Form 5471 PDF Details

Navigating the complexities of international taxation is a critical task for U.S. persons with interests in foreign corporations, and among the key tools at their disposal is Form 5471, as revised in December 2021. This form, issued by the Department of the Treasury's Internal Revenue Service, serves as an information return for U.S. persons who either control or have a significant interest in certain foreign corporations. The form covers a wide spectrum of information, from the identifying details of the person filing the return, including their name, address, and tax identification number, to comprehensive details about the foreign corporation itself. These details include the corporation’s annual accounting period, its country of incorporation, principal place of business, and the nature of its principal business activity. The form is meticulously structured to capture the organization's financial health and operations, encompassing everything from the shareholders' details, stock descriptions, and the corporation’s income statement to its balance sheet and a diverse range of other pertinent financial information. Moreover, the form delves into transactions that could have implications for U.S. taxation, such as payments that might fall under the Base Erosion and Anti-Abuse Tax (BEAT), disallowed deductions under specific sections of the U.S. tax code, and details of any cost sharing arrangements. The specific categories of filers are meticulously outlined, ensuring that each U.S. person engaging with foreign corporations understands their filing obligations, which are monumental in ensuring compliance with U.S. tax laws and potentially avoiding substantial penalties for non-compliance.

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Form NameForm 5471
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Form 5471

(Rev. December 2021)

Department of the Treasury Internal Revenue Service

Information Return of U.S. Persons With Respect to Certain Foreign Corporations

Go to www.irs.gov/Form5471 for instructions and the latest information.

Information furnished for the foreign corporation’s annual accounting period (tax year required by

section 898) (see instructions) beginning

, 20

, and ending

, 20

OMB No. 1545-0123

Attachment Sequence No. 121

Name of person filing this return

 

 

A Identifying number

 

 

 

 

 

 

 

 

 

Number, street, and room or suite no. (or P.O. box number if mail is not delivered to street address)

B Category of filer (See instructions. Check applicable box(es).):

 

 

 

 

1a

1b

1c

2

3

4

5a

5b

5c

 

 

 

 

 

 

City or town, state, and ZIP code

 

 

C Enter the total percentage of the foreign corporation’s voting

 

 

 

 

stock you owned at the end of its annual accounting period

%

 

 

 

 

 

 

 

 

 

 

 

 

 

Filer’s tax year beginning

, 20

, and ending

 

 

 

, 20

 

 

 

 

 

 

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:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(1) Name

 

(2) Address

(3) Identifying number

(4) Check applicable box(es)

 

 

 

 

 

 

Shareholder

 

Officer

 

Director

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Important: Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in U.S. dollars unless otherwise indicated.

1a Name and address of foreign corporation

b(1) Employer identification number, if any

b(2) Reference ID number (see instructions)

cCountry under whose laws incorporated

d Date of incorporation

e Principal place of business

f Principal business activity code number

g Principal business activity

h Functional currency code

2Provide 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

b If a U.S. income tax return was filed, enter:

 

United States

(i) Taxable income or (loss)

 

(ii) U.S. income tax paid

 

 

 

 

 

 

 

(after all credits)

 

 

 

 

 

 

 

 

c Name and address of foreign corporation’s statutory or resident agent in country

d Name and address (including corporate department, if applicable) of person (or

of incorporation

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

(a)Description of each class of stock

(b)Number of shares issued and outstanding

(i) Beginning of annual

(ii) End of annual

accounting period

accounting period

 

 

For Paperwork Reduction Act Notice, see instructions.

Cat. No. 49958V

Form 5471 (Rev. 12-2021)

Form 5471 (Rev. 12-2021)

Page 2

 

 

Schedule B

Shareholders of Foreign Corporation

 

Part I

U.S. Shareholders of Foreign Corporation (see instructions)

 

(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)

Part II Direct Shareholders of Foreign Corporation (see instructions)

(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

Form 5471 (Rev. 12-2021)

Form 5471 (Rev. 12-2021)

Page 3

 

 

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.

