Instructions for Form 5471

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Text

(Rev. December 2025)

(Use with the December 2025 revision of Form 5471; the December 2024 revision of

separate Schedules H-1 and Q; the December 2023 revision of separate Schedule

G-1; 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

Section references are to the Internal Revenue Code

unless otherwise noted.

allocated under guidance issued under section 70352(c)

(1)(C) of the OBBBA.

Future Developments

Changes to instructions. The Schedule G, line 14

instructions have been updated. Question 22 has been

changed to Question 22a. Question 22b has been added

to identify dividends paid (or deemed paid) by a CFC that

are potentially subject to the Pro Rata Share Transition

Rule.

Schedule I, Worksheet A, line 46 instructions have

been added to reflect the application of the Pro Rata

Share Transition Rule.

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

CFC tax years. Under section 70352 of Public Law

119-21, 139 Stat. 72 (July 4, 2025), commonly known as

the One Big Beautiful Bill Act (OBBBA), for a tax year of a

specified foreign corporation (SFC) beginning after

November 30, 2025, the SFC may not have a tax year

beginning one month earlier than the majority U.S.

shareholder year.

Pro Rata Share Transition Rule. Under a transition rule

provided by section 70354(c)(2) of the OBBBA (the Pro

Rata Share Transition Rule), certain dividends paid (or

deemed paid) by a CFC are not treated as dividends for

purposes of applying section 951(a)(2)(B) (as unamended

by the OBBBA). For guidance on the Pro Rata Share

Transition Rule, see Notice 2025-75, 2025-52 I.R.B. 867,

which taxpayers may rely on as provided in that notice.

Changes to Form 5471. On page 4 of Form 5471,

Schedule G, question 3b is new. If the foreign corporation

has one or more qualified business units (as defined in

section 989(a)) with a functional currency different from its

owner, the filer is required to check the “Yes” box and

enter the number of Forms 8964-TRA attached to Form

5471 in the entry space provided.

On page 6, Schedule G, line 21, is new. If, during the

tax year, any portion of any increase or decrease to the

foreign corporation’s E&P (including previously taxed E&P

described in section 959) was attributable to a transaction

described in section 304, the filer is required to check the

“Yes” box on line 21a and do the following.

• Enter on line 21b(1) the change in PTEP described in

section 959(c)(1) and (c)(2).

• Enter on line 21b(2) the change in other E&P described

in section 959(c)(3).

Changes to separate Schedule E. Schedule E, Part I,

Section 1, column (j) instructions have been updated to

request a statement providing information on taxes

Jan 28, 2026

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

Note: Complete a separate Form 5471 and all applicable

schedules for each applicable foreign corporation.

Instructions for Form 5471 (Rev. 12-2025) Catalog Number 49959G

Department of the Treasury Internal Revenue Service www.irs.gov

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 a 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:

• 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).

Instructions for Form 5471 (Rev. 12-2025)

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.

Instructions for Form 5471 (Rev. 12-2025)

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 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.

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 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).

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

See Regulations section 1.6038-2(d) for exceptions.

See Regulations section 1.6046-1(i) for additional

information.

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 subscriber 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.

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.

Instructions for Form 5471 (Rev. 12-2025)

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 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

Instructions for Form 5471 (Rev. 12-2025)

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 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.

Example. U, a domestic corporation, owns 15% of the

stock of FP, a foreign corporation. FP wholly owns the only

class of stock of D, a domestic corporation, and the only

class of stock of FS, a foreign corporation. FS is a

foreign-controlled CFC because it would not be a CFC

without applying subparagraphs (A), (B), and (C) of

section 318(a)(3) so as to consider D (a U.S. person) as

owning stock that is owned by FP (a foreign person). U is

a U.S. shareholder of FS because it indirectly owns 10%

or more of the stock of FS. U is an unrelated section

958(a) U.S. shareholder, and thus, a Category 5b filer

because it indirectly owns the stock of FS and is not

related to FS. D is a U.S. shareholder of FS because it

constructively owns the stock of FS directly owned by FP

for 50% or more. D is a related constructive U.S.

shareholder, and thus, a Category 5c filer because it does

not directly or indirectly own the stock of FS and is related

to FS. See Category 5c Filer below. D and U cannot file a

joint Form 5471 because a Category 5b filer and Category

5c filer do not have the same filing requirements. See

Multiple filers of same information, later, for additional

information pertaining to the joint filers exception.

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.

Example. FP, a foreign corporation, owns 85% of the

only class of stock of FS, a foreign corporation. U, a

domestic corporation, owns the remaining 15% of the

stock of FS. FP also wholly owns D, a domestic

corporation. FS is a foreign-controlled CFC because it

would not be a CFC without applying subparagraphs (A),

(B), and (C) of section 318(a)(3) so as to consider D (a

U.S. person) as owning stock that is owned by FP (a

foreign person). D is a U.S. shareholder of FS because it

constructively owns 50% or more of the stock of FS

directly owned by FP. D is a related constructive U.S.

shareholder, and thus, a Category 5c filer because it does

not directly or indirectly own the stock of FS and is related

to FS. U is a Category 5a filer.

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

Instructions for Form 5471 (Rev. 12-2025)

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.

Example. U, a domestic corporation, owns 9% of the

stock of FP, a foreign corporation. FP wholly owns the only

class of stock of D, a domestic corporation, and the only

class of stock of FS, a foreign corporation. U is not a U.S.

shareholder because it does not own, directly, indirectly, or

constructively, 10% or more of the stock of FS. Thus, U

has no filing requirement. FS is a foreign-controlled CFC

because it would not be a CFC without applying

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

to consider D (a U.S. person) as owning stock that is

owned by FP (a foreign person). However, D does not

have to file Form 5471 because D, the only U.S.

shareholder of FS, does not own, within the meaning of

section 958(a), stock in FS, a foreign-controlled CFC.

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).

Instructions for Form 5471 (Rev. 12-2025)

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 if the person

has the same filing requirements as, or greater filing

requirements than, the other persons. 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. However, a Category 5b filer and Category 5c filer

cannot file a joint Form 5471 because a Category 5b filer

and Category 5c filer do not have the same filing

requirements. For Category 3 filers, the required

information may only be filed 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 and must also

complete a separate Schedule P and attach it to that

statement if they qualify as a Category 1a, 1b, 4, 5a, or 5b

filer. 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.

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

Filing Requirements for Categories of Filers*

Required Information

Category of Filer

Separate Schedule E

Schedule E-1 (included with separate Schedule E)

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

Schedule G

Separate Schedule G-1

Separate Schedule H

Separate Schedule H-1

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.

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.

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.

Schedule H-1 is required for any U.S. shareholder that is an applicable corporation for corporate alternative minimum tax (CAMT) purposes. See Instructions for

Form 4626.

Instructions for Form 5471 (Rev. 12-2025)

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.

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.

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.

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.

Penalties

Other Reporting Requirements

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

Instructions for Form 5471 (Rev. 12-2025)

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 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

C:DC:TS: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).

Caution: 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.

Instructions for Form 5471 (Rev. 12-2025)

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 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 a tax year of an SFC beginning after November 30,

2025, the SFC may not have a tax year beginning one

month earlier than the majority U.S. shareholder year.

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

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

Enter the filer’s street address. Enter the suite, room, or

other unit number in the box for “Room or suite no.” 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.

Instructions for Form 5471 (Rev. 12-2025)

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. If you file on

behalf of other persons pursuant to the joint filers

exception, only check the category or categories that

apply to you. See Multiple filers of same information,

earlier, for additional information pertaining to the joint

filers exception.

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 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.

Audited separate-entity financial statements of the foreign

01 corporation that are prepared in accordance with U.S. generally

accepted accounting principles (U.S. GAAP).

Audited separate-entity financial statements of the foreign

02 corporation that are prepared on the basis of international financial

reporting standards (IFRS).

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”).

