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Department of the Treasury Instructions for Form 5471 Internal (Rev. December 2012) (Use with the December 2012 revisions of Form 5471, and Schedules J, M, and O.) Information Return of U.S. Persons With Respect to Certain Foreign

Section references are to the Internal Revenue 1. Stock which meets the 10% stock Code unless otherwise noted. General Instructions ownership requirement (described below) with respect to the foreign or Future Developments Purpose of Form 2. An additional 10% or more (in value For the latest information about or voting power) of the outstanding stock Form 5471 is used by certain U.S. citizens developments related to Form 5471, its of the . schedules, and its instructions, such as and residents who are officers, directors, legislation enacted after they were or shareholders in certain foreign A U.S. person has acquired stock in a published, go to www.irs.gov/form5471. corporations. The form and schedules are foreign corporation when that person has used to satisfy the reporting requirements an unqualified right to receive the stock, What's New of sections 6038 and 6046, and the even though the stock is not actually related regulations. issued. See Regulations section Line 1(b)(2) is used to request the 1.6046-1(f)(1) for more details. reference ID number of the foreign corporation and must be completed for Who Must File Stock ownership requirement. For years beginning in 2012. This entry space Generally, all U.S. persons described in purposes of Category 2 and Category 3, was optional in 2011. See the instructions Categories of Filers below must complete the stock ownership threshold is met if a for line 1b(2) for details. the schedules, statements, and/or other U.S. person owns: information requested in the chart, Filing 1. 10% or more of the total value of Reference ID numbers are also Requirements for Categories of Filers, on the foreign corporation's stock or requested on Schedules J, M, and O. page 2. Read the information for each Schedule G has been expanded to category carefully to determine which 2. 10% or more of the total combined include questions 6, 7, and 8, addressing schedules, statements, and/or information voting power of all classes of stock with reportable transactions and new rules apply. voting rights. relating to foreign disqualified under section 901(m) or constituting a splitting If the filer is described in more than one U.S. person. For purposes of Category 2 event under section 909. filing category, do not duplicate and Category 3, a U.S. person is: Schedule I has been expanded to information. However, complete all items 1. A citizen or resident of the United report name and identifying number of that apply. For example, if you are the sole States, Category 4 and 5 filers. owner of a controlled foreign corporation 2. A domestic , The American Taxpayer Relief Act of (CFC) (i.e., you are described in 2012 has extended the temporary Categories 4 and 5), complete all four 3. A domestic corporation, and exceptions for certain “active financing pages of Form 5471 and separate 4. An estate or trust that is not a income” from subpart F foreign personal Schedules J and M. foreign estate or trust defined in section holding income, foreign base 7701(a)(31). company services income, and insurance Note. Complete a separate Form 5471 income. The exceptions now apply to tax and all applicable schedules for each See Regulations section 1.6046-1(f)(3) years of foreign corporations beginning applicable foreign corporation. for exceptions. after December 31, 1998, and before January 1, 2014, and to tax years of U.S. When and Where To File Category 3 Filer shareholders with or within which any Attach Form 5471 to your This category includes: such tax years of foreign corporations return (or, if applicable, partnership or A U.S. person (defined above) who end. For more information, see the exempt organization return) and file both acquires stock in a foreign corporation instructions for Worksheet A beginning on by the due date (including extensions) for which, when added to any stock owned on page 8. that return. the date of acquisition, meets the 10% The American Taxpayer Relief Act of stock ownership requirement (described 2012 has extended the look-through rule Categories of Filers above) with respect to the foreign of section 954(c)(6). The rule now applies corporation; to tax years of foreign corporations Category 1 Filer A U.S. person who acquires stock beginning after December 31, 2005, and This filing requirement has been repealed which, without regard to stock already before January 1, 2014, and to tax years by section 413(c)(26) of the American owned on the date of acquisition, meets of U.S. shareholders with or within which Jobs Creation Act of 2004, which repealed the 10% stock ownership requirement with such tax years of the foreign corporations section 6035. respect to the foreign corporation; end. Continue to exclude the applicable A person who is treated as a U.S. types of income specified in section Category 2 Filer shareholder under section 953(c) with 954(c)(6) from Worksheet A, line 1a for This includes a U.S. citizen or resident respect to the foreign corporation; the time period specified in the previous who is an officer or director of a foreign A person who becomes a U.S. person sentence. corporation in which a U.S. person while meeting the 10% stock ownership (defined below) has acquired (in one or requirement with respect to the foreign more transactions): corporation; or

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A U.S. person who disposes of See Regulations section 1.6038-2(d) U.S. shareholder. For purposes of sufficient stock in the foreign corporation for exceptions. Category 5, a U.S. shareholder is a U.S. to reduce his or her interest to less than Control. A U.S. person has control of a person who: the stock ownership requirement. foreign corporation if, at any time during 1. Owns (directly, indirectly, or For more information, see section 6046 that person's tax year, it owns stock constructively, within the meaning of and Regulations section 1.6046-1. possessing: sections 958(a) and (b)) 10% or more of the total combined voting power of all Category 4 Filer 1. More than 50% of the total combined voting power of all classes of classes of voting stock of a CFC or This includes a U.S. person who had stock of the foreign corporation entitled to 2. Owns (either directly or indirectly, control (defined below) of a foreign vote or within the meaning of section 958(a)) any corporation for an uninterrupted period of 2. More than 50% of the total value of stock of a CFC (as defined in sections at least 30 days during the annual shares of all classes of stock of the foreign 953(c)(1)(B) and 957(b)) that is also a accounting period of the foreign corporation. captive insurance company. corporation. U.S. person. For purposes of A person in control of a corporation U.S. person. For purposes of Category 4, a U.S. person is: that, in turn, owns more than 50% of the Category 5, a U.S. person is: combined voting power, or the value, of all 1. A citizen or resident of the United 1. A citizen or resident of the United classes of stock of another corporation is States, States; also treated as being in control of such 2. A nonresident alien for whom an other corporation. 2. A domestic partnership, election is in effect under section 6013(g) 3. A domestic corporation, and Example. Corporation A owns 51% of to be treated as a resident of the United 4. An estate or trust that is not a States; the voting stock in Corporation B. Corporation B owns 51% of the voting foreign estate or trust defined in 3. An individual for whom an election stock in Corporation C. Corporation C section 7701(a)(31). is in effect under section 6013(h), relating owns 51% of the voting stock in See section 957(c) for exceptions. to nonresident aliens who become Corporation D. Therefore, Corporation D residents of the United States during the is controlled by Corporation A. CFC. A CFC is a foreign corporation that tax year and are married at the close of has U.S. shareholders that own (directly, For more details on “control,” see the tax year to a citizen or resident of the indirectly, or constructively, within the Regulations sections 1.6038-2(b) and (c). United States; meaning of sections 958(a) and (b)) on 4. A domestic partnership; Category 5 Filer any day of the tax year of the foreign corporation, more than 50% of: 5. A domestic corporation; and This includes a U.S. shareholder who 1. The total combined voting power of 6. An estate or trust that is not a owns stock in a foreign corporation that is all classes of its voting stock or foreign estate or trust defined in section a CFC for an uninterrupted period of 30 7701(a)(31). days or more during any tax year of the 2. The total value of the stock of the foreign corporation, and who owned that corporation. stock on the last day of that year. Exceptions From Filing Filing Requirements for Categories of Filers Multiple filers of same information. Category of Filer One person may file Form 5471 and the Required Information* 12345 applicable schedules for other persons who have the same filing requirements. If The identifying information on page 1 of Form 5471 you and one or more other persons are above Schedule A, see Specific Instructions ߛߛߛߛ required to furnish information for the Schedule A ߛ ߛ same foreign corporation for the same period, a joint information return that contains the required information may be ߛ ߛ Schedule B filed with your tax return or with the tax return of any one of the other persons. For Schedules C, E, and F ߛ ߛ example, a U.S. person described in Category 5 may file a joint Form 5471 with Schedule G ߛߛߛߛ a Category 4 or another Category 5 filer. However, for Category 3 filers, the ߛ ߛ required information may only be filed by Schedule H another person having an equal or greater interest (measured in terms of value or Schedule I ߛ ߛ voting power of the stock of the foreign corporation). Separate Schedule J ߛ ߛ The person that files Form 5471 must complete Item D on page 1 of the form. All Separate Schedule M ߛ persons identified in Item D must attach a statement to their income tax return that includes the information described in the Separate Schedule O, Part I ߛ instructions for Item D.

Separate Schedule O, Part II ߛ Domestic corporations. Shareholders are not required to file the information *See also Additional Filing Requirements on page 3. checked in the chart on this page for a

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foreign insurance company that has 1. The amount and type of any A seller (or its U.S. shareholder) must elected (under section 953(d)) to be indebtedness the foreign corporation has attach a copy of Form 8883 to the last treated as a domestic corporation and has with the related persons described in Form 5471 for the old foreign target filed a U.S. income tax return for its tax Regulations section 1.6046-1(b)(11) and corporation. year under that provision. See Rev. Proc. 2. The name, address, identifying Reportable transaction disclosure 2003-47, 2003-28 I.R.B. 55, for procedural number, and number of shares subscribed statement. If a U.S. shareholder of a rules regarding the election under section to by each subscriber to the foreign CFC is considered to have participated in 953(d). corporation's stock. a reportable transaction under the rules of Members of consolidated groups. A Regulations section 1.6011-4(c)(3)(i)(G), Category 4 filer is not required to file Form Foreign sales corporations (FSCs). the shareholder is required to disclose 5471 for a corporation defined in section Category 2 and Category 3 filers who information for each reportable 1504(d) that files a consolidated return for are shareholders, officers, and directors of transaction. Form 8886, Reportable the tax year. a FSC (as defined in section 922, as in Transaction Disclosure Statement, must effect before its repeal) must file Form Constructive owners. be filed for each tax year indicated in 5471 and separate Schedule O to report Regulations section 1.6011-4(c)(3)(i)(G). A U.S. person described in Category 3, changes in the ownership of the FSC. The following are reportable transactions. 4, or 5 does not have to file Form 5471 if Category 4 and 5 filers are not subject 1. Any listed transaction, which is a all of the following conditions are met: to the subpart F rules for: transaction that is the same as or 1. The U.S. person does not own a 1. Exempt foreign income, substantially similar to one of the types of direct interest in the foreign corporation, 2. Deductions that are apportioned or transactions that the IRS has determined 2. The U.S. person is required to allocated to exempt foreign trade income, to be a transaction and furnish the information requested solely 3. Nonexempt foreign trade income identified by notice, regulation, or other because of constructive ownership (as (other than section 923(a)(2) nonexempt published guidance as a listed determined under Regulations section income, within the meaning of transaction. 1.6038-2(c) or 1.6046-1(i)) from another section 927(d)(6), as in effect before its 2. Any transaction offered under U.S. person, and repeal), and conditions of confidentiality for which the 3. The U.S. person through which the 4. Any deductions that are corporation (or a related party) paid an indirect shareholder constructively owns apportioned or allocated to the nonexempt advisor a fee of at least $250,000. an interest in the foreign corporation files foreign trade income described above. 3. Certain transactions for which the Form 5471 to report all of the required corporation (or a related party) has information. Category 4 and 5 filers are subject to contractual protection against No statement is required to be attached the subpart F rules for: disallowance of the tax benefits. to tax returns for persons claiming the 1. All other types of FSC income 4. Certain transactions resulting in a constructive ownership exception. (including section 923(a)(2) nonexempt loss of at least $10 million in any single income within the meaning of A Category 2 filer does not have to file year or $20 million in any combination of section 927(d)(6), as in effect before its Form 5471 if: years. repeal), 1. Immediately after a reportable 5. Any transaction identified by the 2. Investment income and carrying stock acquisition, three or fewer U.S. IRS by notice, regulation, or other charges (as defined in sections 927(c) and persons own 95% or more in value of the published guidance as a “transaction of 927(d)(1), as in effect before their repeal), outstanding stock of the foreign interest.” See Notice 2009-55, 2009-31 and corporation and the U.S. person making I.R.B. 170. the acquisition files a return for the 3. All other FSC income that is not For more information, see Regulations acquisition as a Category 3 filer or foreign trade income or investment income or carrying charges. section 1.6011-4. Also see the Instructions 2. The U.S. person(s) for which the for Form 8886. Category 2 filer is required to file Form Category 4 and 5 filers are not required 5471 does not directly own an interest in to file a Form 5471 (in order to satisfy the Penalties. The U.S. shareholder may the foreign corporation but is required to requirements of section 6038) if the FSC have to pay a penalty if it is required to furnish the information solely because of has filed a Form 1120-FSC. See disclose a reportable transaction under constructive stock ownership from a U.S. Temporary Regulations section section 6011 and fails to properly person and the person from whom the 1.921-1T(b)(3). However, these filers may complete and file Form 8886. Penalties stock ownership is attributed furnishes all be required to file Form 5471 if they are may also apply under section 6707A if the of the required information. subject to the subpart F rules with respect U.S. shareholder fails to file Form 8886 to certain types of FSC income (see with its income tax return, fails to provide a A Category 4 or 5 filer does not have to above). copy of Form 8886 to the Office of Tax file Form 5471 if the shareholder: Shelter Analysis (OTSA), or files a form 1. Does not own a direct or indirect Section 338 election. If a section 338 that fails to include all the information interest in the foreign corporation and election is made with respect to a qualified required (or includes incorrect stock purchase of a foreign target information). Other penalties, such as an 2. Is required to file Form 5471 solely corporation for which a Form 5471 must accuracy-related penalty under section because of constructive ownership from a be filed: 6662A, may also apply. See the nonresident alien. A purchaser (or its U.S. shareholder) Instructions for Form 8886 for details on must attach a copy of Form 8883, Asset these and other penalties. Additional Filing Allocation Statement Under Section 338, Reportable transactions by material to the first Form 5471 for the new foreign Requirements advisors. Material advisors to any target corporation. See the Instructions for reportable transaction must disclose Category 3 filers. Category 3 filers must Form 8883 for details. attach a statement that includes: certain information about the reportable transaction by filing Form 8918, Material

