5471 Sch. P

Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations

Agency
IRS
Revision
Rev. December 2020
Fillable fields
317
Pages
4
Official source
IRS form page
Checked
October 21, 2026
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Page 1 of form 5471 Sch. P

Schedule P (Form 5471): Previously Taxed Earnings and Profits of U.S. Shareholder

Schedule P (Form 5471), Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations, is one of the schedules filed with Form 5471. The instructions say to "use Schedule P to report the PTEP in the U.S. shareholder's annual PTEP accounts with respect to a CFC in the CFC's functional currency (Part I) and the U.S. shareholder's U.S. dollar basis in that PTEP (Part II)." PTEP stands for previously taxed earnings and profits, and CFC for controlled foreign corporation.

The schedule is completed by U.S. shareholders who are Category 1a, 1b, 4, 5a or 5b filers of Form 5471, and the form says "Attach to Form 5471." Each schedule covers one foreign corporation and one separate category of income, with columns for each PTEP group from section 965 PTEP to section 951A and section 959(c)(1) PTEP.

This page covers the December 2020 revision. You can fill it out free in your browser on this page and download the result without an account.

What's on Schedule P (Form 5471)

Identifying information

Name and identifying number of the person filing Form 5471, name and identifying number of the U.S. shareholder, name of the foreign corporation, its EIN if any, and a reference ID number.

Lines a and b

Line a takes the separate category code. Line b takes the country code for the sanctioned country when code 901j is entered on line a.

Part I: Previously taxed E&P in functional currency

Lines 1a to 12 run from the balance at beginning of year, through reductions, carryovers, reclassifications and actual distributions, to the balance at beginning of next year.

Columns (a) to (k)

Reclassified section 965(a), 965(b), 951A and 245A(d) PTEP, general section 959(c)(1) PTEP, section 965(a), 965(b), 951A, 245A(d) and 951(a)(1)(A) PTEP, and a total column.

Part II: Previously taxed E&P in U.S. dollars

The same lines 1a to 12 and columns (a) to (k), stated in U.S. dollars on pages 3 and 4.

How to fill out Schedule P (Form 5471)

  1. 1

    Names and reference ID

    Enter the filer, the U.S. shareholder and the foreign corporation. The instructions say to use the reference ID number shown on Form 5471, page 1, item 1b(2), if applicable.

  2. 2

    Line a: one schedule per category

    Complete a separate Schedule P for each separate category of income and enter its code, found under Categories of Income in the Instructions for Form 1118. The instructions add a separate schedule with code TOTAL when there is more than one category.

  3. 3

    No separate section 951A schedule

    The instructions say not to complete a separate Schedule P for the section 951A category. That PTEP goes on the Schedule P completed for the general category.

  4. 4

    Line 1b

    If last year's ending balance differs from what it should be, include the difference on line 1b and attach an explanation. Multiple differences each get an explanation and amount on the attachment.

  5. 5

    Part I in functional currency

    Enter amounts in the foreign corporation's functional currency as reported on Form 5471, page 1, item 1h. Columns (a) to (j) correspond to columns (e)(i) to (e)(x) of Schedule J.

  6. 6

    Part II in U.S. dollars

    Enter the U.S. shareholder's dollar basis in the PTEP. The instructions say it is generally equal to the U.S. dollar amount of E&P previously included in gross income.

The Instructions for Form 5471 have a section on Schedule P.

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Where it goes and how it ties to other schedules

Where it goes

The schedule says "Attach to Form 5471." The instructions say to attach Form 5471 to the income tax return (or partnership or exempt organization return) and file both by its due date, including extensions.

Zero amounts

The instructions say a required schedule with all zero amounts is still filed with one or more zero amounts, and for schedules completed by category, a single instance for any separate category meets the requirement.

Ties to Schedule J

If a U.S. shareholder wholly owns the CFC, the instructions say Schedule P should include the same information as column (e) of Schedule J, Part I. With more than one shareholder the amounts might differ.

Ties to Schedule R

Amounts in column (d) of Schedule R (Form 5471) are also included on Part I, line 8, of Schedule P, the instructions say.

Edition

The schedule PDF is the December 2020 revision. The Instructions for Form 5471 that cover it are revised 12/2025.

Related forms

Who completes Schedule P (Form 5471)?

  • Category 1a and 1b filers

    U.S. shareholders of a foreign corporation that was a section 965 specified foreign corporation (SFC). The instructions say a Category 1 filer has section 965 PTEP that is reportable on Schedule P.

  • Category 4 filers

    A U.S. person who had control of a foreign corporation during the foreign corporation's annual accounting period, as the instructions define control.

  • Category 5a and 5b filers

    U.S. shareholders that owned stock in a foreign corporation that was a CFC and owned it on the last day of that year. Category 5b covers an unrelated section 958(a) U.S. shareholder of a foreign-controlled CFC.

  • Shareholders under the joint filers exception

    A qualifying filer who is not filing Form 5471 under the joint filers exception still completes Schedule P and attaches it to the statement attached to their tax return, the instructions say.

  • Individuals, corporations, partnerships, estates and trusts

    The U.S. person definitions in the instructions include citizens and residents, domestic partnerships, domestic corporations and estates or trusts that are not foreign. For a consolidated return, the U.S. parent's name goes in the filer field.

The instructions say a separate Schedule P is completed by each Category 1a, 1b, 4, 5a or 5b filer. The categories are defined in the Instructions for Form 5471.

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Questions about Form 5471 Sch. P

Who completes Schedule P (Form 5471)?

The instructions say each Category 1a, 1b, 4, 5a or 5b filer completes a separate Schedule P. Other categories of Form 5471 filers are not listed for it.

Is Schedule P filed on its own?

No. The schedule says "Attach to Form 5471," and Form 5471 is attached to the filer's income tax return.

How many Schedules P does a filer complete?

One for each separate category of income for each foreign corporation, plus one with code TOTAL that aggregates the others when there is more than one category, the instructions say.

What is the difference between Part I and Part II?

Part I reports the PTEP in the CFC's functional currency. Part II reports the U.S. shareholder's U.S. dollar basis in that PTEP, which the instructions say is used to determine foreign currency gain or loss under section 986(c).

How does Schedule P relate to Schedule J?

Columns (a) through (j) of Schedule P correspond to columns (e)(i) through (e)(x) of Schedule J, and the instructions point to Schedule J for specific line instructions.

What if the foreign corporation has no previously taxed E&P?

The instructions say that when a schedule is required but all amounts are zero, it should still be filed with one or more zero amounts.