Unaudited separate-entity financial statements of the foreign

corporation that are prepared in accordance with U.S. GAAP.

Unaudited separate-entity financial statements of the foreign

corporation that are prepared on the basis of IFRS.

Unaudited separate-entity financial statements of the foreign

corporation that are prepared on the basis of local-country GAAP.

Separate-entity records used by the foreign corporation for tax

reporting.

Separate-entity records used by the foreign corporation for

08 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 Schedule H-1 must be attached for each

person described in Category 4, 5a, or 5b. For each

Category 4, 5a, or 5b filer that is required to file

Schedule H-1, send a copy of their separate

Schedule H-1 to them to assist them in completing their

tax return.

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.

Caution: 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

Instructions for Form 5471 (Rev. 12-2025)

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 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

Instructions for Form 5471 (Rev. 12-2025)

• 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.

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 standard. These

codes are available at six-group.com/en/productsservices/financial-information/datastandards.html#scrollTo=currency-codes. 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 the person 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 a CFC owned by an FDE,

please include the information of the FDE and the

regarded entity owner. Indicate the regarded entity

owner’s name in parentheses after the FDE’s name. If

there is more than one regarded entity owner, use

separate lines for each, listing each regarded entity owner

in column (a) and reporting the information requested in

columns (b), (c), and (d) for each such regarded entity

owner.

Category 4 filers should list all direct owners of the

CFC. Category 1a, 3, and 5a filers should list all direct

owners of the SFC or CFC through which such filer

indirectly owns the SFC or CFC as described in section

958(a)(2). Category 1c and 5c filers should list all direct

owners of the SFC or CFC from which such filer is

attributed ownership in the SFC or CFC as described in

section 958(b). If the filer is a direct owner, include the

filer’s direct ownership.

Schedule C

Report all information in the foreign corporation’s

functional currency in accordance with U.S. GAAP and

translate using U.S. GAAP translation principles.

If the foreign corporation uses the DASTM under

Regulations section 1.985-3, the functional currency

column should reflect local hyperinflationary currency

amounts computed in accordance with U.S. GAAP. The

U.S. dollar column should reflect such amounts translated

into dollars under U.S. GAAP translation rules. Differences

between this U.S. dollar GAAP column and the U.S. dollar

income or loss figured for tax purposes under Regulations

section 1.985-3(c) should be accounted for on

Schedule H. See Special rules for DASTM, later.

Line 8. Enter foreign currency transaction gain or loss

reported on the income statement. For amounts included

in Other Comprehensive Income (OCI), see Lines 23 and

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

realized gain or loss on line 8b.

Line 16. Enter transactional taxes excluding items

reportable in income tax expense (benefit). Report income

taxes on line 21.

Line 20. The term “unusual or infrequently occurring

items” is defined by U.S. GAAP (see FASB Accounting

Standards Codification (ASC) Topic 220 (Income

Statement), Subtopic 220-20 (Unusual or Infrequently

Occurring Items) or subsequent guidance). If “prior period

adjustments” are not reported separately on the income

statement, do not report such amounts on this line item

(see ASC 250 (Accounting Changes and Error

Corrections) or subsequent guidance).

Line 21. Enter income tax expense (benefit) reported in

accordance with U.S. GAAP (ASC 740 (Income Taxes)).

Income tax expense (benefit) includes current and

deferred income tax expense (benefit). It may also reflect

uncertain tax positions (ASC 740-10) and would not

include taxes paid in respect of uncertain tax positions

recorded in prior years. Enter the current income tax

expense (benefit) on line 21a and deferred income tax

expense (benefit) on line 21b.

Note: If there is an income tax expense amount on

line 21a or 21b, subtract that amount from the line 19 net

income or (loss) amount in arriving at line 22 current-year

net income or (loss) per the books. If there is an income

tax benefit amount on line 21a or 21b, add that amount to

the line 19 net income or (loss) amount in arriving at

line 22 current-year net income or (loss) per the books.

Lines 23 and 24. Enter amounts defined in ASC 220

(Income Statement—Reporting Comprehensive Income).

Line 23a. Enter foreign currency translation

adjustments before the income tax expense (benefit) is

allocated.

Line 23b. Enter other comprehensive income such as

foreign currency gains or losses on certain hedging

transactions, pensions and other post-retirement benefits,

and certain investments available for sale.

Line 23c. Enter the income tax expense (benefit)

allocated to OCI items in the intraperiod allocation.

Important. Differences between the functional currency

amount of income tax expense (benefit) reported on

line 21 and the amount of taxes that reduce or increase

U.S. E&P should be accounted for on line 2g of

Schedule H.

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.

Instructions for Form 5471 (Rev. 12-2025)

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 3a

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

Form 5471.

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)).

Check the “Yes” box if the foreign corporation is the tax

owner of an FDE or FB. The “tax owner” of an FDE is the

person that is treated as owning the assets and liabilities

of the FDE for purposes of U.S. income tax law.

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.

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.

Questions 5a and 5b

IF amounts were reported on...

THEN take those amounts into

account (converting from GAAP to

tax as necessary) when

determining the amounts to be

reported on...

Form 8858, Schedule C

Form 5471, Schedule C.

Form 8858, Schedule F

Form 5471, Schedule F.

Form 8858, Schedule H

Schedule H (Form 5471).

Form 8858, Schedule J

Schedules E and E-1 (Form 5471).

Schedule M (Form 8858)

Schedule M (Form 5471).

If the foreign corporation is the tax owner of an FDE or

FB and you are not a Category 1b, 4, or 5 filer of Form

5471, you must attach the statement described below in

lieu of Form 8858.

Statement in lieu of Form 8858. This statement must

list the name of the FDE or FB, country under whose laws

the FDE or FB was organized, and EIN (if any) of the FDE

or FB.

Question 3b

Check the “Yes” box if, during the tax year, the foreign

corporation had one or more qualified business units as

defined in section 989(a) with a functional currency

different than its owner. If “Yes,” for tax years 2025 and

Instructions for Form 5471 (Rev. 12-2025)

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 10

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.

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 9b

Question 14

Question 9a

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.

Check the “Yes” box on line 14 if you answer “Yes” to any

of the questions in the Schedule G, Line 14 table below. If

“Yes,” enter the corresponding code(s) from the table in

the entry space provided on line 14 of the form. Enter the

applicable corresponding code in capital letters. Enter a

space between each code. Also attach the statement

described in the table below.

Instructions for Form 5471 (Rev. 12-2025)

Form 5471, Schedule G, Line 14

Question

See in the

Schedule I

instructions

If “Yes,”

Code

corresponding description

code to enter

on Schedule G,

line 14

If “Yes,” content of

statement to be

attached to Form

5471

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?

De minimis

Amount excluded by

reason of the de

minimis rule (but

only to the extent not

already included in

amounts below)

During the tax year, did the CFC receive any item of income

In other words, is

that was subject to an effective rate of income tax imposed by a line 13i, 14f, 15f, 16f,

foreign country greater than 90% of the maximum rate of tax

17f, or 18j of

specified in section 11?

Worksheet A greater

than zero?

High tax

Sum of the amounts

from lines 13g, 14d,

15d, 16d, 18d, and

19d

During the tax year, was the CFC’s foreign personal holding

company income, foreign base company sales income, foreign

base company services income, or full inclusion foreign base

company income reduced so as to take into account any

deductions (including taxes)?

In other words, is

line 13b, 13d, 13e,

14b, 15b, or 18f of

Worksheet A greater

than zero?

DED

Deductions

taken into

account

Sum of the amounts

from lines 13b, 13d,

13e, 14b, 15b, and

16b

During the tax year, did the CFC have any gains or losses that

(a) arise out of commodity hedging transactions; (b) are active

business gains or losses from the sale of commodities (and

substantially all of the corporation’s commodities are property

described in section 1221(a)(1), (2), or (8)); or (c) are foreign

currency gains or losses (as defined in section 988(b))

attributable to any section 988 transactions?

