 

revised list before entering a six-digit 

code and the description of the 

activity on page 1, items 1f and 1g.

Item 1h—Functional Currency

The foreign corporation's functional 

currency is determined under section 

985. Enter the applicable 

three-character alphabet code for the 

foreign corporation's functional 

currency using the ISO 4217 

CAUTION

!

standard. These codes are available 

at six-group.com/en/productsservices/financial-information/datastandards.html#scrollTo=currencycodes. Click on List One (XLS).

Regulations sections 1.6038-2(h) 

and 1.6046-1(g) require that certain 

amounts be reported in U.S. dollars 

and/or in the foreign corporation's 

functional currency. The specific 

instructions for the affected schedules 

state these requirements.

Special rules apply for foreign 

corporations that use the U.S. dollar 

approximate separate transactions 

method of accounting (DASTM) under 

Regulations section 1.985-3. See 

Schedule C, Schedule F, and 

Schedule H, later.

Schedule B

Note. If any person (including the 

filer) is both a U.S. shareholder and a 

direct shareholder of the foreign 

corporation, that person’s information 

should be provided in both 

Schedule B, Part I and Part II.

Part I

Category 3 and 4 filers must complete 

Schedule B, Part I, for U.S. persons 

that owned (at any time during the 

annual accounting period), directly or 

indirectly through foreign entities, 10% 

or more of the total combined voting 

power of all classes of stock entitled 

to vote of the foreign corporation, or 

10% or more of the total value of 

shares of all classes of stock of the 

foreign corporation.

A person that is both a category 3 

and category 5 filer because it is 

treated as a U.S. shareholder under 

section 953(c)(1)(A) with respect to 

the foreign corporation must complete 

Schedule B, Part I, for U.S. persons 

that owned (on the last day of the 

foreign corporation’s tax year), directly 

or indirectly through foreign entities, 

any of the foreign corporation's 

outstanding stock.

Column (e). Enter each 

shareholder's allocable percentage of 

the foreign corporation's subpart F 

income.

Part II

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 

12 Instructions for Form 5471 (Rev. 01-2024)
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 Schedule H, 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.

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.

Include all derivatives, both 

short-term and long-term.

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.

1. Name and EIN (if any) of the 

foreign partnership.

2. 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 8804.

3. Name of the partnership 

representative (if any).

4. Beginning and ending dates of 

the foreign partnership's tax year.

Question 3

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 

Instructions for Form 5471 (Rev. 01-2024) 13
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.

Questions 4b and 4c

Complete lines 4b and 4c if:

1. The foreign corporation is a 

related party to the U.S. filer within the 

meaning of section 59A(g); and

2. 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 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 22 

questions in the Schedule G, Line 14 

table below. If “Yes,” enter the 

corresponding code(s) from the table 

14 Instructions for Form 5471 (Rev. 01-2024)
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.

Form 5471, Schedule G, Line 14

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

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 13g, 14d, 15d, 

16d, 18d, or 19d 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, or 

foreign base company services income reduced so as to take 

into account any deductions (including taxes)? 

In other words, is 

line 13b, 13d, 13e, 

14b, 15b, or 16b 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 1c 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. 01-2024) 15
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

16 Instructions for Form 5471 (Rev. 01-2024)
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

21 During the tax year, did the subpart F income of the CFC 

exceed the earnings and profits of such corporation? 

In other words, is 

line 36 of Worksheet 

A greater than 

line 37c? 

EP Earnings & 

profits 

limitation

Excess of line 36 

over line 37c

Instructions for Form 5471 (Rev. 01-2024) 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

22 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 58 of Worksheet 

A greater than zero?

PRS Pro Rata 

Share

The amounts from 

lines 58 and 59 of 

Worksheet A

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.

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 

18 Instructions for Form 5471 (Rev. 01-2024)
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).

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 63, 

65, 67, and 69, respectively. However, 

corporate U.S. shareholders should 

report on line 1e the amount from 

Worksheet A, line 63, 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 1 through 

17).

• Adjusted net insurance income 

(Worksheet A, line 18).

• Adjusted net related person 

insurance income (Worksheet A, 

line 19).

• International boycott income 

(Worksheet A, line 20).

• Illegal bribes, kickbacks, and other 

payments (Worksheet A, line 21).

• Income described in section 952(a)

(5) (Worksheet A, line 22).

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 69, and include the 

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. 

Instructions for Form 5471 (Rev. 01-2024) 19
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 line 1a on Form 1120, 

Schedule C, line 16a; enter the result 

from line 1b on Form 1120, 

Schedule C, line 16b; and enter the 

remaining 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 line 5a 

amount on Form 1120, Schedule C, 

line 13, column (a), or 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 line 5b 

amount on Form 1120, Schedule C, 

line 14, column (a), or 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 line 5c 

amount on Form 1120, Schedule C, 

line 14, column (a), or 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 hybrid 

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 line 5d 

amount on Form 1120, Schedule C, 

line 14, column (a), or 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 line 5e 

amount on Form 1120, Schedule C, 

line 14, column (a), or 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, 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.

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 

20 Instructions for Form 5471 (Rev. 01-2024)
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.

Instructions for Form 5471 (Rev. 01-2024) 21
Worksheet A

16 Adjusted net full inclusion foreign base company income:

a Enter the excess, if any, of line 11 over line 7 16a

b Expenses allocated and apportioned under section 954(b)(5) 16b

c Net full inclusion foreign base company income. Subtract line 16b from line 16a 16c

d Net full inclusion foreign base company income excluded under high-tax exception 16d

e Subtract line 16d from line 16c

1 Gross foreign personal holding company income:

a Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A)

(excluding amounts described in sections 954(c)(2), (3), and (6)) 1a

Excess of gains over losses from certain property transactions

(section 954(c)(1)(B))

b

1b

c Excess of gains over losses from commodity transactions (section 954(c)(1)(C)) 1c

d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D)) 1d

e Income equivalent to interest (section 954(c)(1)(E)) 1e

2 Gross foreign personal holding company income. Add lines 1a through 1i 2

3 Gross foreign base company sales income (see section 954(d)) 3

4 Gross foreign base company services income (see section 954(e)) 4

5 5

6

6

Gross foreign base company income. Add lines 2 through 4

7 7

Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 18 and 

19)

8 8

Gross foreign base company income and gross insurance income. Add lines 5 and 6

9

Enter 5% of total gross income (as computed for income tax purposes)

9

10 10

Enter 70% of total gross income (as computed for income tax purposes)

11

If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 19

11 If line 7 is more than line 9, enter total gross income (as computed for income tax purposes)

12

12

Total adjusted gross foreign base company income and insurance income (enter the greater of 

line 7 or line 11)

13 Adjusted net foreign personal holding company income:

a Enter amount from line 2 13a

13d

b

Related person interest expense (see section 954(b)(5))

c

Other expenses allocated and apportioned to the amount on line 2

under section 954(b)(5) 13e

d

Net foreign personal holding company income. Subtract the sum of

lines 13d and 13e from line 13c 13f

13g

Net foreign personal holding company income excluded under

high-tax exception

e

Subtract line 13g from line 13f 13h

f

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 Net foreign base company sales income excluded under high-tax exception 14d

e Subtract line 14d from line 14c 14e

15 Adjusted net foreign base company services income:

a Enter amount from line 4 15a

b Expenses allocated and apportioned to line 4 under section 954(b)(5) 15b

c Net foreign base company services income. Subtract line 15b from line 15a 15c

d Net foreign base company services income excluded under high-tax exception 15d

e Subtract line 15d from line 15c 15e

Expenses directly related to amount on line 2

Subtract line 13b from line 13a

13b

13c

g

h

Net 1f f income from a notional principal contract (section 954(c)(1)(F))

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))

i Certain amounts from sales of partnership interests to which the

look-through rule of section 954(c)(4) applies

1h

1i

16e

Summary of U.S. Shareholder’s Pro Rata Share of Subpart F Income of a CFC (See the Worksheet A 

instructions, later.) Enter the amounts on lines 1a through 62, 64, 66, and 68 in functional currency.

22 Instructions for Form 5471
Worksheet A

Worksheet A (continued) (See instructions.)

17 Adjusted net foreign base company income. Add lines 13h, 14e, 15e, and 16e . . . . . . . 17

18 Adjusted net insurance income (other than related person insurance income):

a Enter amount from line 6 (other than related person insurance income) . . 18a

b Expenses allocated and apportioned to the amount on line 18a under section

953 . . . . . . . . . . . . . . . . . . . . . . . . . 18b

c Net insurance income. Subtract line 18b from line 18a . . . . . . . . 18c

d Net insurance income excluded under high-tax exception . . . . . . . 18d

e Subtract line 18d from line 18c . . . . . . . . . . . . . . . . . . . . . . . . 18e

19 Adjusted net related person insurance income:

a Enter amount from line 6 that is related person insurance income . . . . 19a

b Expenses allocated and apportioned to the amount on line 19a under section

953 . . . . . . . . . . . . . . . . . . . . . . . . . 19b

c Net related person insurance income. Subtract line 19b from line 19a . . . 19c

d Net related person insurance income excluded under high-tax exception . . 19d

e Subtract line 19d from line 19c . . . . . . . . . . . . . . . . . . . . . . . . 19e

20 International boycott income (section 952(a)(3)) . . . . . . . . . . . . . . . . . . 20

21 Illegal bribes, kickbacks, and other payments (section 952(a)(4)) . . . . . . . . . . . . . 21

22 Income described in section 952(a)(5) (see instructions) . . . . . . . . . . . . . . . 22

23 Subpart F income before application of section 952(b) and (c), section 959(b), and section 961(c). Add 

lines 17, 18e, 19e, and 20 through 22 . . . . . . . . . . . . . . . . . . . . . . 23

24 Enter the portion of line 13h that is U.S. source income effectively connected

with a U.S. trade or business (section 952(b)) . . . . . . . . . . . 24

25 Exclusions under section 959(b) and section 961(c) basis that apply to line 13h

amount . . . . . . . . . . . . . . . . . . . . . . . 25

26 Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract the sum of lines

24 and 25 from line 13h . . . . . . . . . . . . . . . . . . . . . . . . . . 26

27 Enter the portion of line 14e that is U.S. source income effectively connected

with a U.S. trade or business (section 952(b)) . . . . . . . . . . . 27

28 Exclusions under section 959(b) that apply to line 14e amount . . . . . 28

29 Section 954(d) subpart F Foreign Base Company Sales Income. Subtract the sum of lines 27 and 

28 from line 14e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

30 Enter the portion of line 15e that is U.S. source income effectively connected

with a U.S. trade or business (section 952(b)) . . . . . . . . . . . 30

31 Exclusions under section 959(b) that apply to line 15e amount . . . . . 31 -0-

32 Section 954(e) subpart F Foreign Base Company Services Income. Subtract the sum of lines 30 

and 31 from line 15e . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

33 Enter the sum of the portion of lines 16e, 18e, 19e, 20, 21, and 22 that is U.S. 

source income effectively connected with a U.S. trade or business (section

952(b)) . . . . . . . . . . . . . . . . . . . . . . . . 33

34 Exclusions under section 959(b) that apply to line 16e, 18e, 19e, 20, 21, and 

22 amounts . . . . . . . . . . . . . . . . . . . . . . 34

35 Other subpart F income. Subtract the sum of lines 33 and 34 from the sum of lines 16e, 18e, 19e, 

20, 21, and 22 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

36 Total subpart F income. Add lines 26, 29, 32, and 35 . . . . . . . . . . . . . . . . 36

37 Current E&P limitation computation:

a Current E&P . . . . . . . . . . . . . . . . . . . . . . 37a

b Tested loss (enter as a positive number—see instructions) . . . . . . . 37b

c Total of line 37a and line 37b . . . . . . . . . . . . . . . . 37c

38 Enter the smaller of line 36 or line 37c . . . . . . . . . . . . . . . . . . . . . 38

-0-

Instructions for Form 5471 (Rev. 01-2024) 23
Worksheet A

Worksheet A (continued) (See instructions.)