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Advisor Disclosure Statement, with the Form 5471 and Schedule J, M, or O who “118.5050” in column (c), and “255,309” in IRS. For details, see the Instructions for agrees to have another person file the column (d). Form 8918. form and schedules for him or her may be subject to the above penalties if the other Computer-Generated Reporting other foreign financial as- person does not file a correct and proper Form 5471 and Schedules sets. If you have other foreign financial form and schedule. assets, you may be required to file Form A computer-generated Form 5471 and its 8938, Statement of Specified Foreign Section 6662(j). Penalties may be schedules may be filed if they conform to Financial Assets. However, you are not imposed for undisclosed foreign financial and do not deviate from the official form required to report any items otherwise asset understatements. No penalty will be and schedules. Generally, all reported on Form 5471 on that form. See imposed with respect to any portion of an computer-generated forms must receive the Instructions for Form 8938 for more underpayment if the taxpayer can prior approval from the IRS and are information. demonstrate that the failure to comply was subject to an annual review. due to reasonable cause with respect to Requests for approval may be Penalties such portion of the underpayment and the submitted electronically to taxpayer acted in good faith with respect [email protected], or requests may Failure to file information required by to such portion of the underpayment. See be mailed to: , section 6038(a) (Form 5471 and sections 6662(j) and 6664(c) for additional Attention: Substitute Forms Program, Schedule M). information. SE:W:CAR:MP:T:T:SP, 1111 Constitution A $10,000 penalty is imposed for each Avenue, NW, IR-6526, Washington, DC annual accounting period of each foreign Other Reporting 20224. corporation for failure to furnish the Requirements required information within the time Important: Be sure to attach the approval prescribed. If the information is not filed Reporting exchange rates on Form letter to Form 5471. within 90 days after the IRS has mailed a 5471. When translating amounts from Every year, the IRS issues a revenue notice of the failure to the U.S. person, an functional currency to U.S. dollars, you procedure to provide guidance for filers of additional $10,000 penalty (per foreign must use the method specified in these computer-generated forms. In addition, corporation) is charged for each 30-day instructions. For example, when every year the IRS issues Pub. 1167, period, or fraction thereof, during which translating amounts to be reported on General Rules and Specifications For the failure continues after the 90-day Schedule E, you generally must use the Substitute Forms and Schedules, which period has expired. The additional penalty average exchange rate as defined in reprints the most recent applicable is limited to a maximum of $50,000 for section 986(a). But, regardless of the revenue procedure. Pub. 1167 is available each failure. specific method required, all exchange on the IRS website at IRS.gov. Any person who fails to file or report all rates must be reported using a “divide-by of the information required within the time convention” rounded to at least four Dormant Foreign Corporations prescribed will be subject to a reduction of places. That is, the exchange rate must be Rev. Proc. 92-70, 1992-2 C.B. 435, 10% of the foreign taxes available for reported in terms of the amount by which credit under sections 901, 902, and 960. If provides a summary filing procedure for the functional currency amount must be filing Form 5471 for a dormant foreign the failure continues 90 days or more after divided in order to reflect an equivalent the date the IRS mails notice of the failure corporation (defined in sec. 3 of Rev. amount of U.S. dollars. As such, the Proc. 92-70). This summary filing to the U.S. person, an additional 5% exchange rate must be reported as the reduction is made for each 3-month procedure will satisfy the reporting units of foreign currency that equal one requirements of sections 6038 and 6046. period, or fraction thereof, during which U.S. dollar, rounded to at least four the failure continues after the 90-day places. Do not report the exchange rate If you elect the summary procedure, period has expired. See section 6038(c) as the number of U.S. dollars that equal complete only page 1 of Form 5471 for (2) for limits on the amount of this penalty. one unit of foreign currency. each dormant foreign corporation as Failure to file information required by follows: section 6046 and the related regula- Note. You must round the result to more The top margin of the summary return tions (Form 5471 and than four places if failure to do so would must be labeled “Filed Pursuant to Rev. Schedule O). Any person who fails to file materially distort the exchange rate or the Proc. 92-70 for Dormant Foreign or report all of the information requested equivalent amount of U.S. dollars. Corporation.” by section 6046 is subject to a $10,000 Example. During its annual Include filer information such as name penalty for each such failure for each accounting period, the foreign corporation and address, Items A through C, and tax reportable transaction. If the failure paid income taxes of 30,255,400 Yen to year. continues for more than 90 days after the Japan. The Schedule E instructions Include corporate information such as date the IRS mails notice of the failure, an specify that the foreign corporation must the dormant corporation's annual additional $10,000 penalty will apply for translate these amounts into U.S. dollars accounting period (below the title of the each 30-day period or fraction thereof at the average exchange rate for the tax form) and Items 1a, 1b, 1c, and 1d. during which the failure continues after the year to which the tax relates in For more information, see Rev. Proc. 90-day period has expired. The additional accordance with the rules of section 92-70. penalty is limited to a maximum of 986(a). The average exchange rate is File this summary return in the manner $50,000. 118.5050 Japanese Yen to 1 U.S. dollar described in When and Where To File, Criminal penalties. Criminal penalties (0.00843846) U.S. dollars to 1 Japanese earlier. Yen). The foreign corporation divides under sections 7203, 7206, and 7207 may Treaty-Based Return Positions apply for failure to file the information 30,255,400 Yen by 118.5050 to determine required by sections 6038 and 6046. the U.S. dollar amount to enter in column You are generally required to file (d) of Schedule E. Line 2 of Schedule E is Form 8833, Treaty-Based Return Position Note. Any person required to file to be completed as follows: Enter “Japan” Disclosure Under Section 6114 or in column (a), “30,255,400” in column (b), 7701(b), to disclose a return position that any treaty of the United States (such as an

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income , an estate and period of the foreign corporation for which Item B—Category of Filer treaty, or a friendship, commerce, and you are furnishing information. Except for Complete Item B to indicate the category navigation treaty): information contained on Schedule O, or categories that describe the person report information for the tax year of the Overrides or modifies any provision of filing this return. If more than one category foreign corporation that ends with or within the Internal Revenue Code and applies, check all boxes that apply. Causes, or potentially causes, a your tax year. When filing Schedule O, reduction of any tax incurred at any time. report acquisitions, dispositions, and Item C—Percentage of Voting organizations or reorganizations that See Form 8833 for exceptions. Stock Owned occurred during your tax year. Failure to make a required disclosure Enter the total percentage of the foreign Specified foreign corporation. The may result in a $1,000 penalty ($10,000 corporation's voting stock you owned annual accounting period of a specified for a C corporation). See section 6712. directly, indirectly, or constructively at the foreign corporation is generally required to end of the corporation's annual accounting Section 362(e)(2)(C) Elections be the tax year of the corporation's period. majority U.S. shareholder. If there is more The transferor and transferee in certain Item D—Person(s) on Whose section 351 transactions may make a joint than one majority shareholder, the election under section 362(e)(2)(C) to limit required tax year will be the tax year that Behalf This Information Return the transferor's basis in the stock received results in the least aggregate deferral of Is Filed instead of the transferee's basis in the income to all U.S. shareholders of the foreign corporation. The person that files the required transferred property. The election is made information on behalf of other persons by a statement as provided in Notice A specified foreign corporation is any must complete Item D. See Multiple filers 2005-70, 2005-41 I.R.B. 694, and foreign corporation: of same information, earlier. In addition, a regulations under section 362(e)(2). 1. That is treated as a CFC under separate Schedule I must be filed for each Do not attach the statement subpart F and person described in Category 4 or 5. ! described above to Form 5471. 2. In which more than 50% of the total Except for members of the filer's CAUTION voting power or value of all classes of consolidated return group and those stock of the corporation is treated as Section 108(i) Elections persons claiming the constructive owned by a U.S. shareholder. ownership exception, all persons identified The controlling domestic shareholder(s) of For more information, see section 898 in Item D must attach a statement to their a CFC may make the election under and Rev. Procs. 2002-37, 2002-22 I.R.B. tax returns that includes the following section 108(i) to defer recognizing 1030, and 2002-39, 2002-22 I.R.B. 1046, information: discharge of indebtedness income in as modified by Notice 2002-72, 2002-46 A statement that their filing certain situations. The election is made by I.R.B. 843. requirements have been or will be a statement as provided in Rev. Proc. satisfied; 2009-37, 2009-36 I.R.B. 309. Name Change The name, address, and identifying Do not attach the statement If the name of either the person filing the number of the return with which the described above to Form 5471. return or the corporation whose activities information was or will be filed; and are being reported changed within the The IRS Service Center where the past 3 years, show the prior name(s) in return was or will be filed. If the return was Corrections to Form 5471 parentheses after the current name. or will be filed electronically, enter “e-file.” If you file a Form 5471 that you later determine is incomplete or incorrect, file a Address Item 1b(2)—Reference ID corrected Form 5471 with an amended tax Include the suite, room, or other unit Number return, using the amended return number after the street address. If the post A reference ID number (defined below) is instructions for the return with which you office does not deliver mail to the street required on line 1b(2) only in cases where originally filed Form 5471. Write address and the U.S. person has a P.O. no EIN was entered on line 1b(1) for the "corrected" at the top of the form and box, show the box number instead. foreign corporation. However, filers are attach a statement identifying the Foreign address. Enter the information permitted to enter both an EIN on changes. in the following order: city, province or line 1b(1) and a reference ID number on state, and country. Follow the country's line 1b(2). If applicable, enter the practice for entering the postal code, if reference ID number you have assigned to Specific Instructions any. Do not abbreviate the country name. the foreign corporation identified on line 1a. Important: If the information required in a Item A—Identifying Number A "reference ID number" is a number given section exceeds the space provided The identifying number of an individual is established by or on behalf of the U.S. within that section, do not write “see his or her social security number (SSN). person identified at the top of page 1 of attached” in the section and then attach all The identifying number of all others is their the form that is assigned to a foreign of the information on additional sheets. employer identification number (EIN). If a corporation with respect to which Form Instead, complete all entry spaces in the U.S. corporation that owns stock in a 5471 reporting is required. These section and attach the remaining foreign corporation is a member of a numbers are used to uniquely identify the information on additional sheets. The consolidated group, list the common foreign corporation in order to keep track additional sheets must conform with the parent as the person filing the return and of the corporation from tax year to tax IRS version of that section. enter its EIN in Item A. Identify only the year. direct owners in Item D who are also Identifying Information members of the consolidated group; The reference ID number must meet constructive owners who are also the requirements set forth below. Annual Accounting Period members of the consolidated group are Enter, in the space provided below the title not required to be listed. Note. Because reference ID numbers are of Form 5471, the annual accounting established by or on behalf of the U.S.

