5471 Sch. Q
CFC Income by CFC Income Groups
Schedule Q (Form 5471), CFC Income by CFC Income Groups, is attached to Form 5471. The Instructions for Form 5471 say it is used to report the controlled foreign corporation's (CFC's) income, deductions, taxes, and assets by CFC income groups for purposes of section 960(a) and (d), the rules on foreign income taxes a corporate U.S. shareholder is deemed to pay.
The schedule sorts the CFC's income into subpart F income groups (lines 1a to 1m), recaptured subpart F income (line 2), the tested income group (line 3) and the residual income group (line 4), with a row for each unit. Sixteen columns follow each amount from gross income through expenses, foreign taxes, average asset value and loss allocation. The schedule says to enter amounts in the functional currency of the foreign corporation unless otherwise noted.
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The filer's name and identifying number, the foreign corporation's name, EIN and reference ID number, then the separate category code (line A), passive grouping code (B), sanctioned country code (C), U.S. or foreign source (D) and a FOGEI or FORI box (E).
Lines 1a to 1j for foreign personal holding company income types, foreign base company sales and services income, full inclusion income and insurance income, each with unit rows, plus lines 1k to 1m for boycott income, bribes and section 901(j) income.
Recaptured subpart F income, the tested income group and the residual income group, the last two with unit rows, and a total on line 5.
Country code, gross income, and expenses: definitely related expenses, related person interest expense, other interest expense, research and experimental expense, and other expenses with an attached statement.
Current year taxes on disregarded payments and other current year taxes, net income, foreign taxes for which credit is allowed (U.S. dollars), average asset value, a high-tax election box, loss allocation and net income after loss allocation.
Enter PAS, 901j or GEN. The instructions say to complete a separate Schedule Q for each applicable separate category of income, and one more using code TOTAL when there is more than one category.
With PAS on line A, enter the passive group code i, ii, iii or iv from the instructions. With 901j, enter the two-letter country code for the sanctioned country.
Check U.S. source income or foreign source income; the instructions generally call for a separate Schedule Q for each, and both boxes may be checked only on a TOTAL schedule that includes both. Check line E for a schedule reporting FOGEI or FORI.
On rows (1), (2) and so on, enter the name of each unit (each tested unit for a CFC), including the corporation itself, with columns (i) through (xvi). The instructions say to expand the schedule with new rows when reporting more than two units.
Check column (xiv) for an item excluded under the subpart F high-tax exception or the GILTI high-tax exclusion. The instructions say those amounts are left out of the totals on lines 1a to 1j and line 3 and added to line 4.
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The schedule says 'Attach to Form 5471.' The instructions say Form 5471 is attached to the income tax return (or, if applicable, partnership or exempt organization return) and filed by its due date, including extensions.
The instructions call for a separate Schedule Q for each separate category of income, each passive grouping, U.S. and foreign source income, and FOGEI or FORI income.
The instructions say a required schedule with all zero amounts is still filed with one or more zero amounts, and for Schedule Q a single instance for any separate category meets the requirement.
The instructions call for an attached statement splitting line 1f among income from notional principal contracts, payments in lieu of dividends and personal service contracts.
5471
437 fields, 6 pages
5471 Sch. E
400 fields, 3 pages
5471 Sch. I-1
35 fields, 1 page
5471 Sch. H
41 fields, 1 page
5471 Sch. R
101 fields, 1 page
1118
1,263 fields, 12 pages
Schedule Q is completed by the person filing Form 5471 and attached to that form. The chart Filing Requirements for Categories of Filers in the instructions shows which categories complete it.
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No. The schedule says to attach it to Form 5471, which the instructions say is attached to the filer's income tax return.
The instructions call for a separate Schedule Q for each separate category of income, each passive grouping, U.S. and foreign source income, and FOGEI or FORI, plus a TOTAL schedule when there is more than one category.
The schedule says to enter amounts in the functional currency of the foreign corporation unless otherwise noted. Column (xii) is in U.S. dollars.
The instructions say to expand the schedule by adding new lines (3), (4), (5) and so on to pages 1 to 4 in all necessary locations.
The instructions list PAS for passive category income, 901j for section 901(j) income and GEN for general category income, plus TOTAL for the schedule that aggregates the others.