Form 5471Information Return of U.S. Persons With Respect to Certain Foreign Corporations
Name of person filing this return
First Name
Last Name
A Identifying number
Address of person filing this return
Street Address
Street Address Line 2
City
State / Province
Postal / Zip Code
Filer’s tax year beginning , 20 , and ending
1
, 20
2
B Category of filer (See instructions. Check applicable box(es)):
1a
1b
1c
2
3
4
5a
5b
5c
C Enter the total percentage of the foreign corporation's voting stock you owned at the end of its annual accounting period
Check box if this is a final Form 5471 for the foreign corporation
D Check box if this is a final Form 5471 for the foreign corporation
E Check if any excepted specified foreign financial assets are reported on this form (see instructions)
F Check the box if this Form 5471 has been completed using “Alternative Information” under Rev. Proc. 2019-40 .
G If the box on line F is checked, enter the corresponding code for "Alternative Information" (see instructions)
H Person(s) on whose behalf this information return is filed:
H Person(s) on whose behalf this information return is filed:
Rows
(1) Name
(2) Address
(3) Identifying number
Shareholder
Officer
Director
1
3
4
5
2
6
7
8
3
9
10
11
4
12
13
14
1a Name and address of foreign corporation
b(1) Employer identification number, if any
b(2) Reference ID number (see instructions)
b(3) Previous reference ID number(s), if any (see instructions)
c Country under whose laws incorporated
d Date of incorporation
-
Month
-
Day
Year
2 digit month, 2 digit day, 4 digit year
Date
e Principal place of business
f Principal business activity code number
g Principal business activity
h Functional currency code
2 Provide the following information for the foreign corporation's accounting period stated above.a Name, address, and identifying number of branch office or agent (if any) in the United States
b If a U.S. income tax return was filed, enter:(i) Taxable income or (loss)
b If a U.S. income tax return was filed, enter:(ii) U.S. income tax paid (after all credits)
c Name and address of foreign corporation's statutory or resident agent in country of incorporation
d Name and address (including corporate department, if applicable) of person (or persons) with custody of the books and records of the foreign corporation, and the location of such books and records, if different
Schedule A Stock of the Foreign Corporation
Rows
(a) Description of each class of stock
(b) Number of shares issued and outstanding (i) Beginning of annual accounting period
(b) Number of shares issued and outstanding (ii) End of annual accounting period
1
2
3
4
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Schedule B Shareholders of Foreign Corporation
Part I U.S. Shareholders of Foreign Corporation (see instructions)
Part I U.S. Shareholders of Foreign Corporation (see instructions)
Rows
(a) Name, address, and identifying number of shareholder
(b) Description of each class of stock held by shareholder. Note: This description should match the corresponding description entered in Schedule A, column (a).
(c) Number of shares held at beginning of annual accounting period
(d) Number of shares held at end of annual accounting period
(e) Pro rata share of subpart F income (enter as a percentage)
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Part II Direct Shareholders of Foreign Corporation (see instructions)
Part II Direct Shareholders of Foreign Corporation (see instructions)
Rows
(a) Name, address, and identifying number of shareholder. Also, include country of incorporation or formation, if applicable.
(b) Description of each class of stock held by shareholder. Note: This description should match the corresponding description entered in Schedule A, column (a).
(c) Number of shares held at beginning of annual accounting period
(d) Number of shares held at end of annual accounting period
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
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Schedule C Income Statement (see instructions)
Important:
Report all information in functional currency in accordance with U.S. generally accepted accounting principles (GAAP). Also, report each amount in U.S. dollars translated from functional currency (using GAAP translation rules). However, if the functional currency is the U.S. dollar, complete only the U.S. Dollars column. See instructions for special rules for dollar approximate separate transactions method (DASTM) corporations.
Schedule c Income Statement (see instructions)
Rows
Functional Currency
U.S. Dollars
1a Gross receipts or sales
1b Returns and allowances
1c Subtract line 1b from line 1a
2 Cost of goods sold
3 Gross profit (subtract line 2 from line 1c)
4 Dividends
5 Interest
6a Gross rents
6b Gross royalties and license fees
7 Net gain or (loss) on sale of capital assets
8a Foreign currency transaction gain or loss—unrealized
8b Foreign currency transaction gain or loss—realized
9 Other income (attach statement)
10 Total income (add lines 3 through 9)
11 Compensation not deducted elsewhere
12a Rents
12b Royalties and license fees
13 Interest
14 Depreciation not deducted elsewhere
15 Depletion
16 Taxes (exclude income tax expense (benefit))
17 Other deductions (attach statement—exclude income tax expense (benefit))
18 Total deductions (add lines 11 through 17)
19 Net income or (loss) before unusual or infrequently occurring items, and income tax expense (benefit) (subtract line 18 from line 10)
20 Unusual or infrequently occurring items
21a Income tax expense (benefit)—current
21b Income tax expense (benefit)—deferred
22 Current year net income or (loss) per books (combine lines 19 through 21b)
23a Foreign currency translation adjustments
23b Other
23c Income tax expense (benefit) related to other comprehensive income
24 Other comprehensive income (loss), net of tax (line 23a plus line 23b less line 23c)
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Schedule F Balance Sheet
Important:
Report all amounts in U.S. dollars prepared and translated in accordance with U.S. GAAP. See instructions for an exception for DASTM corporations.