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person filing Form 5471, there is no need each such number. As indicated above, Accounting Principles Board and to apply to the IRS to request a reference the length of a given reference ID number Statement No. 16 of the Financial ID number or for permission to use these is limited to 50 characters and each Accounting Standards Board). numbers. number must be alphanumeric and no Line 20. Enter the income, war profits, special characters are permitted. Note. The reference ID number assigned and excess profits taxes deducted in Note. This correlation requirement accordance with U.S. GAAP. to a foreign corporation on Form 5471 applies only to the first year the new generally has relevance only on Form reference ID number is used. Important: Differences between this 5471 and its schedules and should functional currency amount and the generally not be used with respect to that Items 1f and 1g—Principal amount of taxes that reduce U.S. E&P foreign corporation on any other IRS tax Activity should be accounted for on line 2g of form. However, the foreign corporation’s Schedule H. reference ID number should also be Enter the principal business activity code entered on Form 8858 if the foreign number and the description of the activity corporation is listed as a tax owner of a from the list beginning on page 16. Schedule E foreign disregarded entity (FDE) on Form Item 1h—Functional Currency List income, war profits, and excess profits 8858. See the instructions for Form 8858, taxes paid or accrued to the United States Enter the foreign corporation's functional line 3c(2) for more information. and to any foreign country or U.S. currency. Regulations sections possession for the annual accounting Requirements. The reference ID number 1.6038-2(h) and 1.6046-1(g) require that period. Report these amounts in column that is entered in item 1b(2) must be certain amounts be reported in U.S. (b) in the local currency in which the taxes alphanumeric and no special characters or dollars and/or in the foreign corporation's are payable. Translate these amounts into spaces are permitted. The length of a functional currency. The specific U.S. dollars at the average exchange rate given reference ID number is limited to 50 instructions for the affected schedules for the tax year to which the tax relates characters. state these requirements. unless one of the exceptions below The same reference ID number must applies. See section 986(a). be used consistently from tax year to tax Special rules apply for foreign year with respect to a given foreign corporations that use the U.S. dollar Exceptions. If one of the following corporation. If for any reason a reference approximate separate transactions exceptions applies, use the exchange rate ID number falls out of use (for example, method of accounting (DASTM) under in effect on the date you paid the tax. the foreign corporation no longer exists Regulations section 1.985-3. See the 1. The tax is paid before the due to disposition or liquidation), the instructions for Schedule C and beginning of the year to which the tax reference ID number used for that foreign Schedule H. relates. corporation cannot be used again for 2. For tax years beginning after another foreign corporation for purposes Schedule B December 31, 2004, there is an election in of Form 5471 reporting. Category 3 and 4 filers must complete effect under section 986(a)(1)(D) to There are some situations that warrant Schedule B for U.S. persons that owned translate foreign taxes attributable to the correlation of a new reference ID number (at any time during the annual accounting CFC using the exchange rate in effect on with a previous reference ID number when period), directly or indirectly through the date of payment. assigning a new reference ID number to a foreign entities, 10% or more in value or Enter the exchange rate used in foreign corporation. For example: voting power of any class of the column (c). Report the exchange rate In the case of a merger or acquisition, a corporation's outstanding stock. using the “divide-by convention” specified Form 5471 filer must use a reference ID Column (e). Enter each shareholder's under Reporting Exchange Rates on Form number which correlates the previous allocable percentage of the foreign 5471, earlier. Enter the translated dollar reference ID number with the new corporation's subpart F income. amount in column (d). reference ID number assigned to the foreign corporation. Schedule C Schedule F In the case of an entity classification If the foreign corporation uses the U.S. election that is made on behalf of a foreign If the foreign corporation uses DASTM, dollar approximate separate transactions the tax balance sheet on Schedule F corporation on Form 8832, Regulations method of accounting (DASTM) under section 301.6109-1(b)(2)(v) requires the should be prepared and translated into Regulations section 1.985-3, the U.S. dollars according to Regulations foreign corporation to have an EIN for this functional currency column should reflect election. For the first year that Form 5471 section 1.985-3(d), rather than U.S. local hyperinflationary currency amounts GAAP. is filed after an entity classification election computed in accordance with U.S. is made on behalf of the foreign Generally Accepted Accounting Principles corporation on Form 8832, the new EIN (GAAP). The U.S. dollar column should Schedule G must be entered on line 1b(1) of Form reflect such amounts translated into Question 1 5471 and the old reference ID number dollars under U.S. GAAP translation rules. If the foreign corporation owned at least a must be entered on line 1b(2). In Differences between this U.S. dollar 10% interest, directly or indirectly, in any subsequent years, the Form 5471 filer GAAP column and the U.S. dollar income foreign partnership, attach a statement may continue to enter both the EIN on or loss figured for tax purposes under listing the following information for each line 1b(1) and the reference ID number on Regulations section 1.985-3(c) should be foreign partnership: line 1b(2), but must enter at least the EIN accounted for on Schedule H. See on line 1b(1). Schedule H, Special rules for DASTM, 1. Name and EIN (if any) of the You must correlate the reference ID below. foreign partnership; numbers as follows: New reference ID 2. Identify which, if any, of the number [space] Old reference ID number. Line 19. The terms “extraordinary items” and “prior period adjustments” have the following forms the foreign partnership If there is more than one old reference ID filed for its tax year ending with or within number, you must enter a space between same meaning given to them by U.S. GAAP (see Opinion No. 30 of the

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the corporation's tax year: Form 1042, depreciation must be figured according to types of income, including subpart F 1065 or 1065-B, or 8804; section 167. However, if 20% or more of income. For more information, see 3. Name of the tax matters partner (if the foreign corporation's gross income is sections 951 and 952. any); and from U.S. sources, depreciation must be Use Worksheet A (which begins on figured on a straight line basis according page 8) to compute the U.S. shareholder's 4. Beginning and ending dates of the to Regulations section 1.312-15. foreign partnership's tax year. pro rata share of subpart F income of the Line 2f. Inventories must be taken into CFC. Subpart F income includes the Question 3 account according to the rules of following: Check the “Yes” box if the foreign sections 471 (incorporating the provisions Adjusted net foreign base company corporation is the tax owner of an FDE. of section 263A) and 472 and the related income (lines 1 through 19); The “tax owner” of an FDE is the person regulations. Adjusted net insurance income (line 20); that is treated as owning the assets and Line 2g. See the instructions for Adjusted net related person insurance liabilities of the FDE for purposes of U.S. Schedule C, line 20 above. income . income (line 21); Line 2h. Enter the net amount of any International boycott income (line 22); If the foreign corporation is the tax additional adjustments not included on Illegal bribes, kickbacks, and other owner of an FDE and you are a category 4 lines 2a through 2g. List these additional payments (line 23); and or 5 filer of Form 5471, you are required to adjustments on a separate schedule. Income from a country described in attach Form 8858 to Form 5471. Attach this schedule to Form 5471. section 952(a)(5) (line 24). If the foreign corporation is the tax Line 5b. DASTM gain or (loss), reflecting Important: If the subpart F income of any owner of an FDE and you are not a unrealized exchange gain or loss, should CFC for any tax year was reduced category 4 or 5 filer of Form 5471, you be entered on line 5b only for foreign because of the current E&P limitation (see must attach the statement described corporations that use DASTM. below in lieu of Form 8858. the instructions for line 29 of Worksheet A, Line 5d. Enter the line 5c functional later), any excess of the E&P of the CFC Statement in lieu of Form 8858. This currency amount translated into U.S. for any subsequent tax year over the statement must list the name of the FDE, dollars at the average exchange rate for subpart F income of the CFC for the tax country under whose laws the FDE was the foreign corporation's tax year. See year must be recharacterized as subpart F organized, and EIN (if any) of the FDE. section 989(b). Report the exchange rate income. using the “divide-by convention” specified Schedule H under Reporting Exchange Rates on Form Lines 2 Through 4 Use Schedule H to report the foreign 5471, earlier. If the foreign corporation Other amounts not eligible for deferral that corporation's current earnings and profits uses DASTM, enter on line 5d the same are reported on Schedule I include: (E&P) for U.S. tax purposes. Enter the amount entered on line 5c. Earnings invested in U.S. property (Worksheet B); amounts on lines 1 through 5c in Blocked income. The E&P of the foreign functional currency. corporation, as reflected on Schedule H, Amounts withdrawn from qualified must not be reduced by all or any part of investments in less developed countries Special rules for DASTM. If the foreign and amounts withdrawn from qualified corporation uses DASTM, enter on line 1 such E&P that could not have been distributed by the foreign corporation due investments in foreign base company the dollar GAAP income or (loss) from shipping operations (Worksheet C); and line 21 of Schedule C. Enter on lines 2a to currency or other restrictions or limitations imposed under the laws of any Amounts withdrawn from investment in through 4 the adjustments made in trade assets (Worksheet D). figuring current E&P for U.S. tax purposes. foreign country. Report these amounts in U.S. dollars. Line 5 Enter on line 5b the DASTM gain or loss Schedule I Enter the factoring income (as defined in figured under Regulations section Use Schedule I to report in U.S. dollars the section 864(d)(1)) if no subpart F income 1.985-3(d). U.S. shareholder's pro rata share of is reported on line 1a, Worksheet A, Lines 2a through 2h. Certain income from the foreign corporation because of the operation of the de minimis adjustments (required by Regulations reportable under subpart F and other rule (see lines 1a, 9, and 11 of Worksheet sections 1.964-1(b) and (c)) must be income realized from a corporate A and the related instructions). distribution. made to the foreign corporation's line 1 net Line 6 book income or (loss) to determine its current E&P. These adjustments may Note. A separate Schedule I must be Add lines 1 through 5. Enter the result include both positive and negative filed by each Category 4 or 5 U.S. here and on your tax return. For a adjustments to conform the foreign book shareholder for whom reporting is corporate U.S. shareholder, enter the income to U.S. GAAP and to U.S. tax furnished on this Form 5471. result on Form 1120, Schedule C, line 14, accounting principles. If the foreign Line 1 or on the comparable line of other corporation's books are maintained in returns. For a noncorporate functional currency in accordance with Subpart F income. Generally, the U.S. shareholder, enter the result on Form U.S. GAAP, enter on line 1 the functional income of a foreign corporation with U.S. 1040, line 21 (Other Income), or on the currency GAAP income or (loss) from shareholders is not taxed to those U.S. comparable line of other noncorporate tax line 21 of Schedule C, rather than starting shareholders until the income is returns. repatriated to the United States (e.g., with foreign book income, and show Line 7 GAAP-to-tax adjustments on lines 2a through the payment of dividends to the through 2h. U.S. shareholders or in the form of gain on Enter the dividends you received from the the disposition of the U.S. shareholders' foreign corporation that were not Lines 2b and 2c. Generally, stock in the foreign corporation). However, previously taxed under subpart F in the depreciation, depletion, and amortization this deferral of U.S. tax is not available to current year or in any prior year. allowances must be based on the U.S. shareholders of CFCs with certain historical cost of the underlying asset, and