39 If the amount on line 37c is less than the amount on line 36, allocate the subpart F income remaining (after having been limited) 

to lines 40, 41, 42, and 43 below in the manner prescribed by Regulations section 1.952-1(e). If the amount on line 37c is 

greater than or equal to the amount on line 36, enter the amount from line 26 onto line 40, enter the amount from line 29 onto 

line 41, enter the amount from line 32 onto line 42, and enter the amount from line 35 onto line 43.

40 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal . . . . . . . . 40

41 Section 954(d) subpart F Foreign Base Company Sales Income subtotal . . . . . . . . . . 41

42 Section 954(e) subpart F Foreign Base Company Services Income subtotal . . . . . . . . . 42

43 Other subpart F income subtotal . . . . . . . . . . . . . . . . . . . . . . . 43

44 Shareholder’s pro rata share of line 40 . . . . . . . . . . . . . 44

45 Shareholder’s pro rata share of export trade income that applies to line 44 

amount (see section 970(a)) . . . . . . . . . . . . . . . . . 45

46 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 45 from

line 44 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46

47 Shareholder’s pro rata share of line 41 . . . . . . . . . . . . . 47

48 Shareholder’s pro rata share of export trade income that applies to line 47 

amount (see section 970(a)) . . . . . . . . . . . . . . . . . 48

49 Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 48 from line 47 49

50 Shareholder’s pro rata share of line 42 . . . . . . . . . . . . . 50

51 Shareholder’s pro rata share of export trade income that applies to line 50 

amount (see section 970(a)) . . . . . . . . . . . . . . . . . 51

52 Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 51 from line

50 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

53 Shareholder’s pro rata share of line 43 . . . . . . . . . . . . . 53

54 Shareholder’s pro rata share of export trade income that applies to line 53 

amount (see section 970(a)) . . . . . . . . . . . . . . . . . 54

55 Other subpart F income subtotal. Subtract line 54 from line 53 . . . . . . . . . . . . . 55

56 Add lines 46, 49, 52, and 55 . . . . . . . . . . . . . . . . . . . . . . . . . 56

57 Divide the number of days in the tax year that the corporation was a CFC by

the number of days in the tax year and multiply the result by line 56 . . . . 57

58 The amount of dividends received by any other person with respect to your 

stock multiplied by a fraction, the numerator of which is the CFC's subpart F 

income for the tax year and the denominator of which is the sum of the CFC's 

subpart F income and tested income (section 951A(c)(2)(A) and Regulations

section 1.951A-2(b)(1)) for the tax year . . . . . . . . . . . . . 58

59 Divide the number of days in the tax year you did not own such stock by the

number of days in the tax year and multiply the result by line 56 . . . . . 59

60 Enter the smaller of line 58 or line 59 . . . . . . . . . . . . . . 60

61 Shareholder’s pro rata share of subpart F income. Subtract line 60 from line 57 . . . . . . 61

62 Amount of line 61 that applies to section 954(c) subpart F Foreign Personal Holding Company Income 62

63 Translate the amount on line 62 from functional currency to U.S. dollars at the average exchange rate. 

See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1e . . . . . . . . 63

64 Amount of line 61 that applies to section 954(d) subpart F Foreign Base Company Sales Income . . 64

65 Translate the amount on line 64 from functional currency to U.S. dollars at the average exchange rate. 

See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1f . . . . . . . . 65

66 Amount of line 61 that applies to section 954(e) subpart F Foreign Base Company Services Income . 66

67 Translate the amount on line 66 from functional currency to U.S. dollars at the average exchange rate. 

See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1g . . . . . . . . 67

68 Amount of line 61 that applies to other subpart F income . . . . . . . . . . . . . . . 68

69 Translate the amount on line 68 from functional currency to U.S. dollars at the average exchange rate. 

See section 989(b). Enter the result here and on Form 5471, Schedule I, line 1h . . . . . . . . 69

24 Instructions for Form 5471 (Rev. 01-2024)
Worksheet A Instructions

Foreign base company income. 

Foreign base company income 

generally does not include the 

following.

• Foreign base company shipping 

income as defined in former section 

954(f).

• 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)).

Line 1a. 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.

Line 1b. Enter the excess of gains 

over losses from the sale or exchange 

of:

• 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)).

• 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 1c. 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.

Line 1d. 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. Enter any income equivalent 

to interest, including income from 

commitment fees (or similar amounts) 

for loans actually made.

Line 1f. Include net income from 

notional principal contracts (except a 

contract entered into to hedge 

inventory property).

Line 1g. Include payments in lieu of 

dividends that are made as required 

under section 1058.

Line 1h. 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 1i. For tax years beginning after 

December 31, 2004, 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 

Instructions for Form 5471 (Rev. 01-2024) 25
partnership under constructive 

ownership rules similar to the rules of 

section 958(b), the CFC shall be 

treated as owning such interest 

directly or indirectly for purposes of 

this definition.

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 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 

high-tax exception described below, 

the section 952(b) exclusion, and the 

deductions to be taken into account 

under section 954(b)(5)) 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.

Lines 13b, 13d, 13e, 14b, 15b, and 

16b. Expenses. Adjusted net foreign 

base company income is calculated 

by first determining the gross amount 

of each item of income and then 

allocating and apportioning expenses 

to such items of income. 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.

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.

Lines 13g, 14d, 15d, 16d, 18d, and 

19d. Exception for certain income 

subject to high foreign taxes. 

Foreign base company income and 

insurance income do not include any 

item of income received by a CFC if 

the taxpayer establishes that such 

income was subject to an effective 

rate of income tax imposed by a 

foreign country that is greater than 

90% of the maximum rate of tax 

specified in section 11. For more 

information, see section 954(b)(4) and 

Regulations section 1.954-1(d)(1).

Line 18. Adjusted net insurance income. 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)).

Line 18b. Expenses. Do not enter 

expenses on this line to the extent that 

their allocation and apportionment 

reduces an item of insurance income 

below zero.

Note. In determining the amount of 

a net item of 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 19. Adjusted net related person insurance income. 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:

1. 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,

2. Elects to waive all treaty 

benefits (other than from section 884) 

for related person insurance income, 

and

3. Meets any requirement the IRS 

may prescribe to ensure that any tax 

on such income is paid.

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.

Line 19b. Expenses. Do not enter 

expenses on this line to the extent that 

their allocation and apportionment 

reduces an item of insurance income 

below zero.

Note. In determining the amount of 

a net item of insurance income, 

deductions or loss attributable to 

disqualified basis and deductions 

26 Instructions for Form 5471 (Rev. 01-2024)
attributable to disqualified payments 

(Regulations section 1.951A-2(c)(5) 

or (6)) are not allocated and 

apportioned to gross insurance 

income.

Line 20. 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 21. Illegal bribes, kickbacks, 

and other payments. 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 22. 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. shareholders of such CFC. 

As of the date these instructions were 

revised, section 901(j) applied to Iran, 

North Korea, Sudan, and Syria.

Lines 24, 27, 30, and 33. Exclusion 

of U.S. income. Subpart F income 

does not include any U.S. source 

income (which, for these purposes, 

includes all carrying charges and all 

interest, dividends, royalties, and 

other investment income received or 

accrued by an FSC) that is effectively 

connected with a CFC's conduct of a 

trade or business in the United States 

unless that item is exempt from 

taxation (or is subject to a reduced 

rate of tax) pursuant to a treaty 

obligation of the United States or the 

Code.

Line 37. Current E&P limitation. A 

CFC's subpart F income is limited to 

the sum of the following.

• Its current year E&P, computed 

under the special rule of section 

952(c)(1). Enter this amount on 

line 37a.

• Any tested loss under section 

951A(c)(2)(B)(ii). If the total of all lines 

6 of all separate Schedules I-1 (Form 

5471) for the CFC is a negative 

number, enter the amount as a 

positive number on line 37b. If the 

total of all lines 6 is a positive number 

or zero, enter -0- on line 37b.

The amount included in the gross 

income of a U.S. shareholder of a 

CFC under section 951(a)(1)(A) for 

any tax year and attributable to a 

qualified activity must be reduced by 

the shareholder's pro rata share of 

any qualified deficit (see section 

952(c)(1)(B)).

Lines 39 through 43. If Worksheet 

A, line 37c, is less than the amount on 

Worksheet A, line 36, allocate the 

subpart F income remaining (after 

having been limited) (that is, the 

line 38 amount) to the four categories 

of subpart F income listed on 

Worksheet A, lines 40 through 43, 

using the rules of Regulations section 

1.952-1(e).

Instructions for Form 5471 (Rev. 01-2024) 27
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:

1. Compute the current year 

subpart F income inclusion 

(potentially increasing the section 

959(c)(2) PTEP within the PTEP 

accounts),

2. Take into account current 

distributions (potentially reducing the 

PTEP accounts and untaxed earnings 

and profits), and

3. 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 

Worksheet B

.

