Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, is one of the most complex IRS forms. Certain U.S. citizens, residents and companies that own or control a foreign corporation must file it every year. The form reports the foreign company’s ownership, income, balance sheet and dealings with its U.S. owners. It also supports the tax U.S. owners may owe on the company’s earnings.
Form 5471 at a glance
- Who files: certain U.S. citizens, residents, companies, officers and directors connected to a foreign corporation, in five filer categories (see below).
- When: with your income tax return, by its due date including extensions.
- Penalty: $10,000 for each late or incomplete form, for each year, even if no tax is owed.
- Schedules G and P: what they cover and who completes them.
We prepare Form 5471 for founders, business owners and U.S. companies with foreign subsidiaries. Below is an overview of the rules.
Who must file Form 5471?
Filing depends on your relationship with the foreign corporation. The instructions group filers into five categories. For example:
- Category 2: U.S. citizens or residents who are officers or directors when a U.S. person acquires 10% or more of the stock.
- Category 3: U.S. persons who acquire stock that brings them to 10% or more ownership, among other events.
- Category 4: U.S. persons who control the corporation, generally by owning more than 50%.
- Categories 1 and 5: U.S. shareholders of certain foreign corporations, including controlled foreign corporations (CFCs).
One person can fall into more than one category. In that case, you check every category that applies and complete the schedules each one requires. For the full rules, see the IRS page for Form 5471.
Form 5471 filer categories
Form 5471 sorts filers into five categories. Your category decides which schedules you complete, and you can fall into more than one.
| Category | Who it covers (simplified) |
|---|---|
| 1 | U.S. shareholders (generally 10% or more) of a specified foreign corporation, which includes a controlled foreign corporation (CFC) |
| 2 | U.S. citizens or residents who are officers or directors of a foreign corporation when a U.S. person acquires 10% or more of its stock |
| 3 | U.S. persons who acquire stock that brings them to 10% or more, sell down below 10%, or become U.S. persons while owning 10% or more |
| 4 | U.S. persons who control the foreign corporation (more than 50% of vote or value) during its tax year |
| 5 | U.S. shareholders of a CFC who own stock on the last day of its tax year |
The exact tests have more detail and exceptions. See the IRS Form 5471 instructions or ask us to review your ownership.
What information does Form 5471 require?
The form starts with details about you and the foreign corporation. Then, depending on your category, it may require:
- the company’s income statement and balance sheet in U.S. dollars,
- transactions between the company and its U.S. owners or related parties,
- ownership and stock details, and
- schedules for earnings, taxes and income that U.S. shareholders must include.
In practice, a complete filing often runs many pages. In fact, the IRS estimates that the form takes dozens of hours, not counting record-keeping.
Form 5471 Schedule G and Schedule P
Two schedules people often ask about are Schedule G and Schedule P.
Schedule G (Other Information) is on page 4 of Form 5471. It is a set of questions about the foreign corporation. Under the IRS filing requirements chart, Category 1c, 3, 4, 5a and 5c filers complete it.
Schedule P (Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations) tracks the corporation’s earnings and profits that a U.S. shareholder has already included in income, such as subpart F income, global intangible low-taxed income (GILTI) under section 951A, and section 965 amounts. This previously taxed E&P (PTEP) is generally not taxed again when it is later distributed. Part I reports the balances in the corporation’s functional currency and Part II in U.S. dollars. Category 1a, 1b, 4, 5a and 5b filers complete a separate Schedule P.
Foreign income taxes the corporation paid or accrued go on Schedule E, and its accumulated earnings and profits go on Schedule J.
Other Form 5471 schedules you may see
Depending on your category, the IRS may also require these separate schedules:
| Schedule | IRS title |
|---|---|
| E | Income, War Profits, and Excess Profits Taxes Paid or Accrued |
| H | Current Earnings and Profits |
| I-1 | Information for Global Intangible Low-Taxed Income |
| J | Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporation |
| M | Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons |
| O | Organization or Reorganization of Foreign Corporation, and Acquisitions and Dispositions of its Stock |
| Q | CFC Income by CFC Income Groups |
| R | Distributions From a Foreign Corporation |
The instructions for Schedule I, line 9, also include Worksheet A, which is used to work through the CFC’s subpart F income, starting with foreign base company income.
Sources: IRS: About Form 5471 (reviewed 17-Sep-2026); IRS Instructions for Form 5471 (12/2025); Schedule P (Form 5471).