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Line 8 income. Also, a trade or service receivable particular only if at some time acquired or treated as acquired by a CFC during the tax year 25% or more in value If previously taxed E&P described in from a related U.S. person is considered of the outstanding stock of the corporation section 959(a) or (b) was distributed, enter an investment in U.S. property for is owned, directly or indirectly, by or for the amount of foreign currency gain or purposes of section 956 (Worksheet B) if the individual who has performed, is to (loss) on the distribution, computed under the obligor is a U.S. person. perform, or may be designated (by name section 986(c). See Notice 88-71, 1988-2 or by description) as the one to perform, C.B. 374, for rules for computing section Line 1b. Enter the excess of gains over such services. 986(c) gain or (loss). losses from the sale or exchange of: For a corporate U.S. shareholder, Property that produces the type of Line 1i. For tax years beginning after include the gain or (loss) as “other income reportable on line 1a. December 31, 2004, in the case of any income” on line 10 of Form 1120, or on the An interest in a trust, partnership, or sale by a CFC of an interest in a comparable line of other corporate tax REMIC. However, see the instructions for partnership with respect to which the CFC returns. For a noncorporate U.S. line 1i for an exception that provides for is a 25% owner (defined below), such shareholder, include the result as “other look-through treatment for certain sales of CFC is treated for purposes of computing income” on line 21 of Form 1040, or on the partnership interests. its foreign personal comparable line of other noncorporate tax Property that does not produce any income as selling the proportionate share returns. income. of the assets of the partnership attributable to such interest. Thus, the sale Do not include: Certain current year deficits of a of a partnership interest by a CFC that Income, gain, deduction, or loss from member of the same chain of corporations meets the ownership threshold constitutes any transaction (including a hedging may be considered in determining subpart subpart F income only to the extent that a transaction) and transactions involving F income. See section 952(c)(1)(C). proportionate sale of the underlying physical settlement of a regular dealer in partnership assets attributable to the property, forward , option Worksheet A partnership interest would constitute contracts, and similar financial instruments subpart F income. Do not report these Foreign base company income. (section 954(c)(2)(C)). amounts on line 1b. Instead, report them Foreign base company income generally Gains and losses from the sale or on new line 1i. does not include: exchange of any property that, in the Foreign base company shipping income hands of the CFC, is property described in 25% owner. For purposes of these rules, as defined in former section 954(f). section 1221(a)(1). a 25% shareholder is a CFC that owns Foreign personal holding company directly 25% or more of the capital or Line 1c. Enter the excess of gains over income derived in the active conduct of a profits interest in a partnership. For losses from transactions (including CFC of a banking, finance, or similar purposes of the preceding sentence, if a futures, forward, and similar transactions) business (section 954(h)). CFC is a shareholder or partner of a in any commodities. See section 954(c)(1) corporation or partnership, the CFC is Certain investment income derived by a (C) for exceptions. See section 954(c)(5) treated as owning directly its proportionate qualifying insurance company and by for a definition and special rules relating to share of any such capital or profits interest certain qualifying insurance branches commodity transactions. (sections 953(a)(2) and 954(i)). held directly or indirectly by such Exempt insurance income under Line 1d. Enter the excess of foreign corporation or partnership. If a CFC is section 953(e) or that is not treated as currency gains over foreign currency treated as owning a capital or profits foreign personal holding company income losses from section 988 transactions. An interest in a partnership under under the active conduct of an insurance exception applies to transactions directly constructive ownership rules similar to the business exception (section 954(i)); the related to the business needs of a CFC. rules of section 958(b), the CFC shall be treated as owning such interest directly or active conduct of a banking, financing, or Line 1e. Enter any income equivalent to indirectly for purposes of this definition. similar business exception (section interest, including income from 954(h)); or the securities dealer exception commitment fees (or similar amounts) for Line 11. De minimis rule. If the sum of (section 954(c)(2)(C)(ii)). loans actually made. foreign base company income (determined without regard to section Line 1a. Do not include the following: Line 1f. Include net income from notional 954(b)(5)) and gross insurance income Interest from conducting a banking principal contracts (except a contract (as defined in section 954(b)(3)(C)) for the business that is “export financing interest” entered into to hedge inventory property). (section 904(d)(2)(G)); tax year is less than the smaller of 5% of Rents and royalties from actively Line 1g. Include payments in lieu of gross income for income tax purposes, or conducting a trade or business received dividends that are made as required under $1 million, then no portion of the gross from a person other than a “related section 1058. income for the tax year is treated as foreign base company income or person” (as defined in section 954(d)(3)); Line 1h. Enter amounts received: insurance income. In this case, enter zero and Under a contract under which the Dividends, interest, rent or royalty on line 11 and skip lines 12 corporation is to furnish personal services through 21. Otherwise, go to line 12. income from related corporate payors if (a) some person other than the described in section 954(c)(3). However, corporation has a right to designate (by Line 12. Full inclusion rule. If the sum see section 964(e) for an exception. name or by description) the individual who of foreign base company income Interest income includes factoring is to perform the services or (b) the (determined without regard to section income arising when a person acquires a individual who is to perform the services is 954(b)(5)) and gross insurance income for trade or service receivable (directly or designated (by name or by description) in the tax year exceeds 70% of gross income indirectly) from a related person. The the contract, and for income tax purposes, the entire gross income is treated as interest on a loan to From the sale or other disposition of income for the tax year must (subject to the obligor under section 864(d)(1) and is such a contract. the high tax exception described below, generally not eligible for the de minimis, the section 952(b) exclusion, and the export financing, and related party Note. The above rules apply with respect deductions to be taken into account under exceptions to the inclusion of subpart F to amounts received for services under a section 954(b)(5)) be treated as foreign

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Worksheet A—Foreign Base Company Income and Insurance Income and Summary of U.S. Shareholder’s Pro Rata Share of Subpart F Income of a CFC (See instructions beginning on page 7.) Enter the amounts on lines 1a through 38a in functional currency. 1 Gross foreign personal holding company income: a Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A) (excluding amounts described in sections 954(c)(2), (3), and (6))) 1a b Excess of gains over losses from certain property transactions (section 954(c)(1)(B)) 1b c Excess of gains over losses from commodity transactions (section 954(c)(1)(C)) 1c d Excess of foreign currency gains over foreign currency losses (section 954(c)(1)(D)) 1d e Income equivalent to interest (section 954(c)(1)(E)) 1e f Net income from a notional principal contract (section 954(c)(1)(F)) 1f g Payments in lieu of dividends (section 954(c)(1)(G)) 1g h Certain amounts received for services under personal service contracts (see section 954(c)(1)(H)) 1h i Certain amounts from sales of partnership interests to which the look-through rule of section 954(c)(4) applies 1i 2 Gross foreign personal holding company income. Add lines 1a through 1i 2 3 Gross foreign base company sales income (see section 954(d)) 3 4 Gross foreign base company services income (see section 954(e)) 4 5 Gross foreign base company oil-related income (see section 954(g)) after application of section 954(b)(6) 5 6 Gross foreign base company income. Add lines 2 through 5 6 7 Gross insurance income (see sections 953 and 954(b)(3)(C) and the instructions for lines 20 and 21) 7 8 Gross foreign base company income and gross insurance income. Add lines 6 and 7 8 9 Enter 5% of total gross income (as computed for income tax purposes) 9 10 Enter 70% of total gross income (as computed for income tax purposes) 10 11 If line 8 is less than line 9 and less than $1 million, enter -0- on this line and skip lines 12 through 21 11 12 If line 8 is more than line 10, enter total gross income (as computed for income tax purposes) 12 13 Total adjusted gross foreign base company income and insurance income (enter the greater of line 8 or line 12) 13 14 Adjusted net foreign personal holding company income: a Enter amount from line 2 14a b Expenses directly related to amount on line 2 14b c Subtract line 14b from line 14a 14c d Related person interest expense (see section 954(b)(5)) 14d e Other expenses allocated and apportioned to the amount on line 2 under section 954(b)(5) 14e f Net foreign personal holding company income. Subtract the sum of lines 14d and 14e from line 14c 14f g Net foreign personal holding company income excluded under high-tax exception 14g h Subtract line 14g from line 14f 14h 15 Adjusted net foreign base company sales income: a Enter amount from line 3 15a b Expenses allocated and apportioned to the amount on line 3 under section 954(b)(5) 15b c Net foreign base company sales income. Subtract line 15b from line 15a 15c d Net foreign base company sales income excluded under high-tax exception 15d e Subtract line 15d from line 15c 15e 16 Adjusted net foreign base company services income: a Enter amount from line 4 16a b Expenses allocated and apportioned to line 4 under section 954(b)(5) 16b c Net foreign base company services income. Subtract line 16b from line 16a 16c d Net foreign base company services income excluded under high-tax exception 16d e Subtract line 16d from line 16c 16e

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Worksheet A (continued) (See instructions.) 17 Adjusted net foreign base company oil-related income: a Enter amount from line 5 17a b Expenses allocated and apportioned to line 5 under section 954(b)(5) 17b c Subtract line 17b from line 17a 17c 18 Adjusted net full inclusion foreign base company income: a Enter the excess, if any, of line 12 over line 8 18a b Expenses allocated and apportioned under section 954(b)(5) 18b c Net full inclusion foreign base company income. Subtract line 18b from line 18a 18c d Net full inclusion foreign base company income excluded under high-tax exception 18d e Subtract line 18d from line 18c 18e 19 Adjusted net foreign base company income. Add lines 14h, 15e, 16e, 17c, and 18e 19 20 Adjusted net insurance income (other than related person insurance income): a Enter amount from line 7 (other than related person insurance income) 20a b Expenses allocated and apportioned to the amount from line 7 under section 953 20b c Net insurance income. Subtract line 20b from line 20a 20c d Net insurance income excluded under high-tax exception 20d e Subtract line 20d from line 20c 20e 21 Adjusted net related person insurance income: a Enter amount from line 7 that is related person insurance income 21a b Expenses allocated and apportioned to related person insurance income under section 953 21b c Net related person insurance income. Subtract line 21b from line 21a 21c d Net related person insurance income excluded under high-tax exception 21d e Subtract line 21d from line 21c 21e 22 International boycott income (section 952(a)(3)) 22 23 lllegal bribes, kickbacks, and other payments (section 952(a)(4)) 23 24 lncome described in section 952(a)(5) (see instructions) 24 25 Subpart F income before application of sections 952(b) and (c) and section 959(b). Add lines 19, 20e, 21e, and 22 through 24 25 26 Enter portion of line 25 that is U.S. source income effectively connected with a U.S. trade or business (section 952(b)) 26 27 Exclusions under section 959(b) 27 28 Total subpart F income. Subtract the sum of lines 26 and 27 from line 25 28 29 Current E&P 29 30 Enter the smaller of line 28 or line 29 30 31 Shareholder’s pro rata share of line 30 31 32 Shareholder’s pro rata share of export trade income 32 33 Subtract line 32 from line 31 33 34 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 33 34 35 Dividends paid to any other person with respect to your stock during the tax year 35 36 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 33 36 37 Enter the smaller of line 35 or line 36 37 38a Shareholder’s pro rata share of subpart F income. Subtract line 37 from line 34 38a b Translate the amount on line 38a from functional currency to U.S. dollars at the average exchange rate. See section 989(b). Enter the result here and on line 1, Schedule I 38b