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 dened in section 956(c) and (d)) held (directly or 

indirectly) by the CFC as of the close of:

a The rst 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 . . . . . . . . 2

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.) . . . 3

4 U.S. shareholder’s pro rata share of the amount on line 3 . . . . . . . . . . . . . . . 4

5 Earnings and prots described in section 959(c)(1)(A) with respect to the U.S. shareholder after 

reductions (if any) for current year distributions . . . . . . . . . . . . . . . . . . 5

6 Section 956(a)(1) amount. Subtract line 5 from line 4 . . . . . . . . . . . . . . . . 6

7 Applicable earnings:

a Current year earnings and prots . . . . . . . . . . . . . . . 7a

b Line 7a plus accumulated earnings and prots . . . . . . . . . . 7b

8 Enter the greater of line 7a or line 7b . . . . . . . . . . . . . . . . . . . . . . 8

9 Distributions made by the CFC during the tax year . . . . . . . . . . . . . . . . . 9

10 Subtract line 9 from line 8 . . . . . . . . . . . . . . . . . . . . . . . . . 10

11 Earnings and prots described in section 959(c)(1) after reductions (if any) for current year distributions 11

12 Applicable earnings. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . 12

13 Section 956(a)(2) amount. U.S. shareholder’s pro rata share of the amount on line 12 . . . . . 13

14 Section 956(a) amount. Enter the smaller of line 6 or line 13 . . . . . . . . . . . . . . 14

15 Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder . . . . . . 15

16 Tentative section 956 amount. Subtract line 15 from line 14 . . . . . . . . . . . . . . 16

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 . . . . . . . . . . . . . 17

18 Section 956 amount. Subtract line 17 from line 16 . . . . . . . . . . . . . . . . . 18

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 . . . . . . . . . 19

28 Instructions for Form 5471 (Rev. 01-2024)
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.

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).

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 

Instructions for Form 5471 (Rev. 01-2024) 29
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 

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/financialinformation/datastandards.html#scrollTo=currencycodes.

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).

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.

1. The tax is paid before the 

beginning of the year to which the tax 

relates.

2. Accrued taxes are not paid 

before the date 2 years after the close 

of the tax year to which such taxes 

relate.

3. 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.

4. The foreign corporation reports 

on the cash basis. See section 986(a).

5. 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, 2023. 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, 2023, 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, 

30 Instructions for Form 5471 (Rev. 01-2024)
the revised tax liability is $2. All 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 2023 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): 2023/12/31

• Line 1, column (f): 2023/12/31

• 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 

5471. 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).

Column (d)

Enter the code which 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 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 

Instructions for Form 5471 (Rev. 01-2024) 31
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.

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).

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 (l), 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).

32 Instructions for Form 5471 (Rev. 01-2024)
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 ten 

PTEP group columns. Also see 

Regulations section 1.960-3(c)(2) for 

additional information regarding the 

ten 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 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 on 

Schedule E, Part I, Section 1, line 5, 

column (l), 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 

Schedule E, Part I, Section 1, line 5, 

column (l), 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 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 E-1 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 12.

Line 9. A domestic corporation is 

deemed to pay foreign income taxes 

attributable to inclusions under 

Instructions for Form 5471 (Rev. 01-2024) 33
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 on line 10, column (e), 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 recorded 

on line 10, column (e)(x), of CFC1’s 

Form 5471, 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.

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 1.482-7(j)) during 

the tax year. All amounts should be 

reported in U.S. dollars.

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).

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 a 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 

34 Instructions for Form 5471 (Rev. 01-2024)
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.

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.

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 Worksheet H-1 

must be attached for each person 

described in Categories 4, 5a, 5b, and 

5c with respect to which reporting is 

furnished on this Form 5471 that is an 

applicable corporation within the 

meaning of section 59(k). Worksheet 

H-1 and instructions are provided later 

in these instructions.

Note. Category 5b and 5c filers are 

not required to file Schedule H for 

foreign-controlled CFCs.

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).

Special rules for DASTM. If the 

foreign corporation uses DASTM, 

enter on line 1 the dollar GAAP 

income or (loss) 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.

Instructions for Form 5471 (Rev. 01-2024) 35
Line 2h. Enter the adjustment to 

foreign currency gains or losses. 

Attach a statement with a description 

of the gain 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.

36 Instructions for Form 5471 (Rev. 01-2024)
Worksheet H-1

Complete a separate Worksheet H-1 in machine-readable Excel format for each person described in Categories 4, 5a, 5b, and 5c with 

respect to which reporting is furnished on this Form 5471 that is an applicable corporation within the meaning of section 59(k).

Filer’s Pro Rata Share of CFC Adjusted Net Income or Loss for Corporate Alternative Minimum Tax

1 Net income (or loss) set forth on the applicable nancial statement . . . . . . . . . . . . 1

Net 

additions

Net 

2 Adjustments made to line 1 (see instructions) subtractions

a Statements covering different taxable years . . . . . 2a

b Consolidated nancial statements . . . . . . . . . 2b

c Consolidated returns . . . . . . . . . . . . . 2c

d Treatment of dividends and other amounts . . . . . . 2d

e Treatment of partnerships . . . . . . . . . . . 2e

f Effectively connected income . . . . . . . . . . 2f

g Adjustments for certain taxes . . . . . . . . . . 2g

h Adjustments with respect to disregarded entities . . . . 2h

i Depreciation . . . . . . . . . . . . . . . . 2i

j Other adjustments (see instructions) . . . . . . . . 2j

3 Total net additions . . . . . . . . . . . . . . 3

4 Total net subtractions . . . . . . . . . . . . . 4

5a Adjusted net income or loss (line 1 plus line 3 minus line 4) . . . . . . . . . . . . . . 5a

b Filer’s pro rata share of line 5a (see instructions) . . . . . . . . . . . . . . . . . . 5b

c Adjusted net income or loss in U.S. dollars (see instructions) . . . . . . . . . . . . . . 5c

d Enter exchange rate used for line 5c . . . . . . . . . . . . . . 5d

Worksheet H-1 Instructions

Use Worksheet 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 5b in the CFC’s 

functional currency.

Lines 2a through 2j. 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.

Line 2j. Enter the net amount of any 

additional adjustments not included 

on lines 2a through 2i. List these 

additional adjustments on a separate 

statement. Attach this statement to 

Form 5471.

Line 5b. Enter the filer’s pro rata 

share (determined under rules similar 

to the rules under section 951(a)(2)) 

of the amount on line 5a.

Line 5c. Enter the line 5b functional 

currency amount translated into U.S. 

dollars for the CFC’s tax year.

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 F—Alternative 

Information Under Rev. Proc. 

2019-40, earlier, for more details.

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.”

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 

Instructions for Form 5471 (Rev. 01-2024) 37
positive amount. However, if a CFC’s 

cost of goods sold exceeds its gross 

receipts, a negative amount is 

permitted on line 1.

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)(A).

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 4. The line 4 

result can be positive or negative. For 

example:

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 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 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 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).

38 Instructions for Form 5471 (Rev. 01-2024)
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.

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. Category 1b, 1c, 5b, and 5c 

filers are not required to file 

Schedule J for foreign-controlled 

section 965 SFCs or 

foreign-controlled CFCs.

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 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 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 the instructions for 

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 

Instructions for Form 5471 (Rev. 01-2024) 39
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.

• 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).

1. PTEP attributable to 

investments in U.S. property and not 

by reason of reclassification.

2. 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).

3. 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).

1. PTEP attributable to hybrid 

dividends under section 245A(e)(2) 

and reclassified as investments in 

U.S. property.

2. PTEP attributable to section 

1248 amounts under section 959(e) 

and reclassified as investments in 

U.S. property.

3. 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).

• Column (e)(ix) is PTEP described in 

the following three subgroups (which 

are aggregated into a single PTEP 

group) (section 959(c)(2) amounts).

1. PTEP attributable to hybrid 

dividends under section 245A(e)(2).

2. PTEP attributable to section 

1248 amounts under section 959(e).

3. 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, 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 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 

40 Instructions for Form 5471 (Rev. 01-2024)
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 from 

Schedule H (Form 5471), line 5c(ii), in 

the applicable column. 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 in column (a), (b), 

or (c) of line 5a 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 line 5b of columns (a), (b), 

and (c) 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 

on CFC2’s Form 5471, Schedule J, 

line 4, column (e)(x), 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.

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 of 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 Schedule R (Form 5471), 

column (d), 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 

Instructions for Form 5471 (Rev. 01-2024) 41
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).

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.

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. 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.

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 

42 Instructions for Form 5471 (Rev. 01-2024)
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.

Schedule O

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.

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. Use the reference ID 

number shown on Form 5471, page 1, 

item 1b(2).

Part I

Column (d). Enter the date the 

shareholder first acquired 10% or 

more (in value or voting power) of the 

outstanding stock of the foreign 

corporation.

Column (e). Enter the date the 

shareholder acquired (whether in one 

or more transactions) an additional 

10% or more (in value or voting 

power) of the outstanding stock of the 

foreign corporation.

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, Mr. Jackson, a 

U.S. citizen, purchased 10,000 shares 

of common stock of foreign 

corporation X. The purchase 

represented 10% ownership of the 

foreign corporation.

On July 1, 2023, Mr. Jackson made 

a gift of 5,000 shares of foreign 

corporation X to his son, John. 

Because Mr. Jackson 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, Mr. 

Jackson completes Section D as 

follows.

• Enters his name in column (a).

• Enters “common” in column (b).

• Enters “July 1, 2023” 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 

son, John, 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.

Schedule P

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 

Instructions for Form 5471 (Rev. 01-2024) 43
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.

If a U.S. shareholder wholly owns 

the CFC, Schedule P should include 

the same information reported on 

Schedule J, Part I, column (e). 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 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.

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.

Part I

Enter amounts in the functional 

currency of the foreign corporation as 

reported on Form 5471, page 1, item 

1h.

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 category.

Part II

Dollar basis. Enter amounts in U.S. 

dollars. The U.S. shareholder’s U.S. 

dollar basis in PTEP is generally equal 

to the U.S. dollar amount of E&P that 

the U.S. shareholder previously 

included in gross income. See section 

989(b)(1) and (3); and Regulations 

sections 1.951A-1(d)(1) and 

1.965-1(b)(1) and (2).

The U.S. shareholder’s U.S. dollar 

basis is used by the U.S. shareholder 

to determine the amount of foreign 

currency gain or loss on the PTEP that 

the U.S. shareholder is required to 

recognize under section 986(c).

Columns (a) through (k). Use 

columns (a) through (k) to report the 

opening balance of, current year 

additions and subtractions to, and the 

closing balance of, the PTEP in the 

U.S. shareholder’s annual PTEP 

accounts with respect to a CFC.

