Filing IRS Form 5471 is one of the most demanding compliance tasks in the US tax system. While the main four-page form captures basic corporate data, the heavy lifting happens in the Schedules. These attachments serve as the diagnostic tools the IRS uses to calculate everything from deemed dividends to foreign tax credits.
Following the Tax Cuts and Jobs Act (TCJA) and the more recent One Big Beautiful Bill Act (OBBBA) of 2025, the number and complexity of these schedules have expanded. Below is an exhaustive breakdown of the Form 5471 schedules, categorized by their function and filing requirements.
Key Summary: Form 5471 Schedules
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Form 5471 schedules are the core of IRS reporting for US-owned foreign corporations and Controlled Foreign Corporations (CFCs), calculating deemed income, GILTI, Subpart F income, and foreign tax credits.
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Financial schedules (A, C, F, M) report ownership, income statements, balance sheets, and related-party transactions, with required US dollar conversion and US GAAP adjustments.
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Income and post-TCJA schedules (H, I, I-1, J, P, Q, R) determine E&P, GILTI, previously taxed income (PTEP), and Foreign Tax Credit eligibility, directly impacting shareholder tax liability.
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Failure to properly complete Form 5471 schedules can result in a $10,000 IRS penalty per form, even for dormant corporations, making accurate compliance essential.
Financial & Structural Schedules
Schedule A: Stock of the Foreign Corporation
This schedule tracks the entity’s capitalization. You must list the classes of stock (common vs. preferred) and the total shares outstanding at the beginning and end of the year.
Accuracy is paramount here, as your ownership percentage in the US-owned foreign corporation determines your Filer Category and, subsequently, which other schedules you are required to file.
Schedule C: Income Statement
Schedule C reports the corporation’s profit and loss. Crucially, these figures must be converted from local currency to US Dollars and adjusted to reflect US GAAP (Generally Accepted Accounting Principles) rather than local foreign accounting standards.
Schedule F: Balance Sheet
The balance sheet provides a snapshot of assets, liabilities, and equity. Like Schedule C, it must be reported in US Dollars.
Schedule M: Related Party Transactions
The IRS uses Schedule M to flag potential disguised dividends or tax-evasion schemes. You must report all transactions between the foreign corporation and the US person (or related entities), including:
- Sales and purchases of inventory.
- Loans, commissions, and royalties.
- Interest or dividends paid.
Income & Tax Summaries Schedules
These schedules bridge the gap between the corporation’s earnings and the shareholder’s personal tax liability.
Schedule H: Current Earnings and Profits (E&P)
E&P is a specifically defined tax concept that determines whether a distribution to a shareholder is a taxable dividend or a non-taxable return of capital. Schedule H calculates the current year’s E&P in the corporation’s functional currency.
Schedule I: Summary of Shareholder’s Income
This is arguably the most critical schedule for individuals. It calculates the income that must be deemed distributed to you, even if you didn’t receive any cash. This includes:
- Subpart F Income: Passive income like dividends and interest.
- Section 956: Earnings invested in US property.
Schedule I-1: Information for GILTI
Introduced by the TCJA, this schedule is used to calculate Global Intangible Low-Taxed Income (GILTI). It determines the tested income or tested loss of the Controlled Foreign Corporation (CFC), which eventually flows into your personal Form 8992.
Post-TCJA Schedules
Modern international tax compliance relies on a series of specialized schedules that track historical taxes and earnings pools.
Schedule E & E-1: Taxes Paid or Accrued
These schedules are the gateway to claiming the Foreign Tax Credit (FTC). They track the taxes paid to foreign governments on various baskets of income.
- Schedule E: Reports the actual taxes paid or accrued.
- Schedule E-1: Tracks the taxes deemed paid on earnings and profits, essential for corporate shareholders.
Schedule J: Accumulated E&P
While Schedule H looks at the current year, Schedule J tracks the lifetime accumulated earnings and profits of the Controlled Foreign Corporation (CFC). It classifies E&P into different pools based on when and how they were earned.
Schedule P: Previously Taxed E&P (PTEP)
To prevent double taxation, the IRS uses Schedule P. If you were taxed on GILTI or Subpart F income in a prior year, but the cash is only distributed to you this year, Schedule P ensures you aren’t taxed a second time on the same dollar.
Schedule Q: CFC Income Groups
This schedule groups a CFC’s income and taxes into specific income groups (e.g., Section 951A, Foreign Branch, Passive). This is required for the calculation of the Foreign Tax Credit and the High-Tax Exception, which allows you to exclude certain income from GILTI if it was already taxed at a high rate abroad.
Schedule R: Distributions
Schedule R provides a line-item breakdown of every distribution made by the foreign corporation. It identifies whether the payment came from Previously Taxed E&P (PTEP) or current/accumulated earnings.
Event-Based Schedule
Schedule O: Organization or Reorganization
Schedule O is typically only required for Category 2 and 3 filers. It is triggered when a US person acquires or disposes of a 10% interest in a foreign corporation, or when the corporation undergoes a major reorganization (like a merger or liquidation).
Get Your 5471 Schedules Right
The Form 5471 schedule can be complex, with detailed reporting requirements for foreign entities. Schedule a quick consultation with our tax specialists to simplify the process and ensure compliance.
Which Form 5471 Schedule Apply To You?
| Schedule | Category 3 (10%+ Change) | Category 4 (Control) | Category 5 (CFC Shareholder) |
| A, B, G | Yes | Yes | Yes |
| C, F, M | No | Yes | Yes (Partial) |
| H, J, P | No | Yes | Yes |
| I, I‑1 | No | Yes | Yes |
| Q, R | No | Yes | Yes |
| O | Yes | No | No |
Best Practices for Form 5471 Compliance
- Don’t DIY: The interaction between Schedule J (Accumulated E&P) and Schedule P (PTEP) is so complex that even most standard tax software struggles to automate it correctly.
- Monitor Exchange Rates: Use the IRS Average Annual Exchange Rate for income/expense schedules (C and H) and the Year-End Spot Rate for the balance sheet (F).
- Mind the $10,000 Penalty: The IRS imposes a $10,000 penalty for each late or incomplete Form 5471. If you have multiple foreign corporations, these penalties can bankrupt a small business overnight.
- Dormant Corporations: Even if your foreign company has $0 in assets and income, you may still be required to file a simplified Dormant Form 5471 to avoid the failure-to-file penalty.