 

 

 

 

 

Functional Currency

U.S. Dollars

 

 

 

 

 

 

 

 

 

1a

Gross receipts or sales

1a

 

 

 

 

b

Returns and allowances

1b

 

 

 

 

c

Subtract line 1b from line 1a

1c

 

 

 

 

2

Cost of goods sold

2

 

 

 

 

3

Gross profit (subtract line 2 from line 1c)

3

 

 

Income

 

4

Dividends

4

 

 

 

5

Interest

5

 

 

 

 

 

 

 

 

6a

Gross rents

6a

 

 

 

 

b

Gross royalties and license fees

6b

 

 

 

 

7

Net gain or (loss) on sale of capital assets

7

 

 

 

 

8a

Foreign currency transaction gain or loss—unrealized

8a

 

 

 

 

b

Foreign currency transaction gain or loss—realized

8b

 

 

 

 

9

Other income (attach statement)

9

 

 

 

 

10

Total income (add lines 3 through 9)

10

 

 

 

 

11

Compensation not deducted elsewhere

11

 

 

 

 

12a

Rents

12a

 

 

Deductions

 

b

Royalties and license fees

12b

 

 

 

13

Interest

13

 

 

 

 

 

 

 

 

14

Depreciation not deducted elsewhere

14

 

 

 

 

15

Depletion

15

 

 

 

 

16

Taxes (exclude income tax expense (benefit))

16

 

 

 

 

17

Other deductions (attach statement—exclude income tax expense (benefit))

17

 

 

 

 

18

Total deductions (add lines 11 through 17)

18

 

 

Income

 

19

Net income or (loss) before unusual or infrequently occurring items, and

 

 

 

 

 

income tax expense (benefit) (subtract line 18 from line 10)

19

 

 

 

 

 

 

 

 

 

20

Unusual or infrequently occurring items

20

 

 

Net

 

21a

Income tax expense (benefit)—current

21a

 

 

 

b

Income tax expense (benefit)—deferred

21b

 

 

 

 

 

 

 

 

22

Current year net income or (loss) per books (combine lines 19 through 21b)

22

 

 

Other Comprehensive

Income

 

line 23c)

24

 

 

 

 

23a

Foreign currency translation adjustments

23a

 

 

 

 

b

Other

23b

 

 

 

 

c

Income tax expense (benefit) related to other comprehensive income .

23c

 

 

 

 

24

Other comprehensive income (loss), net of tax (line 23a plus line 23b less

 

 

 

 

 

 

 

 

 

 

Form 5471 (Rev. 12-2021)

Form 5471 (Rev. 12-2021)

Page 4

 

 

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.

 

 

 

 

(a)

(b)

 

Assets

 

 

Beginning of annual

End of annual

 

 

 

accounting period

accounting period

 

 

 

 

 

 

1

Cash

1

 

 

 

2a

Trade notes and accounts receivable

2a

 

 

 

b

Less allowance for bad debts

2b

(

) (

)

3

Derivatives

3

 

 

 

4

Inventories

4

 

 

 

5

Other current assets (attach statement)

5

 

 

 

6

Loans to shareholders and other related persons

6

 

 

 

7

Investment in subsidiaries (attach statement)

7

 

 

 

8

Other investments (attach statement)

8

 

 

 

9a

Buildings and other depreciable assets

9a

 

 

 

b

Less accumulated depreciation

9b

(

) (

)

10a

Depletable assets

10a

 

 

 

b

Less accumulated depletion

10b (

) (

)

11

Land (net of any amortization)

11

 

 

 

12

Intangible assets:

 

 

 

 

a

Goodwill

12a

 

 

 

b

Organization costs

12b

 

 

 

c

Patents, trademarks, and other intangible assets

12c

 

 

 

d

Less accumulated amortization for lines 12a, 12b, and 12c

12d (

) (

)

