Instructions for Form 5471 - Introductory Material


Future Developments

For the latest information about developments related to Form 5471, its schedules, and its instructions, such as legislation enacted after they were published, go to www.irs.gov/form5471.

Important Reminders

Extension of certain exceptions from subpart F rules.   
  • The Tax Increase Protection Act of 2014 extended the temporary exceptions for certain “active financing income” from subpart F foreign personal holding company income, foreign base company services income, and insurance income. The exceptions now apply to tax years of foreign corporations beginning after December 31, 1998, and before January 1, 2015, and to tax years of U.S. shareholders with or within which any such tax years of foreign corporations end. For more information, see the instructions for Worksheet A beginning on page 8.

  • The Tax Increase Protection Act of 2014 extended the look-through rule of section 954(c)(6). The rule now applies to tax years of foreign corporations beginning after December 31, 2005, and before January 1, 2015, and to tax years of U.S. shareholders with or within which such tax years of the foreign corporations end. Continue to exclude the applicable types of income specified in section 954(c)(6) from Worksheet A, line 1a for the period specified in the previous sentence.

Net investment income tax.   Certain U.S. shareholders filing Form 5471 may be subject to the net investment income tax on their income from controlled foreign corporations (CFCs). For details, see the Instructions for Form 8960, Net Investment Income Tax, and Regulations section 1.1411-10.


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