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base company income or insurance value of the corporation, is owned (directly operations, then, instead of applying the income, whichever is appropriate. In this or indirectly under the principles of section international boycott factor, the addition to case, enter total gross income (for income 883(c)(4)) by persons who are (directly or subpart F income is the amount tax purposes) on line 12. Otherwise, enter indirectly) insured under any policy of specifically from the operations in which zero. insurance or reinsurance issued by the there was participation in or cooperation corporation or who are related persons to with an international boycott. See Lines 14g, 15d, 16d, 18d, 20d, and 21d. any such person; Schedule B (Form 5713). Exception for certain income subject to high foreign taxes. Foreign base The related person insurance income Line 23. Illegal bribes, kickbacks, and company income and insurance income (determined on a gross basis) of the other payments. Enter the total of any does not include any item of income corporation for the tax year is less than illegal bribes, kickbacks, or other received by a CFC if the taxpayer 20% of its insurance income for the tax payments (within the meaning of section establishes that such income was subject year determined without regard to the 162(c)) paid by or on behalf of the to an effective rate of income tax imposed provisions of section 953(a)(1) that limit corporation, directly or indirectly, to an by a foreign country that is greater than insurance income to income from official, employee, or agent of a 90% of the maximum rate of tax specified countries other than the country in which government. in section 11. This rule does not apply to the corporation was created or organized; Line 24. Income described in section foreign base company oil-related income. or 952(a)(5). The income of a CFC derived For more information, see section 954(b) The corporation: from any foreign country during any period (4) and Regulations section 1.954-1(d)(1). 1. Elects to treat its related person insurance income for the tax year as during which section 901(j) applies to such Line 20. Adjusted net insurance in- income effectively connected with the foreign country will be deemed to be come. In determining a shareholder's pro conduct of a trade or business in the income to the U.S. shareholders of such rata share of the subpart F income of a United States; CFC. As of the date these instructions CFC, insurance income is any income: were revised, section 901(j) applied to: That is attributable to the issuing (or 2. Elects to waive all treaty benefits Cuba, Iran, North Korea, Sudan, and reinsuring) of any insurance or annuity (other than from section 884) for related Syria. person insurance income; and contract: Line 26. Exclusion of U.S. income. 3. Meets any requirement the IRS 1. For property in, liability from an Subpart F income does not include any may prescribe to ensure that any tax on activity in, or for the lives or health of U.S. source income (which, for these such income is paid. residents of a country other than the purposes, includes all carrying charges country under the laws of which the CFC This election will not be effective if the and all interest, dividends, royalties, and is created or organized or corporation was a disqualified corporation other investment income received or 2. For risks not described in 1 above, (as defined in section 953(c)(3)(E)) for the accrued by a FSC) that is effectively resulting from any arrangement in which tax year for which the election was made connected with a CFC's conduct of a trade another corporation receives a or for any prior tax year beginning after or business in the United States unless substantially equal amount of premiums or 1986. See section 953(c)(3)(D) for special that item is exempt from taxation (or is other consideration for issuing (or rules for this election. subject to a reduced rate of tax) pursuant reinsuring) a contract described in 1 to a treaty obligation of the United States Mutual life insurance . The above. or the Code. related person insurance income rules That would, subject to the modifications also apply to mutual life insurance Line 29. Current E&P. A CFC's subpart provided in sections 953(b)(1) and 953(b) companies under regulations prescribed F income is limited to its current year E&P, (2), be taxed under subchapter L by the Secretary. For these purposes, computed under the special rule of section (insurance company tax) if such income policyholders must be treated as 952(c)(3). The amount included in the were income of a domestic insurance shareholders. gross income of a U.S. shareholder of a company. CFC under section 951(a)(1)(A)(i) for any Line 22. International boycott income. tax year and attributable to a qualified Line 21. Adjusted net related person If a CFC or a member of a controlled activity must be reduced by the insurance income. In determining a group (within the meaning of section shareholder's pro rata share of any shareholder's pro rata share of the subpart 993(a)(3)) that includes the CFC has qualified deficit (see section 952(c)(1)(B)). F income of a CFC, related person operations in, or related to, a country (or insurance income is any insurance income with the government, a company, or a Worksheet B (within the meaning of section 953(a)) national of a country) that requires attributable to a policy of insurance or participation in or cooperation with an Use Worksheet B (on page 12) to reinsurance for which the person insured international boycott as a condition of determine a U.S. shareholder's pro rata (directly or indirectly) is a U.S. shareholder doing business within such country or with share of earnings of a CFC invested in (as defined in section 953(c)(1)(A)) in a the government, company, or national of U.S. property that is subject to tax. Only CFC, or a related person (as defined in that country, a portion of the CFC's earnings of a CFC not distributed or section 953(c)(6)) to such a shareholder. income is included in subpart F income. otherwise previously taxed are subject to In such case, the pro rata share referred to The amount included is determined by these rules. Thus, the amount of above is to be determined under the rules multiplying the CFC's income (other than previously untaxed earnings limits the of section 953(c)(5). income included under section 951 and section 956 inclusion. A CFC's investment U.S. source effectively connected in U.S. property in excess of this limit will Exceptions. The above definition does business income described in section not be included in the of not apply to any foreign corporation if: 952(b)) by the international boycott factor. the CFC's U.S. shareholders. At all times during the foreign This factor is a fraction determined on Further, U.S. shareholders are only corporation's tax year, less than 20% of Schedule A (Form 5713). the total combined voting power of all taxed on earnings invested in U.S. classes of stock of the corporation entitled Special rule. If the shareholder of a CFC property to the extent the investments to vote, and less than 20% of the total can clearly demonstrate that the income exceed the CFC's previously taxed earned for the tax year is from specific earnings. The balances in the previously

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Worksheet B—U.S. Shareholder’s Pro Rata Share of Earnings of a CFC Invested in U.S. Property Enter the amounts on lines 1 through 16 in functional currency. 1 Amount of U.S. property (as defined in sections 956(c) and (d)) held (directly or indirectly) by the CFC as of the close of: a The first quarter of the tax year 1a b The second quarter of the tax year 1b c The third quarter of the tax year 1c d The fourth quarter of the tax year 1d 2 Number of quarter-ends the foreign corporation was a CFC during the tax year ᮣ 2 3 Average amount of U.S. property held (directly or indirectly) by the CFC as of the close of each quarter of the tax year. (Add lines 1a through 1d. Divide this amount by the number on line 2.) 3 4 U.S. shareholder’s pro rata share of the amount on line 3 4 5 U.S. shareholder’s earnings and profits described in section 959(c)(1)(A) after reductions (if any) for current year distributions 5 6 Subtract line 5 from line 4 6 7 Applicable earnings: a Current earnings and profits 7a b Line 7a plus accumulated earnings and profits 7b 8 Enter the greater of line 7a or line 7b 8 9 Distributions made by the CFC during the tax year 9 10 Subtract line 9 from line 8 10 11 Earnings and profits described in section 959(c)(1) 11 12 Subtract line 11 from line 10 12 13 U.S. shareholder’s pro rata share of the amount on line 12 13 14 U.S. shareholder’s earnings invested in U.S. property. (Enter the smaller of line 6 or line 13) 14 15 Amount on line 14 that is excluded from the U.S. shareholder’s gross income under section 959(a)(2) 15 16 Subtract line 15 from line 14 16 17 Translate the amount on line 16 from functional currency to U.S. dollars at the year-end spot rate (as provided in section 989(b)). Enter the result here and on line 2 of Schedule I 17 taxed accounts of prior section 956 Worksheet B, the amount taken into during which the foreign corporation was a inclusions (see section 959(c)(1)(A)) and account with respect to U.S. property is its CFC. current or prior subpart F inclusions (see adjusted basis for earnings and profits section 959(c)(2)) reduce what would purposes, reduced by any liability the Schedule J otherwise be the current section 956 property is subject to. See sections 956(c) Use Schedule J to report accumulated inclusion. and (d) for the definition of U.S. property. E&P, in functional currency, computed The amount of U.S. property held (directly under sections 964(a) and 986(b). Note. The previously taxed accounts or indirectly) by the CFC does not include should be adjusted to reflect any any item that was acquired by the foreign Reference ID number. Use the reclassification of subpart F inclusions that corporation before it became a CFC, reference ID number shown on Form reduced prior section 956 or 956A except for the property acquired before 5471, line 1b(2). inclusions (see section 959(a)(2) and the foreign corporation became a CFC Column (a) Schedule J). that exceeds the applicable earnings (as defined in section 956(b)) accumulated Use column (a) to report the opening Distributions are also taken into during periods before it became a CFC. balance, current year additions and account before the section 956 inclusion is subtractions, and the closing balance in determined. Distributions generally are If the foreign corporation ceases to be the foreign corporation's post-1986 treated as coming first from (and thus a CFC during the tax year: undistributed earnings pool. reducing the balances of) the previously The determination of the U.S. taxed accounts. Thus, the U.S. shareholder's pro rata share will be made Note. Line 3 (E&P as of the close of the shareholders must: based upon the stock owned (within the tax year, before actual or deemed 1. Compute the current subpart F meaning of section 958(a)) by the U.S. distributions during the year) is the inclusion (potentially increasing that shareholder on the last day during the tax denominator of the deemed-paid credit previously taxed account); year in which the foreign corporation was fraction under section 902(c)(1) used for foreign purposes. 2. Take into account current a CFC; distributions (potentially reducing the The CFC's U.S. property for the taxable Column (b) previously taxed and untaxed accounts); year will be determined only by taking into Use column (b) to report the aggregate and account quarters ending on or before such last day (and investments in U.S. property amount of the foreign corporation's 3. Compute the current section 956 as of the close of subsequent quarters pre-1987 section 964(a) E&P accumulated inclusion (potentially increasing or should be recorded as zero on line 1); and since 1962 and not previously distributed reclassifying the previously taxed or deemed distributed. These amounts are accounts). In determining applicable earnings, current earnings and profits will include figured in U.S. dollars using the rules of U.S. property is measured on a only earnings and profits that are allocable Regulations sections 1.964-1(a) through quarterly average basis. For purposes of (on a pro rata basis) to the part of the year (e), translated into the foreign

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Worksheet C—U.S. Shareholder’s Pro Rata Share of Previously Excluded Subpart F Income of a CFC Withdrawn From Qualified Investments in Less Developed Countries and From Qualified Investments in Foreign Base Company Shipping Operations Enter the amounts on lines 1 through 6a in functional currency.

