Instructions for Form 5471 - (Rev. December 2025) - Information Return of U.S. Persons With Respect to Certain Foreign Corporations

Oct 3, 2026

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Instructions for U.S. taxpayers on filing Form 5471 (revised December 2025) related to information returns for certain foreign corporations. The document explains future developments, what’s new for CFC tax years, and changes to Form 5471 and its schedules, including Schedule G updates, Schedule I worksheet instructions, and transitions tied to the Pro Rata Share Transition Rule. It also provides general instructions covering purpose, who must file by filer categories, required schedules, and filing timing and attachment requirements.

LanguageEnglish

CategoryExam

FormatPDF

Pages58

Reading Time2 h 26 min

AccessFree to download

Purpose of Form

Who Must File

Categories of Filers

When and Where To File

Future Developments

What’s New

Changes to Form 5471 and Schedules

Changes to Form 5471

Changes to separate Schedule E

Changes to instructions

Instructions for Form 5471 (Rev. December 2025) (Use with the December 2025 revision of Form 5471; the December 2024 revision of separate Schedules H-1 and Q; the December 2023 revision of separate Schedule G-1; the December 2021 revision of separate Schedules E, H, I-1, and M; the December 2020 revision of separate Schedules J, P, and R; and the December 2012 revision of separate Schedule O.) Information Return of U.S. Persons With Respect to Certain Foreign Corporations Section references are to the Internal Revenue Code unless otherwise noted. 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 [IRS.gov/Form5471](IRS.gov/Form5471) . What’s New CFC tax years. Under section 70352 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known asthe One Big Beautiful Bill Act (OBBBA), for a tax year of a specified foreign corporation (SFC) beginning after November 30, 2025, the SFC may not have a tax year beginning one month earlier than the majority U.S. shareholder year. Pro Rata Share Transition Rule. Under a transition rule provided by section 70354(c)(2) of the OBBBA (the Pro Rata Share Transition Rule), certain dividends paid (or deemed paid) by a CFC are not treated as dividends for purposes of applying section 951(a)(2)(B) (as unamended by the OBBBA) . For guidance on the Pro Rata Share Transition Rule, see Notice 2025-75, 2025-52 I. R. B. 867, which taxpayers may rely on as provided in that notice. Changes to Form 5471. On page 4 of Form 5471, Schedule G, question 3b is new. If the foreign corporation has one or more qualified business units (as defined in section 989(a)) with a functional currency different from its owner, the filer is required to check the “Yes” box and enter the number of Forms 8964-TRA attached to Form 5471 in the entry space provided. On page 6, Schedule G, line 21, is new. If, during the tax year, any portion of any increase or decrease to the foreign corporation’s E&P (including previously taxed E&P described in section 959) was attributable to a transaction described in section 304, the filer is required to check the“Yes” box on line 21a and do the following. • Enter on line 21b(1) the change in PTEP described in section 959(c)(1) and (c)(2) . • Enter on line 21b(2) the change in other E&P described in section 959(c)(3) . Changes to separate Schedule E. Schedule E, Part I, Section 1, column (j) instructions have been updated to request a statement providing information on taxes allocated under guidance issued under section 70352(c) (1)(C) of the OBBBA. Changes to instructions. The Schedule G, line 14 instructions have been updated. Question 22 has been changed to Question 22a. Question 22b has been added to identify dividends paid (or deemed paid) by a CFC that are potentially subject to the Pro Rata Share Transition Rule. Schedule I, Worksheet A, line 46 instructions have been added to reflect the application of the Pro Rata Share Transition Rule. General Instructions Purpose of Form Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations. The form and schedules are used to satisfy the reporting requirements of sections 6038 and 6046, and the related regulations. Who Must File Generally, all U.S. persons described in Categories of Filers below must complete the schedules, statements, and/or other information requested in the chart, Filing Requirements for Categories of Filers, later. Read the information for each category carefully to determine which schedules, statements, and/or information apply. Note. When a schedule is required but all amounts are zero, the schedule should still be filed with one or more zero amounts. For schedules that are completed by category (that is, Schedules E, I-1, J, P, and Q), inclusion of a single instance of that sche

FAQs

What is Form 5471 used for?

Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations. It satisfies reporting requirements under sections 6038 and 6046 and related regulations.

Who must file Form 5471?

Generally, U.S. persons described in the filing categories must complete the applicable schedules and information. The instructions require carefully reading each category to determine which schedules and statements apply.

What key updates and changes were made for the December 2025 revision?

The document highlights changes such as new/updated questions and lines in Schedule G, added guidance for Schedule I worksheet instructions reflecting the Pro Rata Share Transition Rule, and revised instructions including new Question 22a/22b to identify potentially subject dividends.

Oct 3, 2026

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