In other words, are

any amounts

described in section

954(c)(1)(C)(i), (ii), or

(iii) excluded from

line 1e of Worksheet

AHC

Active/

hedging

commodities

Sum of the excluded

amounts described

in section 954(c)(1)

(C)(i), (ii), and (iii)

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?

Business

needs

Amount excluded

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

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?

Certain

export

financing

Amount excluded

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?

Regular

dealers

Amount excluded

Instructions for Form 5471 (Rev. 12-2025)

Form 5471, Schedule G, Line 14 (continued)

Question

See Worksheet A in

the Schedule I

instructions

If “Yes,”

corresponding

code to enter

on Schedule G,

line 14

Code

description

If “Yes,” content

of statement to be

attached to Form

5471

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?

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

In other words, are

that is a related person, rents or royalties* for the use of, or

any amounts

privilege of using, property within the country under the laws of described in section

which the CFC is created or organized?

954(c)(3)(A)(ii)

*Rents or royalties (other than rents or royalties that reduce the excluded from line 1a

payor’s subpart F income or create or increase a deficit that

of Worksheet A?

may reduce the subpart F income of the payor or another CFC).

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)?

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)?

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 Amount excluded

manufacturing

Instructions for Form 5471 (Rev. 12-2025)

Form 5471, Schedule G, Line 14 (continued)

Question

See Worksheet A in

the Schedule I

instructions

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

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)?

Physical

Amount excluded

manufacturing

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)?

Substantial

contribution

Amount excluded

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?

Branch

Amount excluded

During the tax year, was the CFC an eligible CFC (as defined In other words, are

in section 954(h)(2)) that derived qualified banking or

any amounts

financing income (as defined in section 954(h)(3))?

excluded from lines

1a–1i of Worksheet A

by reason of the

special rule described

in section 954(h)?

Active

financing

Amount excluded

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))?

Active

insurance

Amount excluded

Instructions for Form 5471 (Rev. 12-2025)

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)?

If “Yes,”

Code

corresponding

description

code to enter on

Schedule G,

line 14

If “Yes,” content of

statement to be

attached to Form

5471

Amount excluded

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

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

exceed the earnings and profits of such corporation?

In other words, do

E&P on line(s) 13g,

14d, 15d, 16d, 17d,

and/or 18h of

Worksheet A exceed

amounts on line(s)

13f, 14c, 15c, 16c,

17c, and/or 18g,

respectively?

Earnings &

profits

limitation

Excess of line(s) 13g,

14d, 15d, 16d, 17d,

and/or 18h (as

applicable), over line(s)

13f, 14c, 15c, 16c, 17c,

and/or 18g (as

applicable)

22a In determining the pro rata share of subpart F income or

tested items of the U.S. person filing this return, was the

amount of distributions by the CFC during the tax year and

described in section 951(a)(2)(B) greater than zero?

In other words, is

line 46 of Worksheet

A greater than zero?

PRS

Pro rata share The amounts from lines

46 and 47 of

Worksheet A

22b Was any amount of the dividends paid (or deemed paid)

during the tax year by the CFC (with respect to the stock

owned by the U.S. person filing this return) described in

section 70354(c)(2)(A) of the OBBBA and also treated by

the U.S. person filing this return as a dividend for purposes

of applying section 951(a)(2)(B) (as unamended by the

OBBBA)? See Notice 2025-75.

In other words, does

the amount on

line 46 of Worksheet

A include the

amount of any

dividends paid (or

deemed paid) by the

CFC that are also

described in section

70354(c)(2)(A) of

the OBBBA? See

Notice 2025-75.

PRST

Pro Rata

The amount of each

dividend paid (or

Transition Rule deemed paid) by the

CFC (with respect to

the stock owned by the

U.S. person filing this

return) that is

described in section

70354(c)(2)(A) of the

OBBBA but that was

nonetheless treated as

a dividend by the U.S.

person filing this return

for purposes of

applying section 951(a)

(2)(B). See Notice

2025-75. Include a

statement describing

why the U.S. person

filing this return is

entitled to treat this

amount as a dividend

for purposes of section

951(a)(2)(B) after

application of the Pro

Rata Share Transition

Rule. This statement

must describe how the

U.S. person filing this

return determined that

the dividend increased

the taxable income of a

U.S. person subject to

federal income tax

within the meaning of

section 70354(c)(2)(B)

of the OBBBA. See

Notice 2025-75.

Other

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)?

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.

Amount excluded,

reduction amount, or

other amount not

reported or reportable

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.

Instructions for Form 5471 (Rev. 12-2025)

Question 16

For the foreign corporation’s annual accounting period

with respect to which reporting is being made on this Form

5471, if the foreign corporation is required to file a U.S.

income tax return (for example, Form 1120-F), check the

“Yes” box if the foreign corporation has previously

disallowed interest expense under section 163(j) carried

forward to the current tax year. If “Yes,” enter the amount

from the prior-year Form 8990, line 31.

Question 17a

Check the “Yes” box on line 17a if there was an

extraordinary reduction with respect to any controlling

section 245A shareholder of the foreign corporation, as

defined in Regulations section 1.245A-5(i)(2), during the

tax year of the foreign corporation. See Regulations

section 1.245A-5(e)(2)(i) for the definition of extraordinary

reduction.

Question 17b

If the answer to the question on line 17a was “Yes,”

complete the question on line 17b. Check the “Yes” box on

line 17b if any controlling section 245A shareholder (as

defined in Regulations section 1.245A-5(i)(2)) made an

election to close the tax year of the foreign corporation

such that no amount is treated as an extraordinary

reduction amount or tiered extraordinary reduction amount

as to any U.S. shareholder of the foreign corporation. See

Regulations section 1.245A-5(e)(3)(i) for further guidance

regarding the election to close the tax year. If the “Yes” box

on line 17b has been checked and the U.S. shareholder

filing the Form 5471 is a controlling section 245A

shareholder of the foreign corporation, the U.S.

shareholder filing this Form 5471 must attach an Elective

Section 245A Year-Closing Statement pursuant to

Regulations section 1.245A-5(e)(3)(i)(C) containing the

information required under Regulations section

1.245A-5(e)(3)(i)(D).

Question 18a

Check the “Yes” box if during the tax year the filer had any

loans to or from the foreign corporation to which the

safe-haven rate rules of Regulations section 1.482-2(a)(2)

(iii)(B) are applicable, and for which the filer used a rate of

interest within the relevant safe-haven range of

Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to

130% of the applicable federal rate for the relevant term).

Question 18b

Check the “Yes” box if during the tax year the filer had any

loans to or from the foreign corporation to which the

safe-haven rate rules of Regulations section 1.482-2(a)(2)

(iii)(B) are applicable, and for which the filer used a rate of

interest outside the relevant safe-haven range of

Regulations section 1.482-2(a)(2)(iii)(B)(1) (100% to

130% of the applicable federal rate for the relevant term).

Questions 19a and 19b

Complete lines 19a and 19b only if the filer is a domestic

corporation. In completing these lines, do not account for

debt instruments that were issued, or distributions or

acquisitions that occurred, before April 5, 2016. See

Regulations section 1.385-3(g)(3) and 1.385-3(b)(3)(viii).

Instructions for Form 5471 (Rev. 12-2025)

Question 19a

Check the “Yes” box if the filer issued a covered debt

instrument in any of the transactions described in

Regulations section 1.385-3(b)(2) with respect to the

foreign corporation during the tax year. Also check the

“Yes” box if the filer issued or refinanced indebtedness

owed to a foreign corporation during the 36 months before

or after the date of a distribution or acquisition described

in Regulations section 1.385-3(b)(3)(i) made by the filer,

and either the issuance or refinance of indebtedness, or

the distribution or acquisition, occurred during the tax

year. Otherwise, check “No.” Apply Regulations section

1.385-3(b)(3)(iii)(E) to determine when a debt instrument

is treated as issued for purposes of Regulations section

1.385-3(b)(3)(iii). Apply Regulations section 1.385-3(f) in

the case of a controlled partnership within the meaning of

Regulations section 1.385-1(c)(1).