1 Decrease in qualified investments in less developed countries (see Regulations section 1.955-1(b)(1)) and foreign base company shipping operations (see Regulations section 1.955A-1(b)(1)) 1 2 Limitation (see Regulations section 1.955-1(b)(2)): a Enter the sum of E&P for the tax year and E&P accumulated for prior tax years beginning after 1962 2a b Enter the sum of amounts invested in less developed countries or foreign base company shipping operations and excluded from foreign base company income for all prior tax years, minus the sum of such amounts withdrawn for such years (see Regulations section 1.955-1(b)(2)(i)) 2b 3 Enter the smaller of line 2a or line 2b 3 4 Previously excluded subpart F income withdrawn for the tax year (enter the smaller of line 1 or line 3) 4 5 U.S. shareholder’s pro rata share of line 4 (see Regulations section 1.955-1(c)) 5 6a Divide the number of days in the tax year that the foreign corporation was a CFC by the number of days in the tax year and multiply the result by line 5 6a b Translate the amount on line 6a from functional currency to U.S. dollars at the average exchange rate. See section 989(b). Enter the result here and on line 3, Schedule I 6b

Worksheet D—U.S. Shareholder’s Pro Rata Share of Previously Excluded Export Trade Income of a CFC Withdrawn From Investment in Export Trade Assets Enter the amounts on lines 1 through 7a in functional currency. 1 Decrease in investments of the CFC in export trade assets (see Regulations section 1.970-1(d)(3)) 1 2 U.S. shareholder’s pro rata share of line 1 2 3 U.S. shareholder’s pro rata share of the sum of E&P of the CFC for the tax year and E&P accumulated for prior tax years beginning after 1962 (see Regulations section 1.970-1(c)(2)(ii)) 3 4 Limitation under section 970(b) (see Regulations section 1.970-1(c)(2)(i)): a U.S. shareholder’s pro rata share of the sum of the amounts by which the CFC’s subpart F income for prior tax years was reduced under section 970(a) 4a b U.S. shareholder’s pro rata share of the sum of the amounts that were not included in subpart F income of the CFC for prior tax years because of Regulations section 1.972-1 4b c Add lines 4a and 4b 4c d U.S. shareholder’s pro rata share of the sum of the amounts that were previously included in his or her gross income for prior tax years under section 951(a)(1)(A)(ii) because of section 970(b) 4d 5 Subtract line 4d from line 4c 5 6 Enter the smallest of line 2, 3, or 5 6 7a Divide the number of days in the tax year that the foreign corporation was a CFC by the number of days in the tax year and multiply the result by line 6 7a b Translate the amount on line 7a from functional currency to U.S. dollars at the average exchange rate. See section 989(b). Enter the result here and on line 4, Schedule I 7b corporation's functional currency dollar PTI should be translated into the excess passive assets (section 959(c)(1) according to Notice 88-70, 1988-2 C.B. foreign corporation's functional currency (B) amounts) accumulated in tax years of 369. using the rules of Notice 88-70 and added foreign corporations beginning after to post-1986 amounts in the appropriate September 30, 1993, and before January Column (c) PTI category. 1, 1997. Use column (c) to report the running Include in column (c)(i) PTI attributable Include in column (c)(iii) PTI attributable balance of the foreign corporation's to, or reclassified as, investments in U.S. to subpart F income net of any previously taxed earnings and profits property (section 959(c)(1)(A) amounts). reclassifications (section 959(c)(2) (PTI), or section 964(a) E&P accumulated Include in column (c)(ii) PTI attributable amounts). since 1962 that have resulted in deemed to, or reclassified as, earnings invested in inclusions under subpart F. Pre-1987 U.S.

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Column (d) netting of payments due and owed). See Column (e). Enter the date the Regulations section 1.482-7(1)(i). The Use column (d) to report the opening and shareholder acquired (whether in one or corporation is required to complete line 5 closing balance of the foreign more transactions) an additional 10% or only if the corporation itself incurred corporation's accumulated E&P. This more (in value or voting power) of the intangible development costs. If the amount is the sum of post-1986 outstanding stock of the foreign corporation does not itself incur intangible undistributed earnings, pre-1987 section corporation. development costs, then it should only 964(a) E&P not previously taxed, and PTI. report cost sharing transaction payments Part II Line 1. Enter the balances for each made on line 17. Section A—General Shareholder column at the beginning of the tax year. If there is a difference between last year's Note. The term “cost sharing transaction” Information ending balance on Schedule J, line 7, and is not limited to transactions that occurred If the shareholder's latest tax return was this year's beginning balance on on or after January 5, 2009, or filed electronically, enter “e-filed” in Schedule J, line 1, attach an explanation. transactions that occur pursuant to a cost column (b)(3) instead of a service center. sharing arrangement that was not in effect before January 5, 2009. See Regulations Schedule M Section C—Acquisition of Stock Every U.S. person described in Category sections 1.482-7(m)(1) and (2)(i). Section C is completed by shareholders 4 must file Schedule M to report the Lines 9 and 21. Report on these lines who are completing Schedule O because transactions that occurred during the dividends received and paid by the foreign they have acquired sufficient stock in a foreign corporation's annual accounting corporation not previously taxed under foreign corporation. If the shareholder period ending with or within the U.S. subpart F in the current year or in any prior acquired the stock in more than one person's tax year. year. transaction, use a separate line to report If a U.S. corporation that owns stock in Lines 25 and 26. Report on these lines each transaction. a foreign corporation is a member of a the largest outstanding balances during Column (d). Enter the method of consolidated group, list the common the year of gross amounts borrowed from, acquisition (e.g., purchase, gift, bequest, parent as the U.S. person filing and gross amounts loaned to, the related trade). Schedule M. parties described in columns (b) through (f). Do not enter aggregate cash flows, Column (e)(2). Enter the number of Important. In translating the amounts year-end loan balances, average shares acquired indirectly (within the from functional currency to U.S. dollars, balances, or net balances. Do not include meaning of section 958(a)(2)) by the use the average exchange rate for the open account balances resulting from shareholder listed in column (a). foreign corporation's tax year. See section sales and purchases reported under other Column (e)(3). Enter the number of 989(b). Report the exchange rate in the items listed on Schedule M that arise and shares constructively owned (within the entry space provided at the top of are collected in full in the ordinary course meaning of section 958(b)) by the Schedule M using the “divide-by of business. convention” specified under Reporting shareholder listed in column (a). Exchange Rates on Form 5471, earlier. Accrued payments and receipts. A corporation that uses an accrual method Section D—Disposition of Stock Reference ID number. Use the of accounting must use accrued payments reference ID number shown on Form and accrued receipts for purposes of Section D must be completed by 5471, line 1b(2). computing the total amount to enter on shareholders who dispose of their interest each line of Schedule M. (in whole or in part) in a foreign Lines 4 and 16. Report on these lines corporation. platform contribution transaction payments received and paid by the foreign Schedule O Column (d). Enter the method of corporation (without giving effect to any Schedule O is used to report the disposition (e.g., sale, bequest, gift, netting of payments due and owed). See organization or reorganization of a foreign trade). Regulations section 1.482-7(b)(1)(ii). The corporation and the acquisition or Example. In 1994, Mr. Jackson, a U.S. corporation is required to complete both disposition of its stock. citizen, purchased 10,000 shares of lines only if the corporation provides a common stock of foreign corporation X. platform contribution to other controlled Every U.S. citizen or resident described in Category 2 must complete Part I. Every The purchase represented 10% participants and is required to make ownership of the foreign corporation. platform contribution transaction U.S. person described in Category 3 must payments to other controlled participants complete Part II. On July 1, 2012, Mr. Jackson made a gift of 5,000 shares of foreign corporation that provide a platform contribution to See Regulations section 1.6046-1(i) for X to his son, John. Because Mr. Jackson other controlled cost sharing arrangement rules on determining when U.S. persons has reduced his holding in the foreign participants. constructively own stock of a foreign corporation, he is required to complete corporation and therefore are subject to Form 5471 and Schedule O. To show the Note. The term “platform contribution the section 6046 filing requirements. transaction” is not limited to transactions required information about the disposition, that occurred on or after January 5, 2009, Reference ID number. Use the Mr. Jackson completes Section D as or transactions that occur pursuant to a reference ID number shown on Form follows: cost sharing arrangement that was not in 5471, line 1b(2). Enters his name in column (a). effect before January 5, 2009. See Part I Enters “common” in column (b). Regulations sections 1.482-7m)(1) and (2) Enters “July 1, 2012” in column (c). (i). Column (d). Enter the date the Enters “gift” in column (d). shareholder first acquired 10% or more (in Enters “5,000” in column (e)(1). Lines 5 and 17. Report on these lines value or voting power) of the outstanding cost sharing transaction payments Enters “-0-” in column (f) because the stock of the foreign corporation. received and paid by the foreign disposition was by gift. corporation (without giving effect to any

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Enters the name and address of his reorganization prior to that date (if it is chart if the foreign corporation is a son, John, in column (g). within the last 4 years). member of a chain of corporations, and to indicate if he is a 10% or more Example for Item (c). Mr. Lyons, a U.S. shareholder in any of those corporations. Section F—Additional Information person, acquires a 10% ownership in foreign corporation F. F is the 100% owner Mr. Lyons would prepare a list showing Item (b). List the date of any of two foreign corporations, FI and FJ. F is the corporations as follows: reorganization of the foreign corporation also a 50% owner of foreign corporation Corporation W that occurred during the last 4 years while FK. In addition, F is 90% owned by foreign Corporation F any U.S. person held 10% or more in corporation W. Mr. Lyons does not own Corporation FI value or vote (directly or indirectly) of the any of the stock of corporation W. Corporation FJ corporation's stock. If there is more than Corporation FK one such date, use the most recent date. Mr. Lyons completes and files Form However, do not enter a date for which 5471 and Schedule O for the corporations Then Mr. Lyons is required to indicate that information was reported in Schedule E. in which he is a 10% or more shareholder. he is a 10% or more shareholder in Instead, enter the date (if any) of any Mr. Lyons is also required to submit a corporations F, FI, and FJ.

Paperwork Reduction Act Notice. We ask for the information on this form to unless the form displays a valid OMB depending on individual circumstances. carry out the Internal Revenue laws of the control number. Books or records relating The estimated burden for individual United States. You are required to give us to a form or its instructions must be taxpayers filing this form is approved the information. We need it to ensure that retained as long as their contents may under OMB control number 1545-0074 you are complying with these laws and to become material in the administration of and is included in the estimates shown in allow us to figure and collect the right any Internal Revenue law. Generally, tax the instructions for their individual income amount of tax. returns and return information are tax return. The estimated burden for all You are not required to provide the confidential, as required by section 6103. other taxpayers who file this form is shown information requested on a form that is The time needed to complete and file below. subject to the Paperwork Reduction Act this form and related schedules will vary

Learning about the Preparing and sending Form Recordkeeping law or the form the form to the IRS 5471 82 hr., 45 min. 16 hr., 14 min. 24 hr., 17 min. Sch. J (5471) 3 hr., 49 min. 1 hr., 29 min. 1 hr., 37 min. Sch. M (5471) 32hr., 3 min. 12min. 43 min. Sch. O (5471) 10 hr., 45 min. 24 min. 35 min.

