Clarification Concerning Filing of Tax Year 2020 Separate Schedule Q (Form 5471)


Notice: Historical Content

This is an archival or historical document and may not reflect current law, policies or procedures.

Starting in tax year 2020, the new separate Schedule Q (Form 5471), CFC Income by CFC Income Groups, is used to report the CFC's income in each CFC income group to the U.S. shareholders of the CFC so that the U.S. shareholders can use it to properly complete Form 1118 (to compute the high-tax exception, high-tax kickout, and section 960 deemed paid taxes).

This update clarifies that:

  • Separate Schedule(s) Q (Form 5471) are required to be filed only by Category 4, 5a, and 5b filers. It is not required to be filed by Category 1a or 1b filers.
  • On page 5 of the Instructions for Form 5471, footnote 1 in the table entitled "Filing Requirements for Categories of Filers" does not apply to category 5b filers who are required to complete separate Schedule(s) Q (Form 5471).