Schedule F Balance Sheet
Rows
(a) Beginning of annual accounting period
(b) End of annual accounting period
1 Cash
2a Trade notes and accounts receivable
2b Less allowance for bad debts
3 Derivatives
4 Inventories
5 Other current assets (attach statement)
6 Loans to shareholders and other related persons
7 Investment in subsidiaries (attach statement)
8 Other investments (attach statement)
9a Buildings and other depreciable assets
9b Less accumulated depreciation
10a Depletable assets
10b Less accumulated depletion
11 Land (net of any amortization)
12 Intangible assets
12a Goodwill
12b Organization costs
12c Patents, trademarks, and other intangible assets
12d Less accumulated amortization for lines 12a, 12b, and 12c
13 Other assets (attach statement)
14 Total assets
15 Accounts payable
16 Other current liabilities (attach statement)
17 Derivatives
18 Loans from shareholders and other related persons
19 Other liabilities (attach statement)
20 Capital stock
20a Preferred stock
20b Common stock
21 Paid-in or capital surplus (attach reconciliation)
22 Retained earnings
23 Less cost of treasury stock
24 Total liabilities and shareholders’ equity
Liabilities and Shareholders' Equity
Untitled Matrix
Rows
Schedule G Other Information
1 During the tax year, did the foreign corporation own at least a 10% interest, directly or indirectly, in any foreign partnership? If 'Yes,' see the instructions for required statement.
Yes
No
2 During the tax year, did the foreign corporation own an interest in any trust?
Yes
No
3a During the tax year, did the foreign corporation own any foreign entities that were disregarded as separate from their owner under Regulations sections 301.7701-2 and 301.7701-3 or did the foreign corporation own any foreign branches (see instructions)? If 'Yes,' you are generally required to attach Form 8858 for each entity or branch (see instructions).
Yes
No
b During the tax year, did the foreign corporation have one or more qualified business units as defined in section 989(a) with a functional currency different than its owner?
Yes
No
If 'Yes,' enter number of Forms 8964-TRA attached to Form 5471
4a During the tax year, did the filer pay or accrue any base erosion payment under section 59A(d) to the foreign corporation or did the filer have a base erosion tax benefit under section 59A(c)(2) with respect to a base erosion payment made or accrued to the foreign corporation (see instructions)? If 'Yes,' complete lines 4b and 4c.
Yes
No
b Enter the total amount of the base erosion payments
c Enter the total amount of the base erosion tax benefits
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Schedule G Other Information (continued)
Schedule G Other Information (continued)
Rows
Yes
No
During the tax year, did the foreign corporation pay or accrue any interest or royalty for which the deduction is not allowed under section 267A?
Enter the total amount of the disallowed deductions (see instructions)
Is the filer claiming a foreign-derived intangible income (FDII) deduction (under section 250) with respect to any transactions with the foreign corporation?
Enter the amount of gross receipts derived from all sales of general property to the foreign corporation that the filer included in its computation of foreign-derived deduction eligible income (FDDEI)
Enter the amount of gross receipts derived from all sales of intangible property to the foreign corporation that the filer included in its computation of FDDEI
Enter the amount of gross receipts derived from all services provided to the foreign corporation that the filer included in its computation of FDDEI
During the tax year, was the foreign corporation a participant in any cost sharing arrangement? . . . . . . If the answer to question 7 is “Yes,” complete a separate Schedule G-1 for each cost sharing arrangement in which the foreign corporation was a participant during the tax year
After April 25, 2014, did the foreign corporation purchase stock or securities of a shareholder of the foreign corporation for use in a triangular reorganization (within the meaning of Regulations section 1.358-6(b)(2))?
Did the foreign corporation receive any intangible property in a prior year or the current tax year for which the U.S. transferor is required to report a section 367(d) annual income inclusion for the tax year? If “Yes,” go to line 9b.
b. Enter in functional currency the amount of the earnings and profits reduction pursuant to section 367(d)(2)(B) for the tax year.
10. During the tax year, was the foreign corporation an expatriated foreign subsidiary under Regulations section 1.7874-12(a)(9)? If “Yes,” see instructions and attach statement.
