5471, Schedule P Transfer of Property to a Foreign Corporation

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SCHEDULE P
(Form 5471)
(December 2018)

DRAFT AS OF
September 28, 2018
DO NOT FILE
Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations

OMB No. 1545-0704

Attach to Form 5471.
▶ Go to www.irs.gov/Form5471 for instructions and the latest information.
▶

Department of the Treasury
Internal Revenue Service

Identifying number

Name of person filing Form 5471
Name of foreign corporation

Reference ID number (see instructions)

EIN (if any)

a Separate Category (Enter code—see instructions.) . . . . . . . . . . . . . . . . .
b If code 901j is entered on line a, enter the country code for the sanctioned country (see instructions)

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Previously Taxed E&P (see instructions)

Important: Enter amounts in functional
currency.

1a
1b
1c
2
3

4
5
6
7

8
9

(a)
Earnings
Invested in
U.S. Property
(section
959(c)(1)(A))

(b)
Section 965(a)
Inclusion (section
959(c)(1)(A))

(c)
Section
965(b)(4)(A)
(section
959(c)(1)(A))

(d)
(e)
(f)
(g)
Section 951A
Earnings
Subpart F
Section 965(a)
Inclusion (section
Invested in
Income (section Inclusion (section
959(c)(1)(A))
Excess Passive
959(c)(2))
959(c)(2))
Assets (section
959(c)(1)(B))

(h)
Section
965(b)(4)(A)
(section
959(c)(2))

(i)
Section 951A
Inclusion (section
959(c)(2))

(j)
Total

Balance at beginning of year (see
instructions)
Beginning balance adjustments
(attach statement)
Adjusted
beginning
balance
(combine lines 1a and 1b)
Reduction for taxes unsuspended
under anti-splitter rules
E&P attributable to distributions of
previously taxed E&P from lowertier foreign corporation
E&P carried over in nonrecognition
transaction
Other
adjustments
(attach
statement)
Total current and accumulated
E&P (combine lines 1c through 5)
Amounts reclassified to section
959(c)(2) E&P from section 959(c)
(3) E&P
Actual distributions of previously
taxed income
Amounts reclassified to section
959(c)(1) E&P from section 959(c)
(2) E&P

For Paperwork Reduction Act Notice, see instructions.

Cat. No. 49203F

Schedule P (Form 5471) (12-2018)

DRAFT AS OF
September 28, 2018
DO NOT FILE

Schedule P (Form 5471) (12-2018)

Page 2

Previously Taxed E&P (see instructions) (continued)

Important: Enter amounts in functional
currency.

(a)
Earnings
Invested in
U.S. Property
(section
959(c)(1)(A))

(b)
Section 965(a)
Inclusion (section
959(c)(1)(A))

(c)
Section
965(b)(4)(A)
(section
959(c)(1)(A))

(e)
(f)
(g)
(h)
(i)
(d)
Earnings
Subpart F
Section 965(a)
Section
Section 951A
Section 951A
Invested in
Inclusion (section Excess Passive Income (section Inclusion (section
965(b)(4)(A)
Inclusion (section
Assets (section
959(c)(1)(A))
959(c)(2))
959(c)(2))
(section 959(c)(2))
959(c)(2))
959(c)(1)(B))

(j)
Total

10 Amounts included as earnings
invested in U.S. property and
reclassified to section 959(c)(1)
E&P (see instructions)
adjustments
(attach
11 Other
statement)
12 Balance at beginning of next year
(combine lines 6 through 11)

Schedule P (Form 5471) (12-2018)