Columns (a) through (j) of 

Schedule P correspond to 

Schedule J, columns (e)(i) through (e)

(x). See Schedule J, earlier, for 

specific line instructions.

Line 1b. If there is a difference 

between last year’s ending balance on 

Schedule P and the amount that 

should be last year’s ending balance, 

taking into account modifications on 

Schedule P, include the difference on 

line 1b and attach an explanation for 

the difference. If there are multiple 

differences, include the explanation 

and amount of each such difference 

on the attachment.

Schedule Q

Use Schedule Q to report the CFC’s 

income, deductions, taxes, and assets 

by CFC income groups for purposes 

of section 960(a) and (d).

44 Instructions for Form 5471 (Rev. 01-2024)
In general, a taxpayer that is 

subject to tax as a domestic 

corporation that is a U.S. shareholder 

(“corporate U.S. shareholder”) of a 

CFC is deemed to pay all or a portion 

of the foreign income taxes paid or 

accrued by the CFC that are properly 

attributable to subpart F income or 

tested income included in gross 

income by the corporate U.S. 

shareholder. See section 960(a) and 

(d). A corporate U.S. shareholder may 

claim a credit for such foreign taxes, 

subject to certain limitations.

Note. If an individual, estate, or trust 

that is a U.S. shareholder of a CFC 

makes an election under section 962 

(“962 electing shareholder”), any 

inclusions under section 951 or 951A 

of the U.S. shareholder will be treated 

as received by a corporate U.S. 

shareholder for purposes of section 

960. See section 962(b) and 

Regulations section 1.962-2(b). As a 

result, these U.S. shareholders may 

also claim a foreign tax credit for 

foreign income taxes deemed paid 

with respect to such inclusions. See 

sections 962(a)(1) and 951A(f)(1)(A).

Note. See also section 1293(f) for 

inclusions with respect to a PFIC.

To calculate the foreign taxes 

deemed paid by the corporate U.S. 

shareholder (including a 962 electing 

shareholder), determine for each of its 

CFCs the income, deductions, and 

taxes that are assigned to each 

separate category of income and 

each income group within each 

separate category. See Regulations 

section 1.960-1(c)(1). The income 

groups include the subpart F income 

groups, the tested income group, and 

the residual income group.

Computer-Generated 

Schedule Q

Expand the Schedule Q if you are 

reporting with respect to more than 

two units. Specifically, if you are 

reporting with respect to more than 

two units, add to pages 1 to 4, as 

appropriate, new lines (3), (4), (5), 

etc., in all necessary locations.

Specific Instructions for 

Schedule Q

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).

Line A. Complete a separate 

Schedule Q for each applicable 

separate category of income. Enter 

the appropriate code from the table 

below for the separate category of 

income with respect to which the 

Schedule Q is being completed.

Codes for Categories of Income

Code Category of Income

PAS Passive category income

901j Section 901(j) income

GEN General category income

If code 901j is entered on line A, 

enter on line 1m, column (i), the 

country code for the sanctioned 

country using the two-letter code 

(from the list at IRS.gov/

CountryCodes).

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 Q using code 

“TOTAL” that aggregates all amounts 

listed for each line and column in all 

other Schedules Q.

Line B. If category code “PAS” is 

entered on line A, a separate 

Schedule Q must be completed for 

each applicable grouping under 

Regulations section 1.904-4(c)(3). 

See Regulations sections 1.954-1(c)

(1)(iii)(B) and 1.904-4(c)(3) through 

(5). Enter on line B the appropriate 

code from the table below for each of 

the following groups under 

Regulations section 1.904-4(c)(3).

Codes for Passive Groups

Code Passive Group

i All passive income received during 

the tax year that is subject to a 

withholding tax of 15% or greater 

must be treated as one item of 

income. See Regulations section 

1.904-4(c)(3)(i). 

ii All passive income received during 

the tax year that is subject to a 

withholding tax of less than 15% (but 

greater than zero) must be treated as 

one item of income. See Regulations 

section 1.904-4(c)(3)(ii).

iii All passive income received during 

the tax year that is subject to no 

withholding tax or other foreign tax 

must be treated as one item of 

income. See Regulations section 

1.904-4(c)(3)(iii).

iv All passive income received during 

the tax year that is subject to no 

withholding tax but is subject to 

foreign tax other than a withholding 

tax must be treated as one item of 

income. See Regulations section 

1.904-4(c)(3)(iv).

Note. The grouping rules of 

Regulations section 1.904-4(c)(3)(i) 

through (iv) apply separately to 

income attributable to each tested unit 

of a CFC. See Regulations section 

1.904-4(c)(4). This is one reason that, 

in the case of a CFC, 

tested-unit-by-tested-unit reporting is 

required with respect to the income 

groups on lines 1a through 1j and 

lines 3 and 4. A foreign corporation 

that is not a CFC but that is a 

noncontrolled 10%-owned foreign 

corporation must report this 

information on a 

foreign-QBU-by-foreign-QBU basis. 

This would be the case, for example, if 

you are completing Schedule Q for 

purposes of attaching it to Schedules 

K-2 and K-3 for purposes of section 

1293(f).

To figure the amounts to enter on 

lines 1a through 1j, on lines (1), (2), 

etc., under each line 1a through 1j, 

enter the name of each unit of the 

foreign corporation (the relevant unit 

being each tested unit in the case of a 

CFC and each QBU in the case of a 

10%-owned foreign corporation), 

including the foreign corporation itself, 

and the information required in each 

column (i) through (xvi) with respect to 

the amount in each subpart F income 

group within each category for each 

unit.

Instructions for Form 5471 (Rev. 01-2024) 45
On lines (1), (2), etc., under line 4, 

enter the name of each unit and enter 

the information required for columns 

(i) through (xvi) for each unit, but do 

not enter amounts excluded from 

subpart F income under the subpart F 

high-tax exception (those amounts are 

reported on lines (1), (2), etc., under 

lines 1a through 1j) or tested income 

under the GILTI high-tax exclusion 

(those amounts are reported on lines 

(1), (2), etc., under line 3).

Line C. If code 901j is entered on line 

A, enter the country code for the 

sanctioned country using the 

two-letter code from the list at 

IRS.gov/CountryCodes.

Line D. Taxpayers are generally 

required to complete a separate 

Schedule Q for foreign source income 

in each separate category and U.S. 

source income in each separate 

category. On a given Schedule Q, 

taxpayers are generally required to 

check the box for either foreign source 

income or U.S. source income, as 

applicable. However, if a taxpayer has 

entered code “TOTAL” on line A and 

the total reported on that Schedule Q 

includes both foreign source income 

and U.S. source income, the taxpayer 

may check both boxes on line D.

Line E. A separate Schedule Q is 

required for foreign oil and gas 

extraction income (FOGEI) and 

foreign oil related income (FORI). If 

the Schedule Q is being prepared to 

report the FOGEI or FORI of a CFC, 

check the box for line E. Indicate the 

amount of FOGEI and FORI in each 

income group.

Line 1. Subpart F Income 

Groups

The separate subpart F income 

groups within each applicable section 

904 category of a CFC are on line 1 

(“subpart F income groups”). See 

Regulations section 1.960-1(d)(2)(ii)

(B). Each single item of foreign base 

company income (as defined in 

Regulations section 1.954-1(c)(1)(iii)) 

is a separate subpart F income group. 

With respect to a CFC, Regulations 

section 1.954-1(c)(1)(iii)(A)(2) 

identifies as a single item of income all 

foreign base company income (other 

than foreign personal holding 

company income) that falls within both 

a single separate category (typically, 

general category income) and a single 

category of foreign base company 

income described in each of 

Regulations section 1.954-1(c)(1)(iii)

(A)(2)(i) through (v). For example, with 

respect to line 1g, there is a single 

subpart F income group within the 

general category that consists of all of 

a CFC’s foreign base company sales 

income.

Use lines 1a through 1f to enter the 

passive category foreign personal 

holding company income of the CFC 

under the appropriate income group 

(dividends, interest, rents, royalties, 

and annuities; net gain from certain 

property transactions; net gain from 

commodities transactions; net foreign 

currency gain; income equivalent to 

interest; and other passive category 

foreign personal holding company 

income of the CFC), each of which is 

also treated as a separate subpart F 

income group under Regulations 

section 1.960-1. See Regulations 

section 1.954-1(c)(1)(iii)(B).

Note. Enter the following passive 

category foreign personal holding 

company income of the CFC on line 1f 

(other foreign personal holding 

company income).

• Income from notional principal 

contracts.

• Payments in lieu of dividends.

• Personal service contracts.

See section 954(c)(1)(F) through (H).

Attach a statement that includes all 

of the information requested by 

Schedule Q, line 1f, delineating the 

amount on line 1f for each of the three 

groups reporting on line 1f. For 

example, if both payments in lieu of 

dividends and income from notional 

principal contracts are included on 

line 1f, on the statement, identify the 

amount related to each of those 

income groups for each column of 

line 1f.

Use lines 1g through 1j to enter the 

foreign base company sales income, 

foreign base company services 

income, full inclusion income, and 

insurance income described in 

section 952(a)(1) of the CFC.

To figure the amounts to enter on 

lines 1a through 1j, on lines (1), (2), 

etc., under each line 1a through 1j, 

enter the name of each QBU of the 

CFC, including the CFC itself, and the 

information required in each column 

(i) through (xvi) with respect to the 

amount in each subpart F income 

group within each category for each 

QBU. On lines 1a through 1j, enter the 

total for each column by adding the 

amounts on lines (1), (2), etc., 

excluding from such total any amounts 

reported with respect to income 

excluded from subpart F income 

under the high-tax exception in 

section 954(b)(4) (“subpart F high-tax 

exception”). These amounts are 

included in the total amount of 

residual income, which is reported on 

line 4. As a result, the amounts 

included on lines 1a through 1j for 

each column may not equal the sum 

of the amounts reported on lines (1), 

(2), etc., for each column because any 

item excluded from subpart F income 

by reason of the high-tax election is 

included in the summation on line 4 

instead of the summations on lines 1a 

through 1j. See the instructions for 

column (xiv) and line 4.

Example. For line 1a(1), gross 

income of $50 is reported in column 

(ii), foreign tax of $20 is reported in 

each of columns (x) and (xii), and the 

checkbox in column (xiv) is checked. 

