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Form 5471 Schedule G - Other Information
You will manually complete responses to most Schedule G questions in Organizer. During binder rollover from 2020 to 2021, responses for some Schedule G questions flow to the new year (see Response Rollover table).
ONESOURCE transfers responses, descriptions and amounts to a subset of the 5471 Schedule G Line 14 questions during the
International Compute > Transfer to US5471, US8865 and US8858
process (see International Compute Transfer table). Information is transferred from the International Computes to the front of the Schedule G in Organizer (not “hidden” screens as is the case with Schedule C and F) for binders with a Foreign Entity Type
of Controlled Foreign Corporation
(Binder Properties > International
tab).note
Before transferring new results, the International Compute deletes any existing Organizer information for the questions in the International Compute Transfer table. If you have manually entered overrides in Organizer, you must select the
Schedule G
option on the INTL Transfer Options
page on the Organizer 5471
navigation tree to prevent additional transfers