CFC Analyzer - Form 5471

Identifying Information

Page 1

Filer Name

Filer EIN / SSN

CFC Name

Country of Incorporation

Country Code

Tax Year End

Functional Currency

Exchange Rate (FC to USD)

CFC EIN (if any)

Reference ID Number

Category of Filer (check all that apply)

1a — Stock acquisition (newly required) 1b — Org / reorganization 2 — U.S. officer/director 3 — 10% U.S. shareholder (not 4 or 5) 4 — Control (majority vote or value) 5a — CFC (majority vote) 5b — CFC (majority value) 5c — CFC (constructive ownership)

Schedule A — Stock of the CFC

Sched A

#	Class of Stock	Shares Issued & Outstanding	Votes / Share	Total Voting Power (%)
1
2
3
4

Schedule B — U.S. Shareholders of CFC

Sched B

#	Shareholder Name	EIN / SSN	Class of Stock	Shares Owned	% Total Voting	% Total Value
1
2
3

Schedule C — Income Statement

Sched C FC: FX Rate:

Line	Description	Functional Currency	U.S. Dollars
1a	Gross receipts / sales
1b	Returns and allowances
1c	Net receipts (1a minus 1b)
1d	Cost of goods sold
1e	Gross profit (1c minus 1d)
2	Dividends received
3	Interest received
4	Rents, royalties, license fees
5	Net gain on sale of assets
5a	Other income
6	Total income
7	Compensation deductions
8	Rent deductions
9	Depreciation/amortization
10	Interest deductions
11	Other deductions
12	Total deductions
13	Income taxes (foreign)
14	Net income (loss)

Schedule F — Balance Sheet

Sched F FX Rate:

Line	Description	Functional Currency	U.S. Dollars
ASSETS
1	Cash & equivalents
2a	Trade receivables
2b	Less: bad debt reserve
3	Inventories
4	Other current assets
5	Loans to shareholders/officers
6	Investment in subsidiaries
7	Other investments
8a	Buildings & equipment (gross)
8b	Less: accumulated depreciation
9	Land
10	Intangible assets (net)
11	Other assets
12	Total assets
LIABILITIES
13	Accounts payable
14	Other current liabilities
15	Long-term debt
16	Loans from shareholders
17	Deferred taxes
18	Other liabilities
19	Total liabilities
EQUITY
20	Capital stock
21	Retained earnings / (deficit)
22	Other equity
23	Total equity
24	Total liabilities & equity

Schedule G — Other Information

Sched G

Q#	Question	Yes	No
1	Did the CFC engage in cost sharing?
2	Did the CFC have any outstanding loans owed to U.S. persons (§956)?
3	Was the CFC a PFIC?
4	Did the CFC own 10% or more of another foreign corporation?
5	Did the CFC make any distributions?
6	Did the CFC pay or accrue any foreign income taxes?
7	Was a §338 election made with respect to the CFC?
8	Did the CFC use DASTM accounting?
9	Did the CFC own any foreign disregarded entities?
10	Did the CFC have tested income or loss for GILTI purposes?

Schedule I — Summary of Shareholder's Income from CFC

Sched I

1a — Subpart F income (insurance)

1b — Subpart F income (foreign base company)

1c — Subpart F income (International Boycott factor)

1d — Illegal bribes/kickbacks

1e — §901(j) income

1f — Other Subpart F income

1g — Subpart F income excluded under §954(b)(4)

1h — Total Subpart F inclusion

2 — GILTI inclusion (§951A)

3 — §956 amount (investment in US property)

4 — §959(a) distributions (PTEP)

5 — §1248 dividend amount

Total shareholder inclusion

Schedule E — Income, War Profits, and Excess Profits Taxes Paid/Accrued

Sched E

#	Country	Income Category	Taxes Paid (FC)	Taxes Paid (USD)	Creditable?	Foreign Tax Credit Category
1
2
3

Schedule H — Current Earnings & Profits

Sched H FX:

Line	Description	Functional Currency	U.S. Dollars
1	Net income per books
2	Federal income taxes
3	Excess of capital losses over capital gains
4	Income recorded on books not included in Sched C
5	Expenses recorded on books not on Sched C
6	Income on Sched C not recorded on books
7	Deductions on Sched C not charged against book income
8	Other additions
9	Other reductions
10	Current E&P
11	PTEP distributions
12	E&P after distributions

Schedule H-1 — Section 964(e) Gain

Sched H-1

Name of lower-tier CFC

EIN / Reference ID

Country of incorporation

Stock sold (description)

Date of sale

Amount realized

Adjusted basis

§964(e) gain recognized

Applicable E&P in lower-tier CFC

Schedule G-1 — Cost Sharing Arrangement

Sched G-1

Is CFC a controlled participant in a CSA?

Yes No

Type of intangible developed

CFC's share of cost (FC)

CFC's share of cost (USD)

Platform contribution transaction amount

Useful life of intangible (years)

Method used for CST payments

Did CFC make a buy-in payment?

Yes No

Buy-in payment amount (USD)

Notes

Schedule I-1 — Information for Global Intangible Low-Taxed Income (GILTI)

Sched I-1

1 — Gross income

2 — Exclusions (§954(b)(4), Subpart F, etc.)

3 — Tested income (1 minus 2, if positive)

4 — Tested loss (1 minus 2, if negative)

5 — Qualified business asset investment (QBAI)

6 — Deemed tangible income return (10% x QBAI)

7 — Net tested income (3 minus 6, if positive)

8 — Tested foreign income taxes paid/accrued

9 — Effective foreign tax rate on tested income (%)

10 — Qualified interest expense

Schedule J — Accumulated Earnings & Profits and PTEP

Sched J

PTEP / E&P Category	Opening Balance	Current Year Increase	Distributions	Closing Balance
Post-2017 E&P (general)
PTEP — §959(c)(1) §956 amounts
PTEP — §959(c)(2) Subpart F
PTEP — GILTI §951A
PTEP — §965(a) Transition Tax
PTEP — §965(b)(4)(A) PTEP
Pre-2018 E&P
Total

PTEP = Previously Taxed E&P. §959(c)(1) and (c)(2) amounts listed in priority order.

Schedule M — Transactions Between CFC and Related Persons

Sched M

Transaction Type	CFC Amount (FC)	CFC Amount (USD)	Related Party Amount (USD)
Sales of inventory
Purchases of inventory
Sales of property (non-inventory)
Purchases of property (non-inventory)
Rents paid
Rents received
Royalties paid
Royalties received
Interest paid
Interest received
Dividends paid
Services received (fees paid)
Services provided (fees received)
Platform contribution transactions
Loans / advances (CFC to related)
Loans / advances (related to CFC)

Schedule P — Previously Taxed E&P by Shareholder

Sched P

#	Shareholder Name	EIN	PTEP Category	Opening Balance	Current Year	Distributions	Closing Balance
1
2
3

Schedule O — Organization or Reorganization of Foreign Corporation

Sched O

#	Transfer Type	Date	FMV (USD)	Adjusted Basis	§367 Gain Recognized	Transferor EIN
1
2
3

§367(a) and (b) transfers. Check if gain deferral election applies.

Schedule Q — CFC Income by Country

Sched Q

Country	Income Category	Gross Income (FC)	Gross Income (USD)	Taxes (FC)	Taxes (USD)	FTC Basket

Reported in functional currency and USD. FTC basket: General, Passive, GILTI, Branch.

Schedule R — Distributions from a Foreign Corporation

Sched R

#	Date	Amount (FC)	Amount (USD)	§959(c) Ordering	From PTEP?	§1248 Amount
1
2
3

§959 ordering: (c)(1) §956 property, then (c)(2) Subpart F/GILTI, then (c)(3) other E&P.