For line 1a(2), gross income of $100 is 

reported in column (ii), $5 of foreign 

tax is reported in each of columns (x) 

and (xii), and the checkbox in column 

(xiv) is not checked. For line 1a(3), 

gross income of $75 is reported in 

column (ii), $3 of foreign tax is 

reported in each of columns (x) and 

(xii), and the checkbox in column (xiv) 

is not checked. As a result, the 

amount reported in column (ii) on 

line 1a is the sum of the amounts 

reported in column (ii) on lines 1a(2) 

and 1a(3), which is equal to $175 

($100 + $75). The amounts reported 

in columns (x) and (xii) on line 1a are 

the sum of the amounts reported in 

each column on lines 1a(2) and 1a(3), 

which is equal to $8 ($5 + $3). The 

items reported on line 1a(1), gross 

income of $50 and $20 of foreign tax, 

are not included in the totals reported 

on line 1a. These amounts are 

included in the totals for each 

respective column on line 4. As a 

result, the amount reported on line 4, 

column (ii), is increased by $50 and 

the amount reported in column (x) on 

line 4 is increased by $20. No amount 

is reported on line 4, column (xii), 

because foreign income taxes 

attributable to high-tax exception or 

high-tax exclusion income are not 

creditable.

On lines 1k through 1m, enter 

international boycott income 

46 Instructions for Form 5471 (Rev. 01-2024)
described in section 952(a)(3); illegal 

bribes, kickbacks, and other 

payments described in section 952(a)

(4); and income included in a section 

901(j) separate category described in 

section 952(a)(5). See Regulations 

section 1.960-1(d)(2)(ii)(B)(2).

Line 2. Recaptured Subpart F 

Income

Enter income that is recaptured as 

subpart F income in the current year. 

See section 952(c)(2).

Line 3. Tested Income Group

Use line 3 to report tested income in 

the tested income group of the CFC (a 

“tested income group”). See 

Regulations section 1.960-1(d)(2)(ii)

(C). On lines (1), (2), etc., under 

line 3, enter the name of each tested 

unit of the CFC (including the CFC 

tested unit itself) and enter for each 

tested unit the information required in 

columns (ii) through (xvi), based on 

the tentative gross tested income 

attributable to each tested unit 

(without regard to any amounts 

excluded under the GILTI high-tax 

exclusion in Regulations section 

1.951A-2(c)(7) (“GILTI high-tax 

exclusion”)). If the GILTI high-tax 

exclusion applies with respect to any 

tested unit of the CFC, include the 

amounts reported for columns (ii) 

through (xiii) and (xvi) in the total 

reported on line 4. See the 

instructions for line 4. As a result, the 

total amount entered on line 3 may not 

equal the sum of the amounts 

reported in columns (ii) through (xiii) 

and (xvi) on lines 3(1), 3(2), etc., if any 

tested unit’s tentative tested income is 

excluded under the GILTI high-tax 

exclusion (these amounts are 

included in the total amounts reported 

on line 4). In general, tested income 

will be in a single tested income group 

within the general category. Because 

a CFC cannot earn section 951A 

category income or foreign branch 

category income at the CFC level, 

there is no tested income group within 

either section 904 category. With 

respect to the general category tested 

income group of a CFC, GILTI 

inclusion amounts and taxes with 

respect to the tested income group 

will generally be treated as income 

and deemed paid taxes in the section 

951A category. See Regulations 

sections 1.904-4(g) and 1.904-6(e).

Line 4. Residual Income Group

Use line 4 to report the information 

required in columns (i) through (xvi) 

that is in a section 904 category but 

that is not of a type that is included in 

one of the subpart F income groups or 

a tested income group and is 

therefore assigned to the residual 

income group. See Regulations 

section 1.960-1(d)(2)(ii)(D). Enter the 

name of each QBU and enter the 

information required for columns (i) 

through (xvi) for each QBU on lines 

4(1), 4(2), etc., but do not enter 

amounts excluded from subpart F 

income under the subpart F high-tax 

exception (those amounts are 

reported on lines (1), (2), etc., under 

lines 1a through 1j) or tested income 

under the GILTI high-tax exclusion 

(those amounts are reported on lines 

3(1), 3(2), etc.,). Enter the sum of the 

amounts reported on lines 4(1), 4(2), 

etc., plus the sum of amounts 

excluded from subpart F income 

under the subpart F high-tax 

exception and tested income under 

the GILTI high-tax exclusion, in the 

appropriate column on line 4.

Example. For line 1a(1), $100 of 

gross income is reported in column 

(ii), $35 of foreign tax is reported in 

each of columns (x) and (xii), and the 

checkbox in column (xiv) is checked. 

For line 1a(2), $75 of gross income is 

reported in column (ii), $5 of foreign 

tax is reported in each of columns (x) 

and (xii), and the checkbox in column 

(xiv) is not checked. For line 3(1), 

$200 of gross income is reported in 

column (ii), $70 of foreign tax is 

reported in each of columns (x) and 

(xii), and the checkbox in column (xiv) 

is checked. For line 3(2), $150 of 

gross income is reported in column 

(ii), $10 of foreign tax is reported in 

each of columns (x) and (xii), and the 

checkbox in column (xiv) is not 

checked. For line 4(1), $300 of gross 

income is reported in column (ii) and 

$105 of foreign tax is reported in 

column (x). On line 4(1), both columns 

(xii) and (xiv) should be blank in all 

cases. As a result, the amount 

reported on line 4 for column (ii) is the 

sum of the amounts reported in 

column (ii) on lines 1a(1), 3(1), and 

4(1), which equals $600 ($100 + $200 

+ $300). The amount reported in 

column (x) of line 4 is the sum of the 

amounts reported in column (x) on 

lines 1a(1), 3(1), and 4(1), which 

equals $210 ($35 + $70 + $105). No 

amount should be reported in column 

(xii) of line 4 as foreign tax on residual 

amounts are not creditable. The 

amounts reported on line 1a(1) would 

not be included in the total for line 1a, 

but the amount reported on line 1a(2) 

would be included in the total reported 

on line 1a. Similarly, the amounts 

reported on line 3(1) would not be 

included in the total reported on line 3, 

but the amounts reported on line 3(2) 

would be reported in the total reported 

on line 3.

Column (i). Consistent with the 

reporting requirement on Form 1118, 

enter the two-letter code (from the list 

at IRS.gov/CountryCodes) of each 

foreign country and U.S. territory 

within which income is sourced and/or 

to which taxes were paid or accrued.

Column (ii). Enter the amount of 

gross income of the CFC that is 

assigned to each income group within 

each section 904 category.

Columns (iii) through (vii). Expenses. Deductions of the CFC, 

including for current year taxes, are 

allocated and apportioned to the 

income groups to determine net 

income (or loss) in each income group 

and to identify the current year foreign 

income taxes that relate to the income 

in each income group for section 960 

purposes. See Regulations section 

1.960-1(c)(1) and 1.960-1(d)(3)(ii). 

Enter the expenses allocated and 

apportioned to the item of gross 

income reported for each QBU or 

tested unit as well as the aggregate 

amount of such expenses allocated 

and apportioned to each group. See 

the instructions for lines 1 through 4.

Column (viii). Current year tax on 

reattributed income from disregarded payments. This column is used 

to report current year tax imposed 

solely by reason of the receipt of a 

disregarded payment that is a 

reattribution payment. The current 

year tax is allocated and apportioned 

to the income group to which an 

amount of gross income is assigned 

by reason of the receipt of the 

reattribution payment. See 

Regulations sections 1.960-1(d)(3)(ii)

(A) and 1.861-20(d)(3)(v)(B). Report 

current year taxes allocated and 

apportioned to the item of gross 

income reported for each QBU or 

tested unit as well as the aggregate 

amount of such foreign taxes in each 

Instructions for Form 5471 (Rev. 01-2024) 47
group. See the instructions for lines 1 

through 4.

Column (ix). Current year tax on all 

other disregarded payments. This 

column is used to report current tax 

imposed solely by reason of the 

receipt of a disregarded payment 

other than a reattribution payment, 

and which is therefore either a 

remittance or a contribution. See 

Regulations section 1.861-20(d)(3)(v)

(C). Foreign tax imposed by reason of 

a disregarded payment that is a 

remittance is assigned to the income 

groups based upon the assets of the 

payor. See Regulations section 

1.861-20(d)(3)(v)(C)(1). Foreign tax 

imposed by reason of a disregarded 

payment that is a contribution is 

assigned to the residual grouping. 

See Regulations section 1.861-20(d)

(3)(v)(C)(2). Report current year taxes 

allocated and apportioned to the item 

of gross income reported for each 

QBU or tested unit as well as the 

aggregate amount of such foreign 

taxes allocated and apportioned to 

each group. See the instructions for 

lines 1 through 4.

Column (x). Other current year taxes. Any other current year tax is 

allocated and apportioned among the 

section 904 categories under the rules 

of Regulations section 1.904-6(a) 

based on the portion of the foreign 

taxable income (as characterized 

under federal income tax principles) 

that is assigned to a particular section 

904 category. Any other current year 

foreign tax is allocated to the CFC 

income group to which the items of 

foreign gross income are assigned 

under the rules of Regulations section 

1.861-20. Report current year taxes 

allocated and apportioned to the item 

of gross income reported for each 

QBU or tested unit as well as the 

aggregate amount of such foreign 

taxes allocated and apportioned to 

each group. See the instructions for 

lines 1 through 4.

Column (xii). Foreign taxes for 

which credit is allowed (U.S. dollars). The amount reported in column 

(xii) may not be the same as the sum 

of the amounts in columns (viii) 

through (x) if columns (viii) through (x) 

include taxes that are not creditable, 

including taxes paid or accrued to 

sanctioned countries; foreign taxes 

disallowed under section 901(k), (m), 

and (l); and taxes paid or accrued to 

the United States.

Column (xiii). Average asset value. 

Foreign gross income that arises from 

a disregarded payment that is treated 

as a remittance for U.S. tax purposes 

is assigned to an income group by 

reference to the income groups to 

which the assets of the payor taxable 

unit are assigned (or would be 

assigned if the taxable unit were a 

U.S. person) under the rules of 

Regulations section 1.861-9 for 

purposes of apportioning interest 

expense. This rule uses the payor’s 

asset apportionment percentages as 

a proxy for the accumulated earnings 

of the payor taxable unit from which 

the remittance is made. For this 

purpose, the assets of the taxable unit 

making the remittance are determined 

in accordance with the rules of 

Regulations section 1.987-6(b) that 

apply in determining the source and 

separate category of exchange gain 

or loss on a section 987 remittance, 

as modified in two respects. See 

Regulations section 1.861-20(d)(3)(v)

(C)(1). Report asset values for each 

QBU or tested unit as well as the 

aggregate amount of assets in each 

group. See the instructions for lines 1 

through 4.

