Form 5471 (Rev. 12-2019)
Page 5
Schedule G Other Information (continued)
Yes No
6
a
Is the filer of this Form 5471 claiming a foreign-derived intangible income deduction (under section 250) with
respect to any amounts listed on Schedule M? . . . . . . . . . . . . . . . . . . . . . .
If “Yes,” complete lines 6b, 6c, and 6d.
b
Enter the amount of gross income derived from sales, leases, exchanges, or other dispositions (but not licenses)
from transactions with the foreign corporation that the filer included in its computation of foreign-derived
deduction eligible income (FDDEI) (see instructions) . . . . . . . . . . . . .
▶
$
c
Enter the amount of gross income derived from a license of property to the foreign corporation that the filer
included in its computation of FDDEI (see instructions) . . . . . . . . . . . .
▶
$
d
Enter the amount of gross income derived from services provided to the foreign corporation that the filer included
in its computation of FDDEI (see instructions) . . . . . . . . . . . . . . .
▶
$
7 During the tax year, was the foreign corporation a participant in any cost sharing arrangement? . . . . . .
8
During the course of the tax year, did the foreign corporation become a participant in any cost sharing arrangement?
9 If the answer to question 7 is “Yes,” was the foreign corporation a participant in a cost sharing arrangement that
was in effect before January 5, 2009? . . . . . . . . . . . . . . . . . . . . . . . . .
10 If the answer to question 7 is “Yes,” did a U.S. taxpayer make any platform contributions as defined under
Regulations section 1.482-7(c) to that cost sharing arrangement during the taxable year? . . . . . . . .
11
If the answer to question 10 is “Yes,” enter the present value of the platform contributions in U.S.
dollars . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
$
12 If the answer to question 10 is “Yes,” check the box for the method under Regulations section 1.482-7(g) used to
determine the price of the platform contribution transaction(s):
Comparable uncontrolled transaction method
Market capitalization method
Income method
Residual profit split method
Acquisition price method
Unspecified methods
13
From April 25, 2014, to December 31, 2017, did the foreign corporation purchase stock or securities of a
shareholder of the foreign corporation for use in a triangular reorganization (within the meaning of Regulations
section 1.358-6(b)(2))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
14
a
Did the foreign corporation receive any intangible property in a prior year or the current tax year for which the U.S.
transferor is required to report a section 367(d) annual income inclusion for the taxable year? . . . . . . .
If “Yes,” go to line 14b.
b
Enter the amount of the earnings and profits reduction pursuant to section 367(d)(2)(B) for the taxable
year
. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
$
15 During the tax year, was the foreign corporation an expatriated foreign subsidiary under Regulations section
1.7874-12(a)(9)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
If “Yes,” see instructions and attach statement.
16 During the tax year, did the foreign corporation participate in any reportable transaction as defined in Regulations
section 1.6011-4? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
If “Yes,” attach Form(s) 8886 if required by Regulations section 1.6011-4(c)(3)(i)(G).
17 During the tax year, did the foreign corporation pay or accrue any foreign tax that was disqualified for credit under
section 901(m)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
18 During the tax year, did the foreign corporation pay or accrue foreign taxes to which section 909 applies, or treat
foreign taxes that were previously suspended under section 909 as no longer suspended? . . . . . . . .
19 Did you answer “Yes” to any of the questions in the instructions for line 19? . . . . . . . . . . . . .
If “Yes,” enter the corresponding code(s) from the instructions and attach statement (see instructions)
▶
20 Does the foreign corporation have interest expense disallowed under section 163(j) (see instructions)? . . . .
If “Yes,” enter the amount . . . . . . . . . . . . . . . . . . . . .
▶
$
21
Does the foreign corporation have previously disallowed interest expense under section 163(j) carried forward to
the current tax year (see instructions)? . . . . . . . . . . . . . . . . . . . . . . . . .
If “Yes,” enter the amount . . . . . . . . . . . . . . . . . . . . .
▶
$
Form 5471 (Rev. 12-2019)