13

Other assets (attach statement)

13

 

 

 

14Total assets . . . . . . . . . . . . . . . . . . . . . . . 14

 

Liabilities and Shareholders’ Equity

 

 

 

 

15

Accounts payable

 

15

 

 

 

16

Other current liabilities (attach statement)

 

16

 

 

 

17

Derivatives

 

17

 

 

 

18

Loans from shareholders and other related persons

 

18

 

 

 

19

Other liabilities (attach statement)

 

19

 

 

 

20

Capital stock:

 

 

 

 

a

Preferred stock

 

20a

 

 

 

b

Common stock

 

20b

 

 

 

21

Paid-in or capital surplus (attach reconciliation)

 

21

 

 

 

22

Retained earnings

 

22

 

 

 

23

Less cost of treasury stock

23

(

) (

)

24Total liabilities and shareholders’ equity . . . . . . . . . . . . . . 24

Schedule G Other Information

1During 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.

2

During the tax year, did the foreign corporation own an interest in any trust?

3During 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).

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.

 

 

 

 

b

Enter the total amount of the base erosion payments

$

 

 

c

Enter the total amount of the base erosion tax benefit

$

 

 

5a

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?

 

If “Yes,” complete line 5b.

 

 

 

 

b

Enter the total amount of the disallowed deductions (see instructions)

$

 

 

Yes No

Form 5471 (Rev. 12-2021)

Form 5471 (Rev. 12-2021)

Page 5

 

 

Schedule G

Other Information (continued)

 

6a Is the filer of this Form 5471 claiming a foreign-derived intangible income deduction (under section 250) with respect to any amounts listed on Schedule M? . . . . . . . . . . . . . . . . . . . . . .

If “Yes,” complete lines 6b, 6c, and 6d.

bEnter the amount of gross income derived from sales, leases, exchanges, or other dispositions (but not licenses) from transactions with the foreign corporation that the filer included in its computation of foreign-derived

deduction eligible income (FDDEI) (see instructions) . . . . . . . . . . . . . $

cEnter the amount of gross income derived from a license of property to the foreign corporation that the filer

included in its computation of FDDEI (see instructions) . . . . . . . . . . . . $

dEnter the amount of gross income derived from services provided to the foreign corporation that the filer included

in its computation of FDDEI (see instructions) . . . . . . . . . . . . . . . $

7 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.

8From April 25, 2014, to December 31, 2017, 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))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9a 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.

bEnter in functional currency the amount of the earnings and profits reduction pursuant to section 367(d)

(2)(B) for the tax year . . . . . . . . . . . . . . . . . . . . . . .

10During 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.

11During 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).

12During the tax year, did the foreign corporation pay or accrue any foreign tax that was disqualified for credit under

section 901(m)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

13During 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

 

15Does the foreign corporation have interest expense disallowed under section 163(j) (see instructions)? . . . .

If “Yes,” enter the amount . . . . . . . . . . . . . . . . . . . . . $

16Does the foreign corporation have previously disallowed interest expense under section 163(j) carried forward to

the current tax year (see instructions)? . . . . . . . . . . . . . . . . . . . . . . . . .

If “Yes,” enter the amount . . . . . . . . . . . . . . . . . . . . . $

17a Did any extraordinary reduction with respect to a controlling section 245A shareholder occur during the tax year (see instructions)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

bIf 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 (see instructions)? . . . . .

18Does the reporting corporation have any loan to or from the related party to which the safe-haven rate rules of Regulations section 1.482-2(a)(2)(iii)(B) are applicable, and for which the reporting corporation used a rate of interest within the safe-haven range of Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to 130% of the AFR for the

relevant term)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

19a Did the reporting corporation make at least one distribution or acquisition (as defined by Regulations section 1.385-3) during the period including the tax year and the preceding three tax years, or, during the period beginning 36 months before the date of the respective distribution or acquisition and ending 36 months afterward, did the reporting corporation issue or refinance indebtedness owed to a related party? . . . . . . . . . . . .

bIf the answer to question 19a is “Yes,” provide the following.