Column (xiv). High-tax election. 

Check the box in column (xiv) of the 

line corresponding to any item of 

income with respect to which the 

subpart F high-tax exception applies. 

If any amount is excluded under the 

subpart F high-tax exception, do not 

include it in the total for lines 1a 

through 1j, but instead add the 

amount to the total for line 4. See the 

instructions for lines 1 and 4. If a GILTI 

high-tax exclusion under Regulations 

section 1.951A-2(c)(7)(viii) is effective 

with respect to the CFC for the CFC 

inclusion year, check the box in 

column (xiv) that corresponds to the 

item(s) of income to which the 

exception applies. If an amount 

reported on line 3(1), 3(2), etc., is 

excluded from gross income under the 

GILTI high-tax exclusion, do not 

include it in the total amount for line 3. 

Instead, include the amounts in the 

total for line 4. See the instructions for 

lines 3 and 4.

Column (xv). Loss allocation. This 

column is used to report a reduction to 

subpart F income in each applicable 

income group when the foreign 

corporation's subpart F income 

exceeds current year E&P. See 

Regulations sections 1.952-1(c) and 

(e) and 1.951A-6.

Schedule R

Schedule R is used to report basic 

information pertaining to distributions 

from foreign corporations. This 

information is required by sections 

245A, 959, and 986(c).

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 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).

Column (a). Description of distribution. The description should 

include whether the distribution was 

cash or noncash and taxable or 

nontaxable to shareholders. Use code 

sections to properly identify the 

taxable or nontaxable consequences 

of the distribution. For example, 

“taxable cash dividend eligible for a 

dividends received deduction under 

section 245A” or “nontaxable cash 

distribution of PTEP.” Report parts of a 

distribution on separate rows if the 

distribution is partially taxable and 

partially nontaxable, or if the 

distribution is either taxable or 

nontaxable by reason of different 

Code sections. For example, a cash 

distribution of $100 that is a 

nontaxable distribution of PTEP under 

section 959(a) of $30, a taxable 

dividend eligible for a dividends 

received deduction under section 

245A of $15, a taxable dividend under 

section 301(c)(1) of $25, a nontaxable 

distribution applied against basis 

under section 301(c)(2) of $10, and a 

taxable distribution treated as gain 

from the sale or exchange of property 

under section 301(c)(3) of $20 would 

be reported on five rows.

If noncash distributions were made, 

attach a statement and show both the 

tax bases and FMVs.

48 Instructions for Form 5471 (Rev. 01-2024)
Column (b). Date of distribution. 

Enter the month, day, and year using 

the following format: MM-DD-YYYY. 

For example, June 30, 2023, would be 

entered as “06-30-2023.”

Column (c). Amount of distribution 

in foreign corporation's functional 

currency. The amount of a 

distribution is generally the amount of 

any money paid to the shareholder 

plus the FMV of any property 

transferred to the shareholder. 

However, this amount is reduced (but 

not below zero) by the following 

liabilities.

• Any liability of the corporation the 

shareholder assumes in connection 

with the distribution.

• Any liability to which the property is 

subject immediately before, and 

immediately after, the distribution.

Column (d). Amount of E&P distribution in foreign corporation's 

functional currency. A corporate 

distribution to a shareholder is 

generally treated as a distribution of 

E&P. Report distributions from current 

and accumulated E&P. Do not report 

any part of a distribution that is not 

from E&P in column (d).

An actual distribution is first out of 

PTEP, if any, and then out of the 

section 959(c)(3) balance. See 

section 959(c).

If PTEP were distributed, include 

on Form 5471, Schedule I, line 6, any 

foreign currency gain or loss on the 

distribution that is recognized under 

section 986(c). See the instructions 

for Schedule I, Line 6, earlier, for 

details. With respect to foreign 

currency gain or loss on a distribution 

of PTEP, for a corporate U.S. 

shareholder, include the gain or (loss) 

as “Other income” on Form 1120, 

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, or 

on the comparable line of other 

noncorporate tax returns.

Note. E&P described in section 

959(c)(3) is generally E&P of the 

foreign corporation that has not been 

included in gross income of a U.S. 

shareholder under section 951(a)(1) 

or section 951A.

Note. Amounts entered in 

Schedule R (Form 5471), column (d), 

are also included on line 9, column (f), 

of Schedule J (Form 5471) and Part I, 

line 8, of Schedule P (Form 5471), 

both of which are completed by 

separate category of income. If the 

filer is required to complete 

Schedule J (Form 5471) with respect 

to more than one category of income, 

the total of all amounts entered in 

Schedule R (Form 5471), column (d), 

should equal the amount entered on 

line 9, column (f), of the Schedule J 

(Form 5471) that is filed with code 

“TOTAL” entered on line a of that 

Schedule J.

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the 

United States. You are required to give us the information. We need it to ensure that you are complying with these laws 

and to allow us to figure and collect the right amount of tax.

You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act 

unless the form displays a valid OMB control number. Books or records relating to a form or its instructions must be 

retained as long as their contents may become material in the administration of any Internal Revenue law. Generally, tax 

returns and return information are confidential, as required by section 6103.

The time needed to complete and file this form will vary depending on individual circumstances. The estimated burden 

for individual and business taxpayers filing this form is approved under OMB control number 1545-0074 and 1545-0123 

and is included in the estimates shown in the instructions for their individual and business income tax return.

Instructions for Form 5471 (Rev. 01-2024) 49
Principal Business Activity Codes

This list of principal business activities and their 

associated codes is designed to classify an 

enterprise by the type of activity in which it is 

engaged to facilitate the administration of the 

Internal Revenue Code. These principal business 

activity codes are based on the North American 

Industry Classification System.

Using the list of activities and codes below, 

determine from which activity the company derives 

the largest percentage of its “total receipts.” If the 

company purchases raw materials and supplies 

them to a subcontractor to produce the finished 

product, but retains title to the product, the 

company is considered a manufacturer and must 

use one of the manufacturing codes 

(311110-339900).

Enter on page 1, Item 1f, the six-digit code 

selected from the list below. In item 1g, enter a 

brief description of the company's business 

activity.

Agriculture, Forestry, Fishing, 

and Hunting

Crop Production

111100 Oilseed & Grain Farming

111210 Vegetable & Melon Farming 

(including potatoes & yams)

111300 Fruit & Tree Nut Farming

111400 Greenhouse, Nursery, & 

Floriculture Production

111900 Other Crop Farming 

(including tobacco, cotton, 

sugarcane, hay, peanut, 

sugar beet & all other crop 

farming)

Animal Production

112111 Beef Cattle Ranching & 

Farming

112112 Cattle Feedlots

112120 Dairy Cattle & Milk Production

112210 Hog & Pig Farming

112300 Poultry & Egg Production

112400 Sheep & Goat Farming

112510 Aquaculture (including 

shellfish & finfish farms & 

hatcheries)

112900 Other Animal Production

Forestry and Logging

113110 Timber Tract Operations

113210 Forest Nurseries & Gathering 

of Forest Products

113310 Logging

Fishing, Hunting, and Trapping

114110 Fishing

114210 Hunting & Trapping

Support Activities for Agriculture 

and Forestry

115110 Support Activities for Crop 

Production (including cotton 

ginning, soil preparation, 

planting, & cultivating)

115210 Support Activities for Animal 

Production (including farriers)

115310 Support Activities For 

Forestry

Mining

211120 Crude Petroleum Extraction

211130 Natural Gas Extraction

212110 Coal Mining

212200 Metal Ore Mining

212310 Stone Mining & Quarrying

212320 Sand, Gravel, Clay, & 

Ceramic & Refractory 

Minerals Mining & Quarrying

212390 Other Nonmetallic Mineral 

Mining & Quarrying

213110 Support Activities for Mining

Utilities

221100 Electric Power Generation, 

Transmission & Distribution

221210 Natural Gas Distribution

221300 Water, Sewage & Other 

Systems

221500 Combination Gas & Electric

Construction

Construction of Buildings

236110 Residential Building 

Construction

236200 Nonresidential Building 

Construction

Heavy and Civil Engineering 

Construction

237100 Utility System Construction

237210 Land Subdivision

237310 Highway, Street, & Bridge 

Construction

237990 Other Heavy & Civil 

Engineering Construction

Specialty Trade Contractors

238100 Foundation, Structure, & 

Building Exterior Contractors 

(including framing carpentry, 

masonry, glass, roofing, & 

siding)

238210 Electrical Contractors

238220 Plumbing, Heating, & 

Air-Conditioning Contractors

238290 Other Building Equipment 

Contractors

238300 Building Finishing 

Contractors (including 

drywall, insulation, painting, 

wallcovering, flooring, tile, & 

finish carpentry)

238900 Other Specialty Trade 

Contractors (including site 

preparation)

Manufacturing

Food Manufacturing

311110 Animal Food Mfg

311200 Grain & Oilseed Milling

311300 Sugar & Confectionery 

Product Mfg

311400 Fruit & Vegetable Preserving 

& Specialty Food Mfg

311500 Dairy Product Mfg

311610 Animal Slaughtering and 

Processing

311710 Seafood Product Preparation 

& Packaging

311800 Bakeries, Tortilla & Dry Pasta 

Mfg

311900 Other Food Mfg (including 

coffee, tea, flavorings, & 

seasonings)

Beverage and Tobacco Product 

Manufacturing

312110 Soft Drink & Ice Mfg

312120 Breweries

312130 Wineries

312140 Distilleries

312200 Tobacco Manufacturing

Textile Mills and Textile Product 

Mills

313000 Textile Mills

314000 Textile Product Mills

Apparel Manufacturing

315100 Apparel Knitting Mills

315210 Cut & Sew Apparel 

Contractors

315250 Cut & Sew Apparel Mfg 

(except Contractors)

315990 Apparel Accessories & Other 

Apparel Mfg

Leather and Allied Product 

Manufacturing

316110 Leather & Hide Tanning & 

Finishing

316210 Footwear Mfg (including 

rubber & plastics)

316990 Other Leather & Allied 

Product Mfg

Wood Product Manufacturing

321110 Sawmills & Wood 

Preservation

321210 Veneer, Plywood, & 

Engineered Wood Product 

Mfg

321900 Other Wood Product Mfg

Paper Manufacturing

322100 Pulp, Paper, & Paperboard 

Mills

322200 Converted Paper Product Mfg

Printing and Related Support 

Activities

323100 Printing & Related Support 

Activities

Petroleum and Coal Products 

Manufacturing

324110 Petroleum Refineries 

(including integrated)