If you have comments concerning the related schedules simpler, we would be instructions for the tax return with which accuracy of these time estimates or happy to hear from you. See the this form is filed. suggestions for making this form and

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Form 5471 principal business activity codes are based on the North retains title to the product, the company is considered a American Industry Classification System. manufacturer and must use one of the manufacturing Codes for Principal Business Activity codes (311110-339900). Using the list of activities and codes below, This list of principal business activities and their determine from which activity the company derives the Enter on page 1, item 1f, the six digit code selected associated codes is designed to classify an enterprise largest percentage of its “total receipts.” If the company from the list below. In item 1g, enter a brief description by the type of activity in which it is engaged to facilitate purchases raw materials and supplies them to a of the company's business activity. the administration of the Internal Revenue Code. These subcontractor to produce the finished product, but Agriculture, Forestry, Fishing 238300 Building Finishing Contractors 325900 Other Chemical Product & 336990 Other Transportation Equipment (including drywall, insulation, Preparation Mfg Mfg and Hunting painting, wallcovering, flooring, Plastics and Rubber Products Furniture and Related Product Crop Production tile, & finish carpentry) Manufacturing Manufacturing 111100 Oilseed & Grain Farming 238900 Other Specialty Trade 326100 Plastics Product Mfg 337000 Furniture & Related Product Contractors (including site Manufacturing 111210 Vegetable & Melon Farming preparation) 326200 Rubber Product Mfg (including potatoes & yams) Nonmetallic Mineral Product Miscellaneous Manufacturing 111300 Fruit & Tree Nut Farming Manufacturing Manufacturing 339110 Medical Equipment & Supplies 111400 Greenhouse, Nursery, & Food Manufacturing 327100 Clay Product & Refractory Mfg Mfg Floriculture Production 311110 Animal Food Mfg 327210 Glass & Glass Product Mfg 339900 Other Miscellaneous Manufacturing 111900 Other Crop Farming (including 311200 Grain & Oilseed Milling 327300 Cement & Concrete Product Mfg tobacco, cotton, sugarcane, hay, Wholesale Trade peanut, sugar beet & all other 311300 Sugar & Confectionery Product 327400 Lime & Gypsum Product Mfg crop farming) Mfg 327900 Other Nonmetallic Mineral Merchant Wholesalers, Durable Goods Animal Production 311400 Fruit & Vegetable Preserving & Product Mfg 423100 Motor Vehicle & Motor Vehicle Specialty Food Mfg 112111 Beef Cattle Ranching & Farming Primary Metal Manufacturing Parts & Supplies 311500 Dairy Product Mfg 112112 Cattle Feedlots 331110 Iron & Steel Mills & Ferroalloy 423200 Furniture & Home Furnishings 311610 Animal Slaughtering and Mfg 112120 Dairy Cattle & Milk Production 423300 Lumber & Other Construction Processing 331200 Steel Product Mfg from Materials 112210 Hog & Pig Farming 311710 Seafood Product Preparation & Purchased Steel 423400 Professional & Commercial 112300 Poultry & Egg Production Packaging 331310 Alumina & Aluminum Production Equipment & Supplies 112400 Sheep & Goat Farming 311800 Bakeries, Tortilla & Dry Pasta & Processing 423500 Metal & Mineral (except 112510 Aquaculture (including shellfish & Mfg 331400 Nonferrous Metal (except Petroleum) finfish farms & hatcheries) 311900 Other Food Mfg (including Aluminum) Production & 423600 Household Appliances and 112900 Other Animal Production coffee, tea, flavorings & Processing Electrical & Electronic Goods seasonings) Forestry and Logging 331500 Foundries 423700 Hardware, & Plumbing & Heating Beverage and Tobacco Product Fabricated Metal Product Equipment & Supplies 113110 Timber Tract Operations Manufacturing Manufacturing 423800 Machinery, Equipment, & 113210 Forest Nurseries & Gathering of 312110 Soft Drink & Ice Mfg Forest Products 332110 Forging & Stamping Supplies 312120 Breweries 113310 Logging 332210 Cutlery & Handtool Mfg 423910 Sporting & Recreational Goods & 312130 Wineries Supplies Fishing, Hunting and Trapping 332300 Architectural & Structural Metals 312140 Distilleries Mfg 423920 Toy & Hobby Goods & Supplies 114110 Fishing 312200 Tobacco Manufacturing 332400 Boiler, Tank, & Shipping 423930 Recyclable Materials 114210 Hunting & Trapping Textile Mills and Textile Product Mills Container Mfg 423940 Jewelry, Watch, Precious Stone, Support Activities for Agriculture and 332510 Hardware Mfg & Precious Metals Forestry 313000 Textile Mills 314000 Textile Product Mills 332610 Spring & Wire Product Mfg 423990 Other Miscellaneous Durable 115110 Support Activities for Crop Goods Production (including cotton Apparel Manufacturing 332700 Machine Shops; Turned Product; & Screw, Nut, & Bolt Mfg Merchant Wholesalers, Nondurable ginning, soil preparation, 315100 Apparel Knitting Mills planting, & cultivating) 332810 Coating, Engraving, Heat Goods 315210 Cut & Sew Apparel Contractors 115210 Support Activities for Animal Treating, & Allied Activities 424100 Paper & Paper Products Production 315220 Men's & Boys' Cut & Sew 332900 Other Fabricated Metal Product 424210 Drugs & Druggists' Sundries Apparel Mfg 115310 Support Activities For Forestry Mfg 424300 Apparel, Piece Goods, & Notions 315240 Women's, Girls' and Infants Cut Machinery Manufacturing Mining & Sew Apparel Mfg 424400 Grocery & Related Products 333100 Agriculture, Construction, & 424500 Product Raw Materials 211110 Oil & Gas Extraction 315280 Other Cut & Sew Apparel Mfg Mining Machinery Mfg 424600 Chemical & Allied Products 212110 Coal Mining 315990 Apparel Accessories & Other 333200 Industrial Machinery Mfg Apparel Mfg 424700 Petroleum & Petroleum Products 212200 Metal Ore Mining 333310 Commercial & Service Industry Leather and Allied Product Machinery Mfg 424800 Beer, Wine, & Distilled Alcoholic 212310 Stone Mining & Quarrying Manufacturing Beverages 212320 Sand, Gravel, Clay, & Ceramic & 333410 Ventilation, Heating, 316110 Leather & Hide Tanning & Air-Conditioning, & Commercial 424910 Farm Supplies Refractory Minerals Mining & Finishing Quarrying Refrigeration Equipment Mfg 424920 Book, Periodical, & Newspapers 316210 Footwear Mfg (including rubber 333510 Metalworking Machinery Mfg 424930 Flower, Nursery Stock, & Florists' 212390 Other Nonmetallic Mineral & plastics) Mining & Quarrying 333610 Engine, Turbine & Power Supplies 316990 Other Leather & Allied Product Transmission Equipment Mfg 424940 Tobacco & Tobacco Products 213110 Support Activities for Mining Mfg 333900 Other General Purpose 424950 Paint, Varnish, & Supplies Wood Product Manufacturing Utilities Machinery Mfg 424990 Other Miscellaneous Nondurable 221100 Electric Power Generation, 321110 Sawmills & Wood Preservation Computer and Electronic Product Goods Transmission & Distribution 321210 Veneer, Plywood, & Engineered Manufacturing Wholesale Electronic Markets and 221210 Natural Gas Distribution Wood Product Mfg 334110 Computer & Peripheral Agents and Brokers 221300 Water, Sewage & Other Systems 321900 Other Wood Product Mfg Equipment Mfg 425110 Business to Business Electronic 221500 Combination Gas & Electric Paper Manufacturing 334200 Communications Equipment Mfg Markets Construction 322100 Pulp, Paper, & Paperboard Mills 334310 Audio & Video Equipment Mfg 425120 Wholesale Trade Agents & 322200 Converted Paper Product Mfg 334410 Semiconductor & Other Brokers Construction of Buildings Printing and Related Support Activities Electronic Component Mfg Retail Trade 236110 Residential Building Construction 323100 Printing & Related Support 334500 Navigational, Measuring, Motor Vehicle and Parts Dealers 236200 Nonresidential Building Activities Electromedical, & Control Instruments Mfg 441110 New Car Dealers Construction Petroleum and Coal Products Heavy and Civil Engineering Manufacturing 334610 Manufacturing & Reproducing 441120 Used Car Dealers Magnetic & Optical Media Construction 324110 Petroleum Refineries (including 441210 Recreational Vehicle Dealers 237100 Utility System Construction integrated) Electrical Equipment, Appliance, and 441222 Boat Dealers Component Manufacturing 237210 Land Subdivision 324120 Asphalt Paving, Roofing, & 441228 Motorcycle, ATV, and All Other 237310 Highway, Street, & Bridge Saturated Materials Mfg 335100 Electric Lighting Equipment Mfg Motor Vehicle Dealers Construction 324190 Other Petroleum & Coal 335200 Household Appliance Mfg 441300 Automotive Parts, Accessories, 237990 Other Heavy & Civil Engineering Products Mfg 335310 Electrical Equipment Mfg & Tire Stores Construction Chemical Manufacturing 335900 Other Electrical Equipment & Furniture and Home Furnishings Stores Specialty Trade Contractors 325100 Basic Chemical Mfg Component Mfg 442110 Furniture Stores 238100 Foundation, Structure, & Building 325200 Resin, Synthetic Rubber, & Transportation Equipment 442210 Floor Covering Stores Exterior Contractors (including Artificial & Synthetic Fibers & Manufacturing 442291 Window Treatment Stores framing carpentry, masonry, Filaments Mfg 336100 Motor Vehicle Mfg glass, roofing, & siding) 442299 All Other Home Furnishings 325300 Pesticide, Fertilizer, & Other 336210 Motor Vehicle Body & Trailer Mfg Stores 238210 Electrical Contractors Agricultural Chemical Mfg 336300 Motor Vehicle Parts Mfg Electronics and Appliance Stores 238220 Plumbing, Heating, & 325410 Pharmaceutical & Medicine Mfg 336410 Aerospace Product & Parts Mfg 443141 Household Appliance Stores Air-Conditioning Contractors 325500 Paint, Coating, & Adhesive Mfg 336510 Railroad Rolling Stock Mfg 443142 Electronics Stores (including 238290 Other Building Equipment 325600 Soap, Cleaning Compound, & Contractors 336610 Ship & Boat Building Audio, Video, Computer, and Toilet Preparation Mfg Camera Stores)

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Form 5471 (Continued)

Building Material and Garden 484120 General Freight Trucking, Activities Related to Credit Accounting, Tax Preparation, Equipment and Supplies Dealers Long-distance Intermediation Bookkeeping, and Payroll Services 444110 Home Centers 484200 Specialized Freight Trucking 522300 Activities Related to Credit 541211 Offices of Certified Public 444120 Paint & Wallpaper Stores Transit and Ground Passenger Intermediation (including loan Accountants Transportation brokers, check clearing, & 541213 Tax Preparation Services 444130 Hardware Stores money transmitting) 485110 Urban Transit Systems 541214 Payroll Services 444190 Other Building Material Dealers Securities, Commodity Contracts, and 444200 Lawn & Garden Equipment & 485210 Interurban & Rural Bus Other Financial Investments and 541219 Other Accounting Services Supplies Stores Transportation Related Activities Architectural, Engineering, and Related Food and Beverage Stores 485310 Taxi Service 523110 Investment Banking & Securities Services 445110 Supermarkets and Other 485320 Limousine Service Dealing 541310 Architectural Services Grocery (except Convenience) 485410 School & Employee Bus 523120 Securities Brokerage 541320 Landscape Architecture Services Stores Transportation 523130 Commodity Contracts Dealing 541330 Engineering Services 445120 Convenience Stores 485510 Charter Bus Industry 523140 Commodity Contracts Brokerage 541340 Drafting Services 445210 Meat Markets 485990 Other Transit & Ground 523210 Securities & Commodity 541350 Building Inspection Services Passenger Transportation 445220 Fish & Seafood Markets Exchanges 541360 Geophysical Surveying & 445230 Fruit & Vegetable Markets Pipeline Transportation 523900 Other Financial Investment Mapping Services 445291 Baked Goods Stores 486000 Pipeline Transportation Activities (including portfolio 541370 Surveying & Mapping (except Scenic & Sightseeing Transportation management & investment Geophysical) Services 445292 Confectionery & Nut Stores advice) 445299 All Other Specialty Food Stores 487000 Scenic & Sightseeing 541380 Testing Laboratories Transportation Insurance Carriers and Related 445310 Beer, Wine, & Liquor Stores Activities Specialized Design Services Support Activities for Transportation Health and Personal Care Stores 524140 Direct Life, Health, & Medical 541400 Specialized Design Services 488100 Support Activities for Air (including interior, industrial, 446110 Pharmacies & Drug Stores Insurance & Reinsurance Transportation Carriers graphic, & fashion design) 446120 Cosmetics, Beauty Supplies, & 488210 Support Activities for Rail Computer Systems Design and Related Perfume Stores 524150 Direct Insurance & Reinsurance Transportation (except Life, Health & Medical) Services 446130 Optical Goods Stores 488300 Support Activities for Water Carriers 541511 Custom Computer Programming 446190 Other Health & Personal Care Transportation 524210 Insurance Agencies & Services Stores 488410 Motor Vehicle Towing Brokerages 541512 Computer Systems Design Gasoline Stations 488490 Other Support Activities for Road 524290 Other Insurance Related Services 447100 Gasoline Stations (including Transportation Activities (including third-party 541513 Computer Facilities Management convenience stores with gas) 488510 Freight Transportation administration of insurance and Services Clothing and Clothing Accessories Arrangement pension funds) 541519 Other Computer Related Stores 488990 Other Support Activities for Funds, Trusts, and Other Financial Services 448110 Men's Clothing Stores Transportation Vehicles Other Professional, Scientific, and 448120 Women's Clothing Stores Couriers and Messengers 525100 Insurance & Employee Benefit Technical Services Funds 448130 Children's & Infants' Clothing 492110 Couriers 541600 Management, Scientific, & Stores 525910 Open-End Investment Funds Technical Consulting Services 492210 Local Messengers & Local (Form 1120-RIC) 448140 Family Clothing Stores Delivery 541700 Scientific Research & 525920 Trusts, Estates, & Agency Development Services 448150 Clothing Accessories Stores Warehousing and Storage Accounts 541800 Advertising & Related Services 448190 Other Clothing Stores 493100 Warehousing & Storage (except 525990 Other Financial Vehicles lessors of miniwarehouses & 541910 Marketing Research & Public 448210 Shoe Stores (including mortgage REITs & Opinion Polling self-storage units) closed-end investment funds) 448310 Jewelry Stores 541920 Photographic Services Information “Offices of Bank Holding Companies” and 448320 Luggage & Leather Goods 541930 Translation & Interpretation Stores Publishing Industries (except Internet) “Offices of Other Holding Companies” are located under Management of Services Sporting Goods, Hobby, Book, and 511110 Newspaper Publishers 541940 Veterinary Services Music Stores Companies (Holding Companies) on 511120 Periodical Publishers page 17. 541990 All Other Professional, Scientific, 451110 Sporting Goods Stores 511130 Book Publishers & Technical Services 451120 Hobby, Toy, & Game Stores Real Estate and Rental and 511140 Directory & Mailing List Management of Companies 451130 Sewing, Needlework, & Piece Publishers Leasing Goods Stores (Holding Companies) 511190 Other Publishers Real Estate 451140 Musical Instrument & Supplies 551111 Offices of Bank Holding Stores 511210 Software Publishers 531110 Lessors of Residential Buildings & Dwellings (including equity Companies 451211 Book Stores Motion Picture and Sound Recording Industries REITs) 551112 Offices of Other Holding 451212 News Dealers & Newsstands Companies 512100 Motion Picture & Video Industries 531120 Lessors of Nonresidential General Merchandise Stores (except video rental) Buildings (except Administrative and Support and 452110 Department Stores Miniwarehouses) (including 512200 Sound Recording Industries equity REITs) Waste Management and 452900 Other General Merchandise Broadcasting (except Internet) Stores 531130 Lessors of Miniwarehouses & Remediation Services 515100 Radio & Television Broadcasting Self-Storage Units (including Miscellaneous Store Retailers Administrative and Support Services 515210 Cable & Other Subscription equity REITs) 561110 Office Administrative Services 453110 Florists Programming 531190 Lessors of Other Real Estate 453210 Office Supplies & Stationery Telecommunications Property (including equity REITs) 561210 Facilities Support Services Stores 517000 Telecommunications (including 531210 Offices of Real Estate Agents & 561300 Employment Services 453220 Gift, Novelty, & Souvenir Stores paging, cellular, satellite, cable & Brokers 561410 Document Preparation Services 453310 Used Merchandise Stores other program distribution, 531310 Real Estate Property Managers 561420 Telephone Call Centers 453910 Pet & Pet Supplies Stores resellers, other 531320 Offices of Real Estate Appraisers telecommunications, & internet 561430 Business Service Centers 453920 Art Dealers service providers) 531390 Other Activities Related to Real (including private mail centers & Estate copy shops) 453930 Manufactured (Mobile) Home Data Processing Services Dealers Rental and Leasing Services 561440 Collection Agencies 518210 Data Processing, Hosting, & 453990 All Other Miscellaneous Store Related Services 532100 Automotive Equipment Rental & 561450 Credit Bureaus Retailers (including tobacco, Leasing Other Information Services 561490 Other Business Support Services candle, & trophy shops) 532210 Consumer Electronics & (including repossession services, Nonstore Retailers 519100 Other Information Services Appliances Rental court reporting, & stenotype (including news syndicates, services) 454110 Electronic Shopping & 532220 Formal Wear & Costume Rental libraries, internet publishing & 561500 Travel Arrangement & Mail-Order Houses broadcasting) 532230 Video Tape & Disc Rental 454210 Vending Machine Operators Reservation Services Finance and Insurance 532290 Other Consumer Goods Rental 561600 Investigation & Security Services 454310 Fuel Dealers (including Heating 532310 General Rental Centers Oil and Liquified Petroleum) Depository Credit Intermediation 561710 Exterminating & Pest Control 532400 Commercial & Industrial 454390 Other Direct Selling 522110 Commercial Banking Services Machinery & Equipment Rental & 561720 Janitorial Services Establishments (including 522120 Savings Institutions Leasing door-to-door retailing, frozen 561730 Landscaping Services food plan providers, party plan 522130 Credit Unions Lessors of Nonfinancial Intangible 522190 Other Depository Credit Assets (except copyrighted works) 561740 Carpet & Upholstery Cleaning merchandisers, & coffee-break Services service providers) Intermediation 533110 Lessors of Nonfinancial Nondepository Credit Intermediation Intangible Assets (except 561790 Other Services to Buildings & Transportation and copyrighted works) Dwellings 522210 Credit Card Issuing Warehousing 561900 Other Support Services 522220 Sales Financing Professional, Scientific, and (including packaging & labeling Air, Rail, and Water Transportation 522291 Consumer Lending Technical Services services, & convention & trade 481000 Air Transportation show organizers) 522292 Real Estate Credit (including Legal Services 482110 Rail Transportation mortgage bankers & originators) Waste Management and Remediation 541110 Offices of Lawyers 483000 Water Transportation 522293 International Trade Financing Services 541190 Other Legal Services Truck Transportation 522294 Secondary Market Financing 562000 Waste Management & Remediation Services 484110 General Freight Trucking, Local 522298 All Other Nondepository Credit Intermediation

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The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.

Form 5471 (Continued)

Educational Services Other Ambulatory Health Care Services 713900 Other Amusement & Recreation 811210 Electronic & Precision 621900 Other Ambulatory Health Care Industries (including golf Equipment Repair & 611000 Educational Services (including Services (including ambulance courses, skiing facilities, Maintenance schools, colleges, & universities) services & blood & organ banks) marinas, fitness centers, & 811310 Commercial & Industrial bowling centers) Health Care and Social Hospitals Machinery & Equipment (except Accommodation and Food Automotive & Electronic) Repair Assistance 622000 Hospitals & Maintenance Offices of Physicians and Dentists Nursing and Residential Care Facilities Services 811410 Home & Garden Equipment & 621111 Offices of Physicians (except 623000 Nursing & Residential Care Accommodation Appliance Repair & Maintenance mental health specialists) Facilities 721110 Hotels (except Casino Hotels) & 811420 Reupholstery & Furniture Repair 621112 Offices of Physicians, Mental Social Assistance Motels 811430 Footwear & Leather Goods Health Specialists 624100 Individual & Family Services 721120 Casino Hotels Repair 621210 Offices of Dentists 624200 Community Food & Housing, & 721191 Bed & Breakfast Inns 811490 Other Personal & Household Offices of Other Health Practitioners Emergency & Other Relief 721199 All Other Traveler Goods Repair & Maintenance Services 621310 Offices of Chiropractors Accommodation Personal and Laundry Services 624310 Vocational Rehabilitation 721210 RV (Recreational Vehicle) Parks 812111 Barber Shops 621320 Offices of Optometrists Services & Recreational Camps 812112 Beauty Salons 621330 Offices of Mental Health 624410 Child Day Care Services Practitioners (except Physicians) 721310 Rooming & Boarding Houses 812113 Nail Salons 621340 Offices of Physical, Occupational Arts, Entertainment, and Food Services and Drinking Places 812190 Other Personal Care Services & Speech Therapists, & Recreation 722300 Special Food Services (including (including diet & weight reducing Audiologists food service contractors & centers) Performing Arts, Spectator Sports, and caterers) 621391 Offices of Podiatrists Related Industries 812210 Funeral Homes & Funeral 722410 Drinking Places (Alcoholic Services 621399 Offices of All Other 711100 Performing Arts Companies Miscellaneous Health Beverages) 812220 Cemeteries & Crematories Practitioners 711210 Spectator Sports (including 722511 Full-Service Restaurants sports clubs & racetracks) 812310 Coin-Operated Laundries & Outpatient Care Centers 722513 Limited-Service Restaurants Drycleaners 711300 Promoters of Performing Arts, 621410 Family Planning Centers Sports, & Similar Events 722514 Cafeterias and Buffets 812320 Drycleaning & Laundry Services (except Coin-Operated) 621420 Outpatient Mental Health & 711410 Agents & Managers for Artists, 722515 Snack and Non-alcoholic Substance Abuse Centers Athletes, Entertainers, & Other Beverage Bars 812330 Linen & Uniform Supply 621491 HMO Medical Centers Public Figures Other Services 812910 Pet Care (except Veterinary) 621492 Kidney Dialysis Centers 711510 Independent Artists, Writers, & Services Repair and Maintenance 621493 Freestanding Ambulatory Performers 812920 Photofinishing Surgical & Emergency Centers Museums, Historical Sites, and Similar 811110 Automotive Mechanical & 812930 Parking Lots & Garages Electrical Repair & Maintenance 621498 All Other Outpatient Care Institutions 812990 All Other Personal Services Centers 712100 Museums, Historical Sites, & 811120 Automotive Body, Paint, Interior, & Glass Repair Religious, Grantmaking, Civic, Medical and Diagnostic Laboratories Similar Institutions Professional, and Similar Organizations 811190 Other Automotive Repair & 621510 Medical & Diagnostic Amusement, Gambling, and Recreation 813000 Religious, Grantmaking, Civic, Industries Maintenance (including oil Laboratories change & lubrication shops & car Professional, & Similar Home Health Care Services 713100 Amusement Parks & Arcades washes) Organizations (including 713200 Gambling Industries condominium and homeowners 621610 Home Health Care Services associations)

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