(1)

The amount of such distribution(s) and acquisition(s)

$

(2)

The amount of such related party indebtedness

$

Yes No

Form 5471 (Rev. 12-2021)

Form 5471 (Rev. 12-2021)

Page 6

 

 

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

Identifying number

 

 

 

1a Section 964(e)(4) subpart F dividend income from the sale of stock of a lower-tier foreign corporation

 

(see instructions)

1a

b Section 245A(e)(2) subpart F income from hybrid dividends of tiered corporations (see instructions) .

1b

cSubpart F income from tiered extraordinary disposition amounts not eligible for subpart F exception

under section 954(c)(6)

1c

dSubpart F income from tiered extraordinary reduction amounts not eligible for subpart F exception

 

under section 954(c)(6)

1d

e

Section 954(c) Subpart F Foreign Personal Holding Company Income (enter result from Worksheet A)

1e

f

Section 954(d) Subpart F Foreign Base Company Sales Income (enter result from Worksheet A) . .

1f

g

Section 954(e) Subpart F Foreign Base Company Services Income (enter result from Worksheet A) .

1g

h

Other subpart F income (enter result from Worksheet A)

1h

2

Earnings invested in U.S. property (enter the result from Worksheet B)

2

 

 

 

3

Reserved for future use

3

 

 

 

4

Factoring income

4

 

 

 

 

See instructions for reporting amounts on lines 1, 2, and 4 on your income tax return.

 

 

 

 

5a

Section 245A eligible dividends (see instructions)

5a

b

Extraordinary disposition amounts (see instructions)

5b

c

Extraordinary reduction amounts (see instructions)

5c

d

Section 245A(e) dividends (see instructions)

5d

e

Dividends not reported on line 5a, 5b, 5c, or 5d

5e

6

Exchange gain or (loss) on a distribution of previously taxed earnings and profits

6

 

 

 

 

 

 

 

Yes

No

7a

Was any income of the foreign corporation blocked?

 

 

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.

 

 

 

 

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)?

 

 

bIf the answer to question 8a is “Yes,” enter the U.S. shareholder’s ED account balance at the beginning of the CFC year

$

 

and at the end of the tax year $

. Provide an attachment detailing any changes from the

 

 

 

 

 

beginning to the ending balances.

 

 

cEnter the CFCs aggregate ED account balance with respect to all U.S. shareholders at the beginning of the CFC year

$

 

and at the end of the tax year $

. Provide an attachment detailing any changes from the

 

 

 

 

 

beginning to the ending balances.

 

 

9Enter the sum of the hybrid deduction accounts with respect to stock of the foreign corporation (see instructions) $

Form 5471 (Rev. 12-2021)

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Step no. 1 of filling out form 5471

2. After filling in this step, go to the next stage and complete all required details in all these blanks - b Reference ID number see, c Country under whose laws, d Date of incorporation, e Principal place of business, f Principal business activity, g Principal business activity, h Functional currency code, code number, Provide the following information, a Name address and identifying, b If a US income tax return was, United States, i Taxable income or loss, ii US income tax paid, and after all credits.

form 5471 completion process shown (part 2)

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4. Completing number of shareholder, match the corresponding description, entered in Schedule A column a, beginning of annual accounting, d Number of shares held at end of, income enter as, accounting period, a percentage, Part II, Direct Shareholders of Foreign, c Number of shares held at, and d Number of shares held at end of is vital in this next stage - ensure to don't rush and fill in each blank!

Learn how to complete form 5471 stage 4

5. As you near the conclusion of the document, there are actually just a few more things to undertake. Specifically, or formation if applicable, description entered in Schedule A, beginning of annual accounting, d Number of shares held at end of, accounting period, and Form Rev should be done.

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