324120 Asphalt Paving, Roofing, & 

Saturated Materials Mfg

324190 Other Petroleum & Coal 

Products Mfg

Chemical Manufacturing

325100 Basic Chemical Mfg

325200 Resin, Synthetic Rubber, & 

Artificial & Synthetic Fibers & 

Filaments Mfg

325300 Pesticide, Fertilizer, & Other 

Agricultural Chemical Mfg

325410 Pharmaceutical & Medicine 

Mfg

325500 Paint, Coating, & Adhesive 

Mfg

325600 Soap, Cleaning Compound, & 

Toilet Preparation Mfg

325900 Other Chemical Product & 

Preparation Mfg

Plastics and Rubber Products 

Manufacturing

326100 Plastics Product Mfg

326200 Rubber Product Mfg

Nonmetallic Mineral Product 

Manufacturing

327100 Clay Product & Refractory 

Mfg

327210 Glass & Glass Product Mfg

327300 Cement & Concrete Product 

Mfg

327400 Lime & Gypsum Product Mfg

327900 Other Nonmetallic Mineral 

Product Mfg

Primary Metal Manufacturing

331110 Iron & Steel Mills & Ferroalloy 

Mfg

331200 Steel Product Mfg from 

Purchased Steel

331310 Alumina & Aluminum 

Production & Processing

331400 Nonferrous Metal (except 

Aluminum) Production & 

Processing

331500 Foundries

Fabricated Metal Product 

Manufacturing

332110 Forging & Stamping

332210 Cutlery & Handtool Mfg

332300 Architectural & Structural 

Metals Mfg

332400 Boiler, Tank, & Shipping 

Container Mfg

332510 Hardware Mfg

332610 Spring & Wire Product Mfg

332700 Machine Shops; Turned 

Product; & Screw, Nut, & Bolt 

Mfg

332810 Coating, Engraving, Heat 

Treating, & Allied Activities

332900 Other Fabricated Metal 

Product Mfg

Machinery Manufacturing

333100 Agriculture, Construction, & 

Mining Machinery Mfg

333200 Industrial Machinery Mfg

333310 Commercial & Service 

Industry Machinery Mfg

333410 Ventilation, Heating, 

Air-Conditioning, & 

Commercial Refrigeration 

Equipment Mfg

333510 Metalworking Machinery Mfg

333610 Engine, Turbine & Power 

Transmission Equipment Mfg

333900 Other General Purpose 

Machinery Mfg

Computer and Electronic Product 

Manufacturing

334110 Computer & Peripheral 

Equipment Mfg

334200 Communications Equipment 

Mfg

334310 Audio & Video Equipment 

Mfg

334410 Semiconductor & Other 

Electronic Component Mfg

334500 Navigational, Measuring, 

Electromedical, & Control 

Instruments Mfg

334610 Manufacturing & Reproducing 

Magnetic & Optical Media

Electrical Equipment, Appliance, 

and Component Manufacturing

335100 Electric Lighting Equipment 

Mfg

335200 Household Appliance Mfg

335310 Electrical Equipment Mfg

335900 Other Electrical Equipment & 

Component Mfg

Transportation Equipment 

Manufacturing

336100 Motor Vehicle Mfg

336210 Motor Vehicle Body & Trailer 

Mfg

336300 Motor Vehicle Parts Mfg

336410 Aerospace Product & Parts 

Mfg

336510 Railroad Rolling Stock Mfg

336610 Ship & Boat Building

336990 Other Transportation 

Equipment Mfg

Furniture and Related Product 

Manufacturing

337000 Furniture & Related Product 

Manufacturing

Miscellaneous Manufacturing

339110 Medical Equipment & 

Supplies Mfg

339900 Other Miscellaneous 

Manufacturing

Wholesale Trade

Merchant Wholesalers, Durable 

Goods

423100 Motor Vehicle & Motor Vehicle 

Parts & Supplies

423200 Furniture & Home Furnishings

423300 Lumber & Other Construction 

Materials

423400 Professional & Commercial 

Equipment & Supplies

423500 Metal & Mineral (except 

Petroleum)

423600 Household Appliances & 

Electrical & Electronic Goods

423700 Hardware & Plumbing & 

Heating Equipment & 

Supplies

423800 Machinery, Equipment, & 

Supplies

423910 Sporting & Recreational 

Goods & Supplies

423920 Toy & Hobby Goods & 

Supplies

423930 Recyclable Materials

423940 Jewelry, Watch, Precious 

Stone, & Precious Metals

423990 Other Miscellaneous Durable 

Goods

50
Principal Business Activity Codes (Continued)

Merchant Wholesalers, Nondurable 

Goods

424100 Paper & Paper Products

424210 Drugs & Druggists' Sundries

424300 Apparel, Piece Goods, & 

Notions

424400 Grocery & Related Products

424500 Farm Product Raw Materials

424600 Chemical & Allied Products

424700 Petroleum & Petroleum 

Products

424800 Beer, Wine, & Distilled 

Alcoholic Beverages

424910 Farm Supplies

424920 Book, Periodical, & 

Newspapers

424930 Flower, Nursery Stock, & 

Florists' Supplies

424940 Tobacco Products & 

Electronic Cigarettes

424950 Paint, Varnish, & Supplies

424990 Other Miscellaneous 

Nondurable Goods

Wholesale Trade Agents and 

Brokers

425120 Wholesale Trade Agents & 

Brokers

Retail Trade

Motor Vehicle and Parts Dealers

441110 New Car Dealers

441120 Used Car Dealers

441210 Recreational Vehicle Dealers

441222 Boat Dealers

441227 Motorcycle, ATV, & All other 

Motor Vehicle Dealers

441300 Automotive Parts, 

Accessories, & Tire Retailers

Building Material and Garden 

Equipment and Supplies Dealers

444110 Home Centers

444120 Paint & Wallpaper Retailers

444140 Hardware Retailers

444180 Other Building Material 

Dealers

444200 Lawn & Garden Equipment & 

Supplies Retailers

Food and Beverage Retailers

445110 Supermarkets and Other 

Grocery Retailers (except 

Convenience)

445131 Convenience Retailers

445132 Vending Machine Operators

445230 Fruit & Vegetable Retailers

445240 Meat Retailers

445250 Fish & Seafood Retailers

445291 Baked Goods Retailers

445292 Confectionery & Nut Retailers

445298 All Other Specialty Food 

Retialers

445320 Beer, Wine, & Liquor 

Retailers

Furniture and Home Furnishings 

Retailers

449110 Furniture Retailers

449121 Floor Covering Retailers

449122 Window Treatment Retailers

449129 All Other Home Furnishings 

Retailers

Electronics and Appliance Retailers

449210 Electronic & Appliance 

Retailers (including 

computers)

General Merchandise Retailers

455110 Department Stores

455210 Warehouse Clubs, 

Supercenters,& Other 

General Merch. Retailers

Health and Personal Care Retailers

456110 Pharmacies & Drug Retailers

456120 Cosmetics, Beauty Supplies, 

& Perfume Retailers

456130 Optical Goods Retailers

456190 Other Health & Personal Care 

Retailers

Gasoline Stations & Fuel Dealers

457100 Gasoline Stations (including 

convenience stores with gas)

457210 Fuel Dealers (including 

Heating Oil & Liquefied 

Petroleum)

Clothing and Accessories Retailers

458110 Clothing & Clothing 

Accessories Retailers

458210 Shoe Retailers

458310 Jewelry Retaileres

458320 Luggage & Leather Goods 

Retailers

Sporting, Hobby, Book, Musical 

Instrument & Miscellaneous 

Retailers

459110 Sporting Goods Retailers

459120 Hobby, Toy, & Game Retailers

459130 Sewing, Needlework, & Piece 

Goods Retailers

459140 Musical Instrument & 

Supplies Retailers

459210 Book Retailers & News 

Dealers (including 

newsstands)

459310 Florists

459410 Office Supplies & Stationery 

Retailers

459420 Gift, Novelty, & Souvenir 

Retailers

459510 Used Merchandise Retailers

459910 Pet & Pet Supplies Retailers

459920 Art Dealers

459930 Manufactured (Mobile) Home 

Dealers

459990 All Other Miscellaneous 

Retailers (including tobacco, 

candle, & trophy retailers)

Nonstore Retailers

various Nonstore retailers sell all 

types of merchandise using 

such methods as Internet, 

mail-order catalogs, 

interactive television, or direct 

sales. These types of 

Retailers should select the 

PBA associated with their 

primary line of products sold. 

For example, establishments 

primarily selling prescription 

and non-prescription drugs, 

select PBA code 456110 

Pharmacies & Drug Retailers.

Transportation and 

Warehousing

Air, Rail, and Water Transportation

481000 Air Transportation

482110 Rail Transportation

483000 Water Transportation

Truck Transportation

484110 General Freight Trucking, 

Local

484120 General Freight Trucking, 

Long-distance

484200 Specialized Freight Trucking

Transit and Ground Passenger 

Transportation

485110 Urban Transit Systems

485210 Interurban & Rural Bus 

Transportation

485310 Taxi Service

485320 Limousine Service

485410 School & Employee Bus 

Transportation

485510 Charter Bus Industry

485990 Other Transit & Ground 

Passenger Transportation

Pipeline Transportation

486000 Pipeline Transportation

Scenic & Sightseeing 

Transportation

487000 Scenic & Sightseeing 

Transportation

Support Activities for 

Transportation

488100 Support Activities for Air 

Transportation

488210 Support Activities for Rail 

Transportation

488300 Support Activities for Water 

Transportation

488410 Motor Vehicle Towing

488490 Other Support Activities for 

Road Transportation

488510 Freight Transportation 

Arrangement

488990 Other Support Activities for 

Transportation

Couriers and Messengers

492110 Couriers & Express Delivery 

Services

492210 Local Messengers & Local 

Delivery

Warehousing and Storage

493100 Warehousing & Storage 

(except lessors of 

mini-warehouses & 

self-storage units)

Information

Motion Picture and Sound 

Recording Industries

512100 Motion Picture & Video 

Industries (except video 

rental)

512200 Sound Recording Industries

Publishing Industries

513110 Newspaper Publishers

513120 Periodical Publishers

513130 Book Publishers

513140 Directory & Mailing List 

Publishers

513190 Other Publishers

513210 Software Publishers

Broadcasting & Content Providers 

& Telecommunications

516100 Radio & Television 

Broadcasting Stations

516210 Media Streaming, Social 

Networks, & Other Content 

Providers

517000 Telecommunications 

(including Wired, Wireless, 

Satellite, Cable & Other 

Program Distribution, 

Resellers, Agents & Other 

Telecommunications, & 

Internet Service Providers)

