Instructions for Form 5471(Rev. February 2020) (Use with the December 2019 revision of Form 5471 and separate Schedules E, I-1, J, and P, the December 2018 revision of separate Schedules H and M, and the December 2012 revision of separate Schedule O.) Information Return of U.S. Persons With Respect to Certain Foreign Corporations
Can a Schedule J filer use Form 5471?
Schedule J filers in certain circumstances. Form 5471 filers generally use the same category of filer codes used on Form 1118. However, in the case of Schedule J (Form 5471) filers, if a foreign corporation has more than one of those categories of income, the filer must also complete and file a separate Schedule J using code
What are the penalties for failing to file Form 5471?
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.
When to report partnership interest on Form 5471?
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.
How is PTI reported on CFC Form 5471?
A: Both Schedule J (reporting all of a CFC’s accumulated E&P, both PTI and untaxed E&P) and Schedule P (reporting U.S. shareholder’s pro rata share of PTI) are reported in the CFC’s functional currency. Form 5471 does not require disclosure of the U.S. shareholder’s U.S. dollar basis in its PTI.
Are there any changes to separate schedule O?
Changes to separate Schedule O (Form 5471). No changes have been made to Schedule O (Form 5471). Use the December 2012 revision. Changes to separate Schedule P (Form 5471). Part II is new. It is identical to Part I except that previously taxed E&P must now be reported in functional currency (Part I) and U.S. dollars (Part II).
Can a dormant foreign corporation file a Form 5471?
Even dormant foreign corporations must file Form 5471. However, certain summary elective filing procedures apply to certain dormant foreign corporations under Rev. Proc. 92-70. 9 Transaction details are also required for any transactions between any shareholders of the foreign corporation and any related entity or person.