11. During the tax year, did the foreign corporation participate in any reportable transaction as defined in Regulations section 1.6011-4? If “Yes,” attach Form(s) 8886 if required by Regulations section 1.6011-4(c)(3)(i)(G).
12. During the tax year, did the foreign corporation pay or accrue any foreign tax that was disqualified for credit under section 901(m)?
13. During the tax year, did the foreign corporation pay or accrue foreign taxes to which section 909 applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended?
14. Did you answer “Yes” to any of the questions in the instructions for line 14? If “Yes,” enter the corresponding code(s) from the instructions and attach statement.
15. Does the foreign corporation have interest expense disallowed under section 163(j)? If “Yes,” enter the amount: $
16. Does the foreign corporation have previously disallowed interest expense under section 163(j) carried forward to the current tax year? If “Yes,” enter the amount: $
17a. Did any extraordinary reduction with respect to a controlling section 245A shareholder occur during the tax year?
17b. If the answer to question 17a is “Yes,” was an election made to close the tax year such that no amount is treated as an extraordinary reduction amount or tiered extraordinary reduction amount?
18a. Did the filer have any loan 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, 100% to 130% of the applicable Federal rate for the relevant term?
18b. Did the filer have any loan 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, 100% to 130% of the applicable Federal rate for the relevant term?
19a. Did the filer issue 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, or did the filer issue or refinance indebtedness owed to the 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, where either the issuance or refinancing of indebtedness, or the distribution or acquisition, occurred during the tax year?
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Schedule G Other Information (continued)
Schedule G Other Information (continued)
Rows
Yes
No
If the answer to question 19a is “Yes,” provide the following. (1) The amount of such transaction(s), distribution(s), and acquisition(s) . . . . . . . $ (2) The amount of such related party indebtedness
(1) The amount of such transaction(s), distribution(s), and acquisition(s)
(2) The amount of such related party indebtedness
During the tax year, did the foreign corporation pay or accrue any Top-up Tax? See instructions
(1) Income Inclusion Rule (IIR) (or similar taxes
(2) Qualified Domestic Minimum Top-up Tax (QDMTT) (or similar taxes)
(3) UTPR (or similar taxes)
During the tax year, was any portion of any increase or decrease to the earnings and profits of the foreign corporation (including previously taxed earnings and profits described in section 959) attributable to a transaction described in section 304?
If the answer to question 21a is “Yes,” provide the following in functional currency, reporting an increase as a positive number and a decrease as a negative number. (1) The change in previously taxed earnings and profits described in section 959(c)(1) and (c)(2)
2) The change in other earnings and profits described in section 959(c)(3)
Schedule I Summary of Shareholder's Income From Foreign Corporation (see instructions)
If item H on page 1 is completed, a separate Schedule I must be filed for each Category 4, 5a, or 5b filer for whom reporting is furnished on this Form 5471. This Schedule I is being completed for:
Name of U.S. shareholder
First Name
Last Name
Identifying number
1a Section 964(e)(4) subpart F dividend income from the sale of stock of a lower-tier foreign corporation (see instructions)
b Section 245A(e)(2) subpart F income from hybrid dividends of tiered corporations (see instructions)
c Subpart F income from tiered extraordinary disposition amounts not eligible for subpart F exception under section 954(c)(6)
d Subpart F income from tiered extraordinary reduction amounts not eligible for subpart F exception under section 954(c)(6)
e Section 954(c) Subpart F Foreign Personal Holding Company Income (enter result from Worksheet A)
f Section 954(d) Subpart F Foreign Base Company Sales Income (enter result from Worksheet A)
g Section 954(e) Subpart F Foreign Base Company Services Income (enter result from Worksheet A)
h Other subpart F income (enter result from Worksheet A)
2 Earnings invested in U.S. property (enter the result from Worksheet B)
3 Reserved for future use
4 Factoring income
See instructions for reporting amounts on lines 1, 2, and 4 on your income tax return.
5a Section 245A eligible dividends (see instructions)
b Extraordinary disposition amounts (see instructions)
c Extraordinary reduction amounts (see instructions)
d Section 245A(e) dividends (see instructions)
e Dividends not reported on line 5a, 5b, 5c, or 5d
6 Exchange gain or (loss) on a distribution of previously taxed earnings and profits
7a Was any income of the foreign corporation blocked?
Yes
No
b Did any such income become unblocked during the tax year (see section 964(b))? If the answer to either question is "Yes," attach an explanation.
Yes
No
8a Did this U.S. shareholder have an extraordinary disposition (ED) account with respect to the foreign corporation at any time during the tax year (see instructions)?
Yes
No
beginning of the CFC year
at the end of the tax year
beginning of the CFC year
at the end of the tax year
9 Enter the sum of the hybrid deduction accounts with respect to stock of the foreign corporation (see instructions)
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