Debt that the filer treats as stock pursuant to

Regulations section 1.385-3 should still be included when

completing line 19a.

Question 19b

Provide the total amount of the transactions described in

Regulations section 1.385-3(b)(2) (as measured by the

fair market value (FMV) of the distribution or, as the case

may be, the property exchanged for the debt instrument),

and of the distributions and/or acquisitions described in

Regulations section 1.385-3(b)(3)(i) (as measured by the

FMV of the property distributed and/or acquired).

Provide the total amount (as measured by issue price in

the case of an instrument treated as stock upon issuance,

or adjusted issue price in the case of an instrument

deemed exchanged for stock) of the debt instrument

issuances addressed by line 19a. See Regulations

sections 1.385-1(d)(1) and 1.385-3(d). The adjusted issue

price of a debt instrument is the issue price increased by

the amount of original issue discount previously includible

in gross income of any holder and decreased by

payments other than payments of stated interest. See

section 1272(a)(4) and Regulations section 1.1275-1(b)

(1).

Questions 20a and 20b

Certain jurisdictions have enacted legislation to implement

the GloBE Model Rules for the Qualified Domestic

Minimum Top-up Tax (QDMTT), Income Inclusion Rule

(IIR), and UTPR. See Org. for Econ. Coop. & Dev.

[OECD], Tax Challenges Arising From the Digitalization of

the Economy — Global Anti-Base Erosion Model Rules

(Pillar Two) (Dec. 14, 2021), at DOI.org/

10.1787/782bac33-en. Under these rules, if the Effective

Tax Rate (ETR) for a jurisdiction is below 15%, Top-up Tax

may be imposed. The amount of Top-up Tax is determined

by multiplying the Top-up Tax Percentage (the positive

excess of 15% over the ETR in the jurisdiction) by the

Excess Profits (the positive amount of the Net GloBE

Income in such jurisdiction that exceeds a

Substance-based Income Exclusion). The Top-up Tax is

collected under the QDMTT, IIR, and/or UTPR.

If the foreign corporation paid or accrued any Top-up

Tax during the tax year, check the "Yes" box for Question

20a on page 6 of the form and enter the amount of

QDMTT, IIR, and/or UTPR (or similar tax) paid or accrued

during the tax year in the space provided on lines 20b(1),

20b(2), and 20b(3).

For more information, see Notice 2023-80, I.R.B.

2023-52 1583, available at IRS.gov/IRB/

2023-52_IRB#NOT-2023-80.

Questions 21a and 21b

If, during the tax year, any portion of any increase or

decrease to the foreign corporation’s E&P (including

previously taxed E&P described in section 959) was

attributable to a transaction described in section 304, the

filer is required to check the “Yes” box on line 21a and do

the following.

• Enter on line 21b(1) the change in PTEP described in

section 959(c)(1) and (c)(2).

• Enter on line 21b(2) the change in other E&P described

in section 959(c)(3).

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

functional currency.

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

Schedule I

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.

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.

Lines 1e Through 1h

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.

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

Enter on lines 1e through 1h the amounts from Worksheet

A, lines 53, 57, 61, and 67, respectively. However,

corporate U.S. shareholders should report on line 1e the

amount from Worksheet A, line 53, less the amount, if any,

reported on line 1a.

Use Worksheet A to compute the U.S. shareholder’s

pro rata share of subpart F income of the CFC, which is

reportable on lines 1e through 1h. Do not include any

income includible on Form 5471, Schedule I, lines 1a

through 1d, or any income includible under section 951A

(Schedule I-1 is used to provide information relating to

section 951A). Subpart F income reportable on lines 1e

through 1h includes the following.

• Adjusted net foreign base company income (Worksheet

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

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

• Adjusted net related person insurance income

(Worksheet A, line 17).

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

• Illegal bribes, kickbacks, and other payments

(Worksheet A, line 20).

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

line 21).

Important. If the subpart F income of a CFC for any tax

year was reduced because of the current E&P limitation,

any excess of the E&P of the CFC for any subsequent tax

year over the subpart F income of the CFC for the tax year

must be recharacterized as subpart F income. As a result,

if the foreign corporation has E&P for the tax period

covered by this return that is subject to recapture as a

result of a prior-year E&P limitation, add the U.S.

shareholder’s pro rata share of such recapture amount to

the result from Worksheet A, line 67, and include the

Instructions for Form 5471 (Rev. 12-2025)

combined amount on line 1h (Other subpart F income).

See Line 37. Current E&P limitation, later, for a discussion

of the current-year E&P limitation. See also Regulations

section 1.952-1(f) for further guidance on

recharacterization of E&P as subpart F income.

Line 2

Report on line 2 the section 956 amount with respect to

the U.S. shareholder. See Worksheet B, line 19.

Line 3

Reserved for future use.

Line 4

Enter the U.S. shareholder’s pro rata share of the factoring

income (as defined in section 864(d)(1)) if no subpart F

income is reported on line 1a of Worksheet A because of

the operation of the de minimis rule (see lines 1a and 10

of Worksheet A and the related instructions under Line 1a

and Line 10. De minimis rule, later).

Reporting Amounts on Lines 1 Through 4 on Your

Income Tax Return

For a corporate shareholder, enter the result from Form

5471, Schedule I, line 1a on Form 1120, Schedule C,

line 16a; enter the result from Form 5471, Schedule I,

line 1b on Form 1120, Schedule C, line 16b; and enter the

results from remaining Form 5471, Schedule I, lines 1c

through 1h, 2, and 4 on Form 1120, Schedule C, line 16c;

or on the comparable line of other corporate tax returns.

For a noncorporate U.S. shareholder, enter the results on

Schedule 1 (Form 1040), line 8n (Other income–section

951(a) inclusion), or on the comparable line of other

noncorporate tax returns.

Line 5a

Enter the amount of dividends received by the

shareholder from the foreign corporation that is eligible for

a deduction under section 245A. This amount does not

include the amount of dividends that are not eligible for a

deduction under section 245A and are instead entered on

lines 5b, 5c, and 5d. See section 245A for guidance on

computing the amount of a dividend eligible for a

deduction.

Note: The corporate U.S. shareholder should include the

Form 5471, Schedule I, line 5a amount in column (a) of

Form 1120, Schedule C, line 13, or on the comparable line

of other corporate income tax returns. In doing so, the

corporate U.S. shareholder must determine whether it

meets the statutory and regulatory requirements for the

section 245A dividends-received deduction.

Line 5b

Enter the amount of the dividends received by the

shareholder from the foreign corporation that is an

extraordinary disposition amount. See Regulations

section 1.245A-5(c) for rules for calculating an

extraordinary disposition amount.

Note: The corporate U.S. shareholder should include the

Form 5471, Schedule I, line 5b amount in column (a) of

Instructions for Form 5471 (Rev. 12-2025)

Form 1120, Schedule C, line 14, or on the comparable line

of other corporate income tax returns.

Line 5c

Enter the amount of the dividends received by the

shareholder from the foreign corporation that is an

extraordinary reduction amount. See Regulations section

1.245A-5(e) for rules for calculating an extraordinary

reduction amount.

Note: The corporate U.S. shareholder should include the

Form 5471, Schedule I, line 5c amount in column (a) of

Form 1120, Schedule C, line 14, or on the comparable line

of other corporate income tax returns.

Line 5d

Enter the amount of hybrid dividends received by the U.S.

shareholder from the foreign corporation. In general, in the

case of a domestic corporation that is a U.S. shareholder

with respect to a CFC, a dividend received by the

domestic corporation from the CFC is a hybrid dividend to

the extent of the sum of the U.S. shareholder’s hybrd

deduction accounts with respect to shares of stock of the

CFC. See section 245A(e) and Regulations section

1.245A(e)-1(b) for additional information about hybrid

dividends.