Data Processing, Web Search 

Portals, & Other Information 

Services

518210 Computing Infrastructure 

Providers, Data Processing, 

Web Hosting & Related 

Services

519200 Web Search Portals, 

Libraries, Archives, & Other 

Info. Services

Finance and Insurance

Depository Credit Intermediation

522110 Commercial Banking

522130 Credit Unions

522180 Savings Institutions & Other 

Depository Credit 

Intermediation

Nondepository Credit 

Intermediation

522210 Credit Card Issuing

522220 Sales Financing

522291 Consumer Lending

522292 Real Estate Credit (including 

mortgage bankers & 

originators)

522299 Intl, Secondary Market, & 

Other Nondepos. Credit 

Intermediation

Activities Related to Credit 

Intermediation

522300 Activities Related to Credit 

Intermediation (including loan 

brokers, check clearing, & 

money transmitting)

Securities, Commodity Contracts, 

and Other Financial Investments 

and Related Activities

523150 Investment Banking & 

Securities Intermediation

523160 Commodity Contracts 

Intermediation

523210 Securities & Commodity 

Exchanges

523900 Other Financial Investment 

Activities (including portfolio 

management & investment 

advice)

Insurance Carriers and Related 

Activities

524110 Direct Life, Health, & Medical 

Insurance Carriers

524120 Direct Insurance (except Life, 

Health & Medical) Carriers

524210 Insurance Agencies & 

Brokerages

524290 Other Insurance Related 

Activities (including 

third-party administration of 

insurance and pension funds)

Funds, Trusts, and Other Financial 

Vehicles

525100 Insurance & Employee 

Benefit Funds

525910 Open-End Investment Funds 

(Form 1120-RIC, U.S. Income 

Tax Return for Regulated 

Investment Companies)

525920 Trusts, Estates, & Agency 

Accounts

525990 Other Financial Vehicles 

(including mortgage REITs 

and closed-end investment 

funds)“Offices of Bank 

Holding Companies” and 

“Offices of Other Holding 

Companies” are located 

under Management of 

Companies (Holding 

Companies) below.

Real Estate and Rental and 

Leasing

Real Estate

531110 Lessors of Residential 

Buildings & Dwellings 

(including equity REITs)

531120 Lessors of Nonresidential 

Buildings (except 

Mini-warehouses) (including 

equity REITs)

531130 Lessors of Mini-warehouses 

& Self-Storage Units 

(including equity REITs)

531190 Lessors of Other Real Estate 

Property (including equity 

REITs)

531210 Offices of Real Estate Agents 

& Brokers

531310 Real Estate Property 

Managers

531320 Offices of Real Estate 

Appraisers

531390 Other Activities Related to 

Real Estate

Rental and Leasing Services

532100 Automotive Equipment Rental 

& Leasing

532210 Consumer Electronics & 

Appliances Rental

532281 Formal Wear & Costume 

Rental

532282 Video Tape & Disc Rental

532283 Home Health Equipment 

Rental

532284 Recreational Goods Rental

532289 All Other Consumer Goods 

Rental

532310 General Rental Centers

532400 Commercial & Industrial 

Machinery & Equipment 

Rental & Leasing

51
Principal Business Activity Codes (Continued)

Lessors of Nonfinancial Intangible 

Assets (except copyrighted works)

533110 Lessors of Nonfinancial 

Intangible Assets (except 

copyrighted works)

Professional, Scientific, and 

Technical Services

Legal Services

541110 Offices of Lawyers

541190 Other Legal Services

Accounting, Tax Preparation, 

Bookkeeping, and Payroll Services

541211 Offices of Certified Public 

Accountants

541213 Tax Preparation Services

541214 Payroll Services

541219 Other Accounting Services

Architectural, Engineering, and 

Related Services

541310 Architectural Services

541320 Landscape Architecture 

Services

541330 Engineering Services

541340 Drafting Services

541350 Building Inspection Services

541360 Geophysical Surveying & 

Mapping Services

541370 Surveying & Mapping (except 

Geophysical) Services

541380 Testing Laboratories & 

Services

Specialized Design Services

541400 Specialized Design Services 

(including interior, industrial, 

graphic, & fashion design)

Computer Systems Design and 

Related Services

541511 Custom Computer 

Programming Services

541512 Computer Systems Design 

Services

541513 Computer Facilities 

Management Services

541519 Other Computer Related 

Services

Other Professional, Scientific, and 

Technical Services

541600 Management, Scientific, & 

Technical Consulting 

Services

541700 Scientific Research & 

Development Services

541800 Advertising, Public Relations, 

& Related Services

541910 Marketing Research & Public 

Opinion Polling

541920 Photographic Services

541930 Translation & Interpretation 

Services

541940 Veterinary Services

541990 All Other Professional, 

Scientific, & Technical 

Services

Management of Companies 

(Holding Companies)

551111 Offices of Bank Holding 

Companies

551112 Offices of Other Holding 

Companies

Administrative and Support and 

Waste Management and 

Remediation Services

Administrative and Support 

Services

561110 Office Administrative 

Services

561210 Facilities Support Services

561300 Employment Services

561410 Document Preparation 

Services

561420 Telephone Call Centers

561430 Business Service Centers 

(including private mail centers 

& copy shops)

561440 Collection Agencies

561450 Credit Bureaus

561490 Other Business Support 

Services (including 

repossession services, court 

reporting, & stenotype 

services)

561500 Travel Arrangement & 

Reservation Services

561600 Investigation & Security 

Services

561710 Exterminating & Pest Control 

Services

561720 Janitorial Services

561730 Landscaping Services

561740 Carpet & Upholstery Cleaning 

Services

561790 Other Services to Buildings & 

Dwellings

561900 Other Support Services 

(including packaging & 

labeling services, & 

convention & trade show 

organizers)

Waste Management and 

Remediation Services

562000 Waste Management & 

Remediation Services

Educational Services

611000 Educational Services 

(including schools, colleges, 

& universities)

Health Care and Social 

Assistance

Offices of Physicians and Dentists

621111 Offices of Physicians (except 

mental health specialists)

621112 Offices of Physicians, Mental 

Health Specialists

621210 Offices of Dentists

Offices of Other Health 

Practitioners

621310 Offices of Chiropractors

621320 Offices of Optometrists

621330 Offices of Mental Health 

Practitioners (except 

Physicians)

621340 Offices of Physical, 

Occupational & Speech 

Therapists, & Audiologists

621391 Offices of Podiatrists

621399 Offices of All Other 

Miscellaneous Health 

Practitioners

Outpatient Care Centers

621410 Family Planning Centers

621420 Outpatient Mental Health & 

Substance Abuse Centers

621491 HMO Medical Centers

621492 Kidney Dialysis Centers

621493 Freestanding Ambulatory 

Surgical & Emergency 

Centers

621498 All Other Outpatient Care 

Centers

Medical and Diagnostic 

Laboratories

621510 Medical & Diagnostic 

Laboratories

Home Health Care Services

621610 Home Health Care Services

Other Ambulatory Health Care 

Services

621900 Other Ambulatory Health 

Care Services (including 

ambulance services & blood 

& organ banks)

Hospitals

622000 Hospitals

Nursing and Residential Care 

Facilities

623000 Nursing & Residential Care 

Facilities

Social Assistance

624100 Individual & Family Services

624200 Community Food & Housing, 

& Emergency & Other Relief 

Services

624310 Vocational Rehabilitation 

Services

624410 Childcare Services

Arts, Entertainment, and 

Recreation

Performing Arts, Spectator Sports, 

and Related Industries

711100 Performing Arts Companies

711210 Spectator Sports (including 

sports clubs & racetracks)

711300 Promoters of Performing Arts, 

Sports, & Similar Events

711410 Agents & Managers for 

Artists, Athletes, Entertainers, 

& Other Public Figures

711510 Independent Artists, Writers, 

& Performers

Museums, Historical Sites, and 

Similar Institutions

712100 Museums, Historical Sites, & 

Similar Institutions

Amusement, Gambling, and 

Recreation Industries

713100 Amusement Parks & Arcades

713200 Gambling Industries

713900 Other Amusement & 

Recreation Industries 

(including golf courses, skiing 

facilities, marinas, fitness 

centers, & bowling centers)

Accommodation and Food 

Services

Accommodation

721110 Hotels (except Casino Hotels) 

& Motels

721120 Casino Hotels

721191 Bed & Breakfast Inns

721199 All Other Traveler 

Accommodation

721210 RV (Recreational Vehicle) 

Parks & Recreational Camps

721310 Rooming & Boarding Houses, 

Dormitories & Workers’ 

Camps

Food Services and Drinking Places

722300 Special Food Services 

(including food service 

contractors & caterers)

722410 Drinking Places (Alcoholic 

Beverages)

722511 Full Service Restaurants

722513 Limited Service Restaurants

722514 Cafeterias, Grill buffets, & 

Buffets

722515 Snack & Nonalcoholic 

Beverage Bars

Other Services

Repair and Maintenance

811110 Automotive Mechanical & 

Electrical Repair & 

Maintenance

811120 Automotive Body, Paint, 

Interior, & Glass Repair

811190 Other Automotive Repair & 

Maintenance (including oil 

change & lubrication shops & 

car washes)

811210 Electronic & Precision 

Equipment Repair & 

Maintenance

811310 Commercial & Industrial 

Machinery & Equipment 

(except Automotive & 

Electronic) Repair & 

Maintenance

811410 Home & Garden Equipment & 

Appliance Repair & 

Maintenance

811420 Reupholstery & Furniture 

Repair

811430 Footwear & Leather Goods 

Repair

811490 Other Personal & Household 

Goods Repair & Maintenance

Personal and Laundry Services

812111 Barber Shops

812112 Beauty Salons

812113 Nail Salons

812190 Other Personal Care Services 

(including diet & weight 

reducing centers)

812210 Funeral Homes & Funeral 

Services

812220 Cemeteries & Crematories

812310 Coin-Operated Laundries & 

Drycleaners

812320 Drycleaning & Laundry 

Services (except 

Coin-Operated)

812330 Linen & Uniform Supply

812910 Pet Care (except Veterinary) 

Services

812920 Photofinishing

812930 Parking Lots & Garages

812990 All Other Personal Services

Religious, Grantmaking, Civic, 

Professional, and Similar 

Organizations

813000 Religious, Grantmaking, 

Civic, Professional, & Similar 

Organizations (including 

condominium and 

homeowners associations)

Other

999000 Unclassified Establishments 

(unable to classify)

52