Form 5471 filing checklist: what to gather
Most of the work on Form 5471 is collecting the foreign company’s information. Before you or your preparer start, gather:
- An ownership chart for the year, showing direct and indirect ownership percentages. This decides your filer category and which schedules you complete.
- The foreign corporation’s financial statements for its tax year: the income statement (Schedule C) and balance sheet (Schedule F), with the exchange rates used to translate them to U.S. dollars.
- Its functional currency and accounting period.
- Transactions with U.S. owners and related parties, such as loans, management fees, sales and purchases (Schedule M).
- Foreign income taxes the company paid or accrued (Schedule E).
- Earnings and profits records: current E&P (Schedule H), accumulated E&P (Schedule J) and previously taxed E&P (Schedule P).
- Distributions the company made during the year (Schedule R), and any stock acquisitions, dispositions or reorganizations (Schedule O).
- Last year’s Form 5471 and income tax return, so balances carry forward correctly.
When is Form 5471 due?
You file Form 5471 with your income tax return, by the same due date, including extensions. For individuals, that is usually April 15. However, U.S. citizens living abroad get an automatic extension to June 15. For a U.S. corporation that owns the foreign company, the form goes with the corporate return.
Penalties for not filing Form 5471
The penalties are steep, even if the foreign company has no profit and you owe no tax.
- Initial penalty: $10,000 for each late or incomplete Form 5471, for each year.
- Continuation penalty: if you don’t file within 90 days after an IRS notice, another $10,000 for each 30-day period, up to $50,000 more.
- Foreign tax credit reduction: the IRS can also reduce your foreign tax credits.
The IRS now assesses many of these penalties automatically. Moreover, a net operating loss doesn’t help, because this is a penalty, not a tax.
The statute of limitations stays open
In addition, if you don’t file a required Form 5471, the statute of limitations on your entire return generally stays open until you do. So the IRS can examine that year long after the usual three years.
Controlled foreign corporations
A foreign corporation is a controlled foreign corporation (CFC) if U.S. shareholders, each owning at least 10%, together own more than 50%. When a company is a CFC, its U.S. shareholders may owe current U.S. tax on some of its income, even if the company pays no dividends. This includes:
- Subpart F income, such as certain passive income like interest, dividends, rents and royalties, and some sales and services income, and
- net CFC tested income, formerly known as GILTI. The 2025 tax law renamed and revised it for tax years beginning after 2025.
Related forms you may need
- Form 8992 for net CFC tested income (formerly GILTI)
- Form 1118 or Form 1116 for foreign tax credits
- Form 5472 for foreign-owned U.S. companies
- FinCEN Form 114 (FBAR) and Form 8938 for foreign accounts and assets
Form 5471 FAQs
Do I need to file Form 5471 if I own less than 10%?
Usually not as a shareholder. However, a U.S. officer or director can have a Category 2 filing when another U.S. person acquires 10% or more, and ownership through family members or other entities can count toward the 10%.
Is Form 5471 filed separately?
No. It is attached to your income tax return (for example Form 1040, 1120 or 1065) and is due when that return is due, including extensions.
What if my foreign company is an LLC?
It depends on how the entity is classified for U.S. tax purposes. A foreign entity treated as a corporation uses Form 5471. One treated as a disregarded entity uses Form 8858, and one treated as a partnership uses Form 8865.
What if I missed Form 5471 in earlier years?
Penalties can be steep, and the statute of limitations on the whole return may stay open. There are ways to catch up, so talk to a tax professional before filing late forms on your own.
What is Schedule H on Form 5471?
Schedule H (Current Earnings and Profits) adjusts the foreign corporation’s net income to figure its current-year earnings and profits for U.S. tax purposes. Those figures feed other schedules, such as Schedule J (accumulated E&P).
What is Worksheet A on Form 5471?
Worksheet A appears in the instructions for Schedule I, line 9. It is used to work through a controlled foreign corporation’s subpart F income, starting with foreign base company income.
Related guides
- U.S. tax treatment of foreign property development
- Nonresident aliens selling U.S. property: ITIN and withholding
- Business and international tax services
Get help with Form 5471
Form 5471 is one of the hardest forms in the tax code, and mistakes are costly. If you own or control a foreign company, or you’ve missed past filings, we can help. Learn more about our tax compliance services, call (415) 842-2940 or book a free 15-minute call.