Note: The corporate U.S. shareholder should include the

Form 5471, Schedule I, line 5d amount in column (a) of

Form 1120, Schedule C, line 14, or on the comparable line

of other corporate income tax returns.

Line 5e

Enter on line 5e dividends not reported on line 5a, 5b, 5c,

or 5d.

Note: The corporate U.S. shareholder should include the

Form 5471, Schedule I, line 5e amount on Form 1120,

Schedule C, line 14, column (a), or on the comparable line

of other corporate income tax returns.

Line 6

If previously taxed E&P (PTEP) were distributed, enter the

amount of foreign currency gain or (loss) recognized on

the distribution, computed under section 986(c). See

Notice 88-71, 1988-2 C.B. 374, for rules for computing

section 986(c) gain or (loss), and Regulations section

1.986(c)-1(a) and (b) for rules for computing section

986(c) gain or (loss) recognized with respect to

distributions of PTEP within the reclassified section 965(a)

PTEP group and the section 965(a) PTEP group. Do not

include any foreign currency gain or loss with respect to

PTEP within the reclassified section 965(b) PTEP group or

the section 965(b) PTEP group. See Regulations section

1.986(c)-1(c).

For a corporate U.S. shareholder, include the gain or

(loss) as “Other income” on Form 1120, page 1, line 10, or

on the comparable line of other corporate tax returns. For

a noncorporate U.S. shareholder, include the result as

“Other income” on Schedule 1 (Form 1040), line 8z (Other

income), or on the comparable line of other noncorporate

tax returns.

Line 8a

Check the “Yes” box on line 8a if the U.S. shareholder

completing this form had an extraordinary disposition

account with respect to the foreign corporation having a

balance greater than zero at any time during the tax year

of the foreign corporation. See Regulations section

1.245A-5(c) for rules regarding an extraordinary

disposition account.

Line 8b

If “Yes” is checked on line 8a, enter on line 8b the U.S.

shareholder’s extraordinary disposition account balance

at the beginning and end of the foreign corporation’s tax

year. Attach a statement detailing any differences

between the starting and ending balance of the

extraordinary disposition account reported on line 8b.

Line 8c

Enter on line 8c the CFC’s total extraordinary disposition

account balance with respect to all U.S shareholders of

the CFC at the beginning of the CFC year and at the end

of the CFC tax year. Attach a statement detailing any

differences between the starting and ending balances

reported on line 8c.

Line 9

If the foreign corporation is a CFC and the filer is a

domestic corporation, enter on line 9 the sum of the hybrid

deduction accounts with respect to each share of stock of

the CFC that the domestic corporation owns directly or

indirectly (within the meaning of section 958(a)(2), and

determined by treating a domestic partnership as foreign).

The reported amount should reflect the balance of the

hybrid deduction accounts as of the close of the tax year

of the CFC, and after all adjustments to the hybrid

deduction accounts for the tax year (for example, to reflect

hybrid deductions of the CFC or hybrid dividends paid by

the CFC). For example, if the CFC is an upper-tier CFC all

the stock of which is owned by the filer, then line 9 must

reflect the sum of the filer’s hybrid deduction accounts with

respect to shares of stock of the upper-tier CFC; if instead

the CFC is a lower-tier CFC all the stock of which is owned

by the filer through an upper-tier CFC, then line 9 must

reflect the sum of the upper-tier CFC’s hybrid deduction

accounts with respect to shares of stock of the lower-tier

CFC.

A hybrid deduction account with respect to a share of

stock of a CFC reflects the amount of hybrid deductions of

the CFC that has been allocated to the share. In general, a

hybrid deduction is a deduction or other tax benefit

allowed to the CFC (or a related person) under a foreign

tax law for an amount paid, accrued, or distributed with

respect to an instrument of the CFC that is stock for U.S.

tax purposes. A hybrid deduction includes a deduction

allowed to the CFC under a foreign tax law with respect to

equity (such as a notional interest deduction). See

Regulations section 1.245A(e)-1(d) for additional

information about hybrid deduction accounts.

A domestic corporation that is a U.S. shareholder with

respect to a CFC must maintain a hybrid deduction

account with respect to each share of stock of the CFC

that the domestic corporation owns directly or indirectly

through a partnership, trust, or estate. In addition, certain

upper-tier CFCs must maintain a hybrid deduction

account with respect to each share of the stock of a

lower-tier CFC that the upper-tier CFC owns directly or

indirectly through a partnership, trust, or estate. See

Regulations section 1.245A(e)-1(d) for more on

maintenance of hybrid deduction accounts.

Instructions for Form 5471 (Rev. 12-2025)

Worksheet A

Summary of U.S. Shareholders Pro Rata Share of Subpart F Income of a CFC (See Worksheet A Instructions, later.) Enter the amounts on

lines 1a through 51, 55, 59, and 67 in functional currency.

Gross foreign personal holding company income (determined after the application of section

952(b)):

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

in sections 954(c)(2), (3), and (6)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

b Income equivalent to interest (section 954(c)(1)(E)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

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

............

...............

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

f Excess of gains over losses from certain property transactions (section 954(c)(1)(B)) . . . . . . . . . . . .

g Payments in lieu of dividends (section 954(c)(1)(G)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

Gross foreign base company sales income (determined after the application of section 952(b)) (see section

954(d)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Gross foreign base company services income (determined after the application of section 952(b)) (see section

954(e)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Gross foreign base company income. Add lines 2 through 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Gross insurance income (determined after the application of section 952(b)) (see sections 953 and 954 (b)(3)(C) and the

instructions for lines 16 and 17) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

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

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

10 If line 7 is less than line 8 and less than $1 million, enter -0- on this line and skip lines 11 through 18 . . . . . . . . . . . . . . .

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

12 Total adjusted gross foreign base company income and insurance income (enter the greater of line 7 or line 11). See

instructions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

13 Adjusted net foreign personal holding company income:

a Enter amount from line 2

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13a

b Expenses definitely related to amount on line 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13b

c Subtract line 13b from line 13a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13c

d Related person interest expense (see section 954(b)(5)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13d

e Other expenses allocated and apportioned to the amount on line 2 under section 954(b)(5)

. . . . . . . 13e

f Net foreign personal holding company income. Subtract the sum of lines 13d and 13e from

line 13c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13f

g Amount of line 13f excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13g

h Subtract line 13g from line 13f

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13h

i Amount of line 13h excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .

13i

j Adjusted net foreign personal holding company income. Subtract line 13i from line 13h . . . . . . . . . . . . . . . . . . . . . . . . .

13j

14 Adjusted net foreign base company sales income:

a Enter amount from line 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14a

b Expenses allocated and apportioned to the amount on line 3 under section 954(b)(5) . . . . . . . . . . . . 14b

c Net foreign base company sales income. Subtract line 14b from line 14a . . . . . . . . . . . . . . . . . . . . . 14c

d Amount of line 14c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14d

e Subtract line 14d from line 14c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14e

f Amount of line 14e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 14f

g Adjusted net foreign base company sales income. Subtract line 14f from line 14e . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

14g

15 Adjusted net foreign base company services income:

a Enter amount from line 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15a

b Expenses allocated and apportioned to the amount on line 4 under section 954(b)(5) . . . . . . . . . . . . 15b

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

d Amount of line 15c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15d

e Subtract line 15d from line 15c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15e

f Amount of line 15e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . . 15f

g Adjusted net foreign base company services income. Subtract line 15f from line 15e . . . . . . . . . . . . . . . . . . . . . . . . . . .

Instructions for Form 5471

15g

Worksheet A (continued)

Worksheet A (continued) (See instructions.)

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

a Enter amount from line 6 (other than related person insurance income) . . . . . . . . . . . . . . . . . . . . . . 16a

b Expenses allocated and apportioned to the amount on line 16a under section 953 . . . . . . . . . . . . . . 16b

c Net insurance income. Subtract line 16b from line 16a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16c

d Amount of line 16c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16d

e Subtract line 16d from line 16c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16e

f Amount of line 16e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .

16f

g Adjusted net insurance income. Subtract line 16f from line 16e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16g

17 Adjusted net related person insurance income:

a Enter amount from line 6 that is related person insurance income . . . . . . . . . . . . . . . . . . . . . . . . . . . 17a

b Expenses allocated and apportioned to the amount on line 17a under section 953 . . . . . . . . . . . . . . 17b

c Net related person insurance income. Subtract line 17b from line 17a . . . . . . . . . . . . . . . . . . . . . . . . 17c

d Amount of line 17c excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17d

e Subtract line 17d from line 17c . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17e

f Amount of line 17e excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .

17f

g Adjusted net related person insurance income. Subtract line 17f from line 17e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

17g

18 Adjusted net full inclusion foreign base company income:

a Enter the excess, if any, of line 12 over line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18a

b Enter amount from line 7 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18b

c Multiply line 18b by 90% (0.9) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18c

d Amount of lines 13a, 14a, 15a, 16a, and 17a attributable to items excluded pursuant to the high-tax

exception of section 954(b)(4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18d

e If line 18d is more than line 18c, enter zero here and skip the remainder of line 18. If line 18d is less

than or equal to line 18c, enter the amount on line 18a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18e

f Expenses allocated and apportioned to the amount on line 18e under section 954(b)(5) . . . . . . . . . .

g Net full inclusion foreign base company income. Subtract line 18f from line 18e

18f

. . . . . . . . . . . . . . . . 18g

h Amount of line 18g excluded pursuant to section 952(c) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18h

i Subtract line 18h from line 18g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

18i

j Amount of line 18i excluded pursuant to the high-tax exception of section 954(b)(4) . . . . . . . . . . . . .

18j

k Adjusted net full inclusion foreign base company income. Subtract line 18j from line 18i

........................

18k

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

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

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

22 Subpart F income before application of section 959(b) and section 961(c). Add lines 13j, 14g, 15g, 16g, 17g, 18k, and 19

through 21 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

23 Exclusions under section 959(b) and section 961(c) basis that apply to line 13j amount . . . . . . . . . . .

24 Section 954(c) subpart F Foreign Personal Holding Company Income. Subtract line 23 from line 13j . . . . . . . . . . .

25 Exclusions under section 959(b) that apply to line 14g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

26 Section 954(d) subpart F Foreign Base Company Sales Income. Subtract line 25 from line 14g . . . . . . . . . . . . . . .

27 Exclusions under section 959(b) that apply to line 15g amount . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

-0-

28 Section 954(e) subpart F Foreign Base Company Services Income. Subtract line 27 from line 15g . . . . . . . . . . . .

29 Exclusions under section 959(b) that apply to lines 16g, 17g, 18k, 19, 20, and 21 amounts . . . . . . . .

-0-

30 Other subpart F income. Subtract line 29 from the sum of lines 16g, 17g, 18k, 19, 20, and 21 . . . . . . . . . . . . . . . . . . .

31 Total subpart F income. Add lines 24, 26, 28, and 30 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

32 Shareholder’s pro rata share of line 24 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

33 Shareholder’s pro rata share of export trade income that applies to line 32 amount (see section

970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

34 Section 954(c) subpart F Foreign Personal Holding Company Income subtotal. Subtract line 33 from line 32 . . . . . . . . .

35 Shareholder’s pro rata share of line 26 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

36 Shareholder’s pro rata share of export trade income that applies to line 35 amount (see section

970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

37 Section 954(d) subpart F Foreign Base Company Sales Income subtotal. Subtract line 36 from line 35

.............

38 Shareholder’s pro rata share of line 28 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

39 Shareholder’s pro rata share of export trade income that applies to line 38 amount (see section

970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Instructions for Form 5471

Worksheet A (continued)

Worksheet A (continued) (See instructions.)

40 Section 954(e) subpart F Foreign Base Company Services Income subtotal. Subtract line 39 from line 38 . . . . . . . . . . .

41 Shareholder’s pro rata share of line 30 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

42 Shareholder’s pro rata share of export trade income that applies to line 41 amount (see section

970(a)) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

43 Other subpart F income subtotal. Subtract line 42 from line 41 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

44 Add lines 34, 37, 40, and 43 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

45 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 44 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

46 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

47 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 44 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

48 Enter the smaller of line 46 or line 47 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

49 Shareholder’s pro rata share of subpart F income. Subtract line 48 from line 45 . . . . . . . . . . . . . . . . . . . . . . . . . . .

50 Amount of line 49 that applies to section 954(c) subpart F Foreign Personal Holding Company Income . . . . . . . . . . . . .

51 Translate the amount on line 50 from functional currency to U.S. dollars at the average exchange rate. See section

989(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

52 Shareholder’s pro rata share of line 51 attributable to a qualified activity under section 952(c)(1)(B) . . . . . . . . . . . . . . . .

53 Subtract line 52 from line 51. Enter the result here and on Form 5471, Schedule I, line 1e . . . . . . . . . . . . . . . . . . . . . . .

54 Amount of line 49 that applies to section 954(d) subpart F Foreign Base Company Sales Income

.................

55 Translate the amount on line 54 from functional currency to U.S. dollars at the average exchange rate. See section

989(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

56 Shareholder’s pro rata share of line 55 attributable to a qualified activity under section 952(c)(1)(B) . . . . . . . . . . . . . . . .

57 Subtract line 56 from line 55. Enter the result here and on Form 5471, Schedule I, line 1f . . . . . . . . . . . . . . . . . . . . . . . .

58 Amount of line 49 that applies to section 954(e) subpart F Foreign Base Company Services Income . . . . . . . . . . . . . . .

59 Translate the amount on line 58 from functional currency to U.S. dollars at the average exchange rate. See section

989(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

60 Shareholder’s pro rata share of line 59 attributable to a qualified activity under section 952(c)(1)(B) . . . . . . . . . . . . . . . .

61 Subtract line 60 from line 59. Enter the result here and on Form 5471, Schedule I, line 1g . . . . . . . . . . . . . . . . . . . . . . .

62 Amount of line 49 that applies to subpart F insurance income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

989(b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

64 Shareholder’s pro rata share of line 63 attributable to a qualified activity under section 952(c)(1)(B) . . . . . . . . . . . . . . . .

65 Subtract line 64 from line 63. Add the result to the amount on line 67 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

66 Amount of line 49 that applies to other subpart F income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

989(b). Add any amount on line 65 to this translated amount and enter the result here and on Form 5471, Schedule I,

line 1h . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Instructions for Form 5471

Worksheet A Instructions

Foreign base company income. Foreign base

company income generally does not include the following.

• Foreign base company shipping or oil related income as

defined in former section 954(f) and (g), respectively.

• Foreign personal holding company income derived in

the active conduct of a banking, finance, or similar

business (section 954(h)).

• Exempt insurance income under section 953(e) and

certain investment income of a qualifying insurance

company or a qualifying insurance branch (sections

953(a)(2) and 954(i)).

• Certain income derived in the ordinary course of

business of a securities dealer (section 954(c)(2)(C)(i)).

Note: Lines 1 through 4, relating to gross foreign personal

holding company income, gross foreign base company

sales income, and gross foreign base company services

income, must be completed after the application of

section 952(b). See Regulations section 1.954-1(a)(2).

Line 1. Gross foreign personal holding company income. If income is foreign personal holding company

income, it is not considered income in any other category

of foreign base company income, except as provided in

Regulations section 1.954-1(e)(4)(i)(A) through (C).

Line 1a. Dividends, interest, royalties, rents, and annuities. 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. Income equivalent to interest. Enter any

income equivalent to interest, including income from

commitment fees (or similar amounts) for loans actually

made.

Line 1c. Net income from a notional principal contract. Include net income from notional principal

contracts (except a contract entered into to hedge

inventory property).

Line 1d. Excess of foreign currency gains over foreign currency losses. Enter the excess of foreign

currency gains over foreign currency losses from section

988 transactions. An exception applies to transactions

directly related to the business needs of a CFC.

Line 1e. Excess of gains over losses from commodity

transactions. Enter the excess of gains over losses from

transactions (including futures, forward, and similar

transactions) in any commodities. See section 954(c)(1)

and special rules relating to commodity transactions.

Line 1f. Excess of gains over losses from certain

property transactions. 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 1g. Payments in lieu of dividends. Include

payments in lieu of dividends that are made as required

under section 1058.

Line 1h. Certain amounts received for services under

personal service contracts. Enter amounts received:

• Under a contract under which the corporation is to

furnish personal services if (a) some person other than the

corporation has a right to designate (by name or by

description) the individual who is to perform the services,

or (b) the individual who is to perform the services is

designated (by name or by description) in the contract;

and

• From the sale or other disposition of such a contract.

Note: The above rules apply with respect to amounts

received for services under a particular contract only if at

some time during the tax year 25% or more in value of the

outstanding stock of the corporation is owned, directly or

indirectly, by or for the individual who has performed, is to

perform, or may be designated (by name or by

description) as the one to perform, such services.

Instructions for Form 5471 (Rev. 12-2025)

Line 1i. Certain amounts from sales of partnership

interests to which the look-through rule of section

954(c)(4) applies. In the case of any sale by a CFC of an

interest in a partnership with respect to which the CFC is a

25% owner (defined below), such CFC is treated for

purposes of computing its foreign personal holding

company income as selling the proportionate share of the

assets of the partnership attributable to such interest.

Thus, the sale of a partnership interest by a CFC that

meets the ownership threshold constitutes subpart F

income only to the extent that a proportionate sale of the

underlying partnership assets attributable to the

partnership interest would constitute subpart F income.

Do not report these amounts on line 1b. Instead, report

them on line 1i.

25% owner. For purposes of these rules, a 25%

shareholder is a CFC that owns directly 25% or more of

the capital or profits interest in a partnership. For purposes

of the preceding sentence, if a CFC is a shareholder or

partner of a corporation or partnership, the CFC is treated

as owning directly its proportionate share of any such

capital or profits interest held directly or indirectly by such

corporation or partnership. If a CFC is treated as owning a

capital or profits interest in a partnership under

constructive ownership rules similar to the rules of section

958(b), the CFC is treated as owning such interest,

directly or indirectly, for purposes of this definition.

Line 6. Gross insurance income. Enter the CFC’s

gross insurance income taken into account in determining

insurance income under section 953, determined after the

application of section 952(b). See Regulations section

1.954-1(a)(6).

Note: If income is insurance income, it is not considered

income in any category of foreign base company income

except as provided in Regulations section 1.954-1(e)(4)(i)

(A) or (B).

Line 10. De minimis rule. If the sum of foreign base

company income (determined without regard to section

954(b)(5)) and gross insurance income (as defined in

section 954(b)(3)(C)) for the tax year is less than the

lesser of 5% of gross income for income tax purposes, or

$1 million, then no portion of the gross income for the tax

year is treated as foreign base company income or

insurance income. In this case, enter zero on line 10 and

skip lines 11 through 19. Otherwise, go to line 11.

Line 11. Full inclusion rule. If the sum of gross foreign

base company income (determined without regard to

section 954(b)(5)) and gross insurance income for the tax

year exceeds 70% of gross income for income tax

purposes, the entire gross income for the tax year must

(subject to the adjustments described below) be treated

as foreign base company income or insurance income,

whichever is appropriate. In this case, enter total gross

income (for income tax purposes) on line 11. Otherwise,

enter zero.

Line 12. Total adjusted gross foreign base company

income and insurance income. Enter the greater of

line 7 or line 11. However, if line 11 is greater than line 7,

reduce the line 11 amount by any portion of such amount

Instructions for Form 5471 (Rev. 12-2025)

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

line 12.

Line 13. Adjusted net foreign personal holding company income. Adjusted net foreign personal holding

company income is calculated by first determining the

gross amount of each item of foreign personal holding

company income and then allocating and apportioning

expenses to such items of income on lines 13b through e.

See section 954(b)(5) and Regulations section 1.954-1(c)

(1)(i). Expenses allocated and apportioned to an item of

income may reduce the item of income below zero, and

any item of income that is less than zero generally cannot

offset other items of income. For more information, see

Regulations section 1.954-1(c)(1)(ii). Do not enter

expenses on these lines of Worksheet A to the extent that

their allocation and apportionment reduces an item of

income below zero.

Once expenses are allocated and apportioned to gross

foreign personal holding company income, resulting in net

foreign personal holding company income, such amount

must be reduced for amounts excluded pursuant to

section 952(c) on line 13g. See Regulations section

1.954-1(a)(5) and (d)(4)(ii). Finally, to determine adjusted

net foreign personal holding company income, any

remaining amount of net foreign personal holding

company income after applying section 952(c) must be

reduced for amounts excluded under the high-tax

exception of section 954(b)(4) on line 13i. See

Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

U.S. shareholders must be reduced in the manner

prescribed in Regulations section 1.952-1(e).

Note: For the definition of “item of income,” see

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

Line 14. Adjusted net foreign base company sales income. Adjusted net foreign base company sales income

is calculated by first determining the gross amount of each

item of foreign base company sales income and then

allocating and apportioning expenses to such items of

income on line 14b. For more information, see section

954(b)(5) and Regulations section 1.954-1(c)(1)(i).

Expenses allocated and apportioned to an item of income

may reduce the item of income below zero, and any item

of income that is less than zero generally cannot offset

other items of income. For more information, see

Regulations section 1.954-1(c)(1)(ii). Do not enter

expenses on these lines of Worksheet A to the extent that

their allocation and apportionment reduces an item of

income below zero.

Once expenses are allocated and apportioned to gross

foreign base company sales income, resulting in net

foreign base company sales income, such amount must

be reduced for amounts excluded pursuant to section

952(c) on line 14d. See Regulations section 1.954-1(a)(5)

and (d)(4)(ii). Finally, to determine adjusted net foreign

base company sales income, any remaining amount of net

foreign base company sales income after applying section

952(c) must be reduced for amounts excluded under the

high-tax exception of section 954(b)(4) on line 14f. See

Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

U.S. shareholders must be reduced in the manner

prescribed in Regulations section 1.952-1(e).

Line 15. Adjusted net foreign base company services

income. Adjusted net foreign base company services

income is calculated by first determining the gross amount

of each item of foreign base company services income

and then allocating and apportioning expenses to such

items of income on line 15b. For more information, see

section 954(b)(5) and Regulations section 1.954-1(c)(1)

(i). Expenses allocated and apportioned to an item of

income may reduce the item of income below zero, and

any item of income that is less than zero generally cannot

offset other items of income. For more information, see

Regulations section 1.954-1(c)(1)(ii). Do not enter

expenses on these lines of Worksheet A to the extent that

their allocation and apportionment reduces an item of

income below zero.

Once expenses are allocated and apportioned to gross

foreign base company services income, resulting in net

foreign base company services income, such amount

must be reduced for amounts excluded pursuant to

section 952(c) on line 15d. See Regulations section

1.954-1(a)(5) and (d)(4)(ii). Finally, to determine adjusted

net foreign base company services income, any remaining

amount of net foreign base company services income

after applying section 952(c) must be reduced for

amounts excluded under the high-tax exception of section

954(b)(4) on line 15f. See Regulations section 1.954-1(a)

(5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

United States shareholders must be reduced in the

manner prescribed in Regulations section 1.952-1(e).

Note: In determining the amount of a net item of foreign

base company income, deductions or loss attributable to

disqualified basis and deductions attributable to

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

or (6)) are not allocated and apportioned to gross foreign

base company income.

Line 16. Adjusted net insurance income (other than

related person insurance income). In general,

insurance income is any income attributable to the issuing

(or reinsuring) of any insurance or annuity contract that

would (subject to the modifications provided in section

953(b)) be taxed under subchapter L (insurance company

tax) if such income were income of a domestic insurance

company. However, insurance income does not include

exempt insurance income (as defined in section 953(e)).

Adjusted net insurance income is calculated by

adjusting the amount of gross insurance income by the

amount of the CFC’s gross related person insurance

income (defined below) on line 16a. Then, each item of

gross insurance income (other than related person

insurance income) is reduced by allocating and

apportioning expenses to such items of income on

line 16b. For more information, see section 953 and

Regulations section 1.954-1(a)(6). Expenses allocated

and apportioned to an item of income may reduce the item

of income below zero, and any item of income that is less

than zero generally cannot offset other items of income.

For more information, see Regulations section 1.954-1(c)

(1)(ii). Do not enter expenses on these lines of Worksheet

A to the extent that their allocation and apportionment

reduces an item of income below zero.

Once expenses are allocated and apportioned to gross

insurance income (other than related person insurance

income), resulting in net insurance income (other than net

related person insurance income), such amount must be

reduced for amounts excluded pursuant to section 952(c)

on line 16d. See Regulations section 1.954-1(a)(6) and (d)

(4)(ii). Finally, to determine adjusted net insurance income

(other than related person insurance income), any

remaining amount of net insurance income (other than

related person insurance income) after applying section

952(c) must be reduced for amounts excluded under the

high-tax exception of section 954(b)(4) on line 16f. See

Regulations section 1.954-1(a)(6) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

U.S. shareholders must be reduced in the manner

prescribed in Regulations section 1.952-1(e).

Line 17. Adjusted net related person insurance income. In general, related person insurance income is

any insurance income (within the meaning of section

953(a)) attributable to a policy of insurance or reinsurance

for which the person insured, directly or indirectly, is a U.S.

shareholder (as defined in section 953(c)(1)(A)) in a CFC

(as defined in section 953(c)(1)(B)) or a related person (as

defined in section 953(c)(6)) to such a shareholder. If a

CFC has related person insurance income, the U.S.

shareholder’s pro rata share is to be determined under the

rules of section 953(c)(5).

Exceptions. The above definition does not apply to any

foreign corporation if:

• At all times during the foreign corporation’s tax year,

less than 20% of the total combined voting power of all

classes of stock of the corporation entitled to vote, and

less than 20% of the total value of the corporation, is

owned, directly or indirectly, under the principles of

section 883(c)(4) by persons who are, directly or indirectly,

insured under any policy of insurance or reinsurance

issued by the corporation or who are related persons to

any such person;

• The related person insurance income (determined on a

gross basis) of the corporation for the tax year is less than

20% of its insurance income for the tax year; or

• The corporation:

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.

Instructions for Form 5471 (Rev. 12-2025)

This election will not be effective if the corporation was

a disqualified corporation (as defined in section 953(c)(3)

(E)) for the tax year for which the election was made or for

any prior tax year beginning after 1986. See section

953(c)(3)(D) for special rules for this election.

Mutual life insurance companies. The related person

insurance income rules also apply to mutual life insurance

companies under regulations prescribed by the Secretary.

For these purposes, policyholders must be treated as

shareholders.

Adjusted net related person insurance income is

calculated by first determining the gross amount of each

item of related person insurance income and then

allocating and apportioning expenses to such items of

income on line 17b. For more information, see section 953

and Regulations section 1.954-1(a)(6). Expenses

allocated and apportioned to an item of income may

reduce the item of income below zero, and any item of

income that is less than zero generally cannot offset other

items of income. For more information, see Regulations

section 1.954-1(c)(1)(ii). Do not enter expenses on these

lines of Worksheet A to the extent that their allocation and

apportionment reduces an item of income below zero.

Once expenses are allocated and apportioned to gross

related person insurance income, resulting in net related

person insurance income, such amount must be reduced

for amounts excluded pursuant to section 952(c) on

line 17d. See Regulations section 1.954-1(a)(6) and (d)(4)

(ii). Finally, to determine adjusted net related person

insurance income, any remaining amount of net related

person insurance income after applying section 952(c)

must be reduced for amounts excluded under the high tax

exception of section 954(b)(4) on line 17f. See

Regulations section 1.954-1(a)(6) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

U.S. shareholders must be reduced in the manner

prescribed in Regulations section 1.952-1(e).

Note: In determining the amount of a net item of

insurance or related person insurance income, deductions

or loss attributable to disqualified basis and deductions

attributable to disqualified payments (Regulations section

1.951A-2(c)(5) or (6)) are not allocated and apportioned to

gross insurance income.

Line 18. Adjusted net full inclusion foreign base company income. Under Regulations section 1.954-1(d)(6),

gross full inclusion base company income is excluded

from a CFC’s subpart F income if more than 90% of the

adjusted gross foreign base company income and

adjusted gross insurance income of a CFC (determined

without regard to Regulations section 1.954-1(b)(1)) is

attributable to net amounts excluded from subpart F

income pursuant to an election to have the high-tax

exception described in section 954(b)(4) and Regulations

section 1.954-1(d) apply. Accordingly, this computation is

performed on lines 18b through 18e.

If gross full inclusion foreign base company income is

not excluded from subpart F as a result of the

computations on lines 18b through 18e, adjusted net full

Instructions for Form 5471 (Rev. 12-2025)

inclusion base company income is calculated by

allocating and apportioning expenses to the excess of the

CFC’s gross income and its gross foreign base company

income and gross insurance income on line 18f. For more

information, see section 954(b)(5) and Regulations

section 1.954-1(c)(1)(i). Expenses allocated and

apportioned to an item of income may reduce the item of

income below zero, and any item of income that is less

than zero generally cannot offset other items of income.

For more information, see Regulations section 1.954-1(c)

(1)(ii). Do not enter expenses on these lines of Worksheet

A to the extent that their allocation and apportionment

reduces an item of income below zero.

Once expenses are allocated and apportioned to gross

full inclusion base company income, resulting in net full

inclusion base company income, such amount must be

reduced for amounts excluded pursuant to section 952(c)

on line 18h. See Regulations section 1.954-1(a)(5) and (d)

(4)(ii). Finally, to determine adjusted net full inclusion base

company income, any remaining amount of net full

inclusion base company income after applying section

952(c) must be reduced for amounts excluded under the

high-tax exception of section 954(b)(4) on line 18j. See

Regulations section 1.954-1(a)(5) and (d)(4)(ii) and (iii).

Note: If the CFC’s subpart F income exceeds the foreign

corporation’s earnings and profits for the taxable year, the

subpart F income includible in the income of the CFC’s

U.S. shareholders must be reduced in the manner

prescribed in Regulations section 1.952-1(e).

Line 19. International boycott income. If a CFC or a

member of a controlled group (within the meaning of

section 993(a)(3)) that includes the CFC has operations

in, or related to, a country (or with the government, a

company, or a national of a country) that requires

participation in or cooperation with an international boycott

as a condition of doing business within such country or

with the government, company, or national of that country,

a portion of the CFC’s income is included in subpart F

income. The amount included is determined by multiplying

the CFC’s income (other than income included under

section 951 and U.S. source effectively connected

business income described in section 952(b)) by the

international boycott factor. This factor is a fraction

determined on Schedule A (Form 5713).

Special rule. If the shareholder of a CFC can clearly

demonstrate that the income earned for the tax year is

from specific operations, then, instead of applying the

international boycott factor, the addition to subpart F

income is the amount specifically from the operations in

which there was participation in or cooperation with an

international boycott. See Schedule B (Form 5713).

Line 20. Illegal bribes, kickbacks, and other 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 c

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