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Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporation

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SCHEDULE J
(Form 5471)
(Rev. December 2018)
Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporation
Department of the Treasury
Internal Revenue Service
▶
Attach to Form 5471.
▶
Go to www.irs.gov/Form5471 for instructions and the latest information.
OMB No. 1545-0123
Name of person filing Form 5471 Identifying number
Name of foreign corporation EIN (if any) Reference ID number (see instructions)
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) . . . . . . . . . . . . . .
▶
Part I Accumulated E&P of Controlled Foreign Corporation
Check the box if person filing return does not have all U.S. Shareholders’ information to complete amount for columns (e)(ii)–(e)(iv) and (e)(vii)–(ix) (see instructions).
Important: Enter amounts in functional currency.
(a)
Post-2017 E&P Not
Previously Taxed
(post-2017 section
959(c)(3) balance)
(b)
Post-1986
Undistributed Earnings
(post-1986 and
pre-2018 section
959(c)(3) balance)
(c)
Pre-1987 E&P Not
Previously Taxed
(pre-1987 section
959(c)(3) balance)
(d)
Hovering Deficit
and Deduction
for Suspended
Taxes
(e) Previously Taxed E&P (see instructions)
(i) Earnings Invested
in U.S. Property
(section 959(c)(1)(A))
(ii) Section 965(a)
Inclusion
(section 959(c)(1)(A))
1a
Balance at beginning of year (as reported on prior
year Schedule J) . . . . . . . . . . . .
1b Beginning balance adjustments (attach statement)
1c
Adjusted beginning balance (combine lines 1a and 1b)
2a
Reduction for taxes unsuspended under anti-splitter rules
2b
Disallowed deduction for taxes suspended under
anti-splitter rules . . . . . . . . . . . .
3 Current year E&P (or deficit in E&P) . . . . .
4
E&P attributable to distributions of previously taxed
E&P from lower-tier foreign corporation . . . .
5a E&P carried over in nonrecognition transaction . .
5b
Reclassify deficit in E&P as hovering deficit after
nonrecognition transaction . . . . . . . .
6 Other adjustments (attach statement) . . . . .
7
Total current and accumulated E&P (combine lines
1c through 6) . . . . . . . . . . . . .
8
Amounts reclassified to section 959(c)(2) E&P from
section 959(c)(3) E&P . . . . . . . . . .
9 Actual distributions . . . . . . . . . . .
10
Amounts reclassified to section 959(c)(1) E&P from
section 959(c)(2) E&P . . . . . . . . . .
11
Amounts included as earnings invested in U.S. property
and reclassified to section 959(c)(1) E&P (see instructions)
12 Other adjustments (attach statement) . . . . .
13
Hovering deficit offset of undistributed
posttransaction E&P (see instructions) . . . .
14
Balance at beginning of next year (combine lines 7
through 13) . . . . . . . . . . . . .
For Paperwork Reduction Act Notice, see the Instructions for Form 5471.
Cat. No. 21111K Schedule J (Form 5471) (Rev. 12-2018)
Schedule J (Form 5471) (Rev. 12-2018)
Page 2
Part I Accumulated E&P of Controlled Foreign Corporation (continued)
(e) Previously Taxed E&P (see instructions)
(f)
Total Section 964(a) E&P
(combine columns (a), (b),
(c), and (e)(i) through (e)(ix))
(iii) Section 965(b)(4)(A)
(section 959(c)(1)(A))
(iv) Section 951A
Inclusion
(section 959(c)(1)(A))
(v) Earnings Invested in
Excess Passive Assets
(section 959(c)(1)(B))
(vi) Subpart F Income
(section 959(c)(2))
(vii) Section 965(a)
Inclusion
(section 959(c)(2))
(viii) Section 965(b)(4)(A)
(section 959(c)(2))
(ix) Section 951A
Inclusion
(section 959(c)(2))
1a
1b
1c
2a
2b
3
4
5a
5b
6
7
8
9
10
11
12
13
14
Part II Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (section 952(c)(2))
Enter amounts in functional currency.
1 Balance at beginning of year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
2 Additions (amounts subject to future recapture) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
3 Subtractions (amounts recaptured in current year) . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
4 Balance at end of year (combine lines 1 through 3) . . . . . . . . . . . . . . . . . . . . . . . . . . . .
▶
Schedule J (Form 5471) (Rev. 12-2018)
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Accumulated Earnings and Profits E and P of Controlled Foreign Corporation

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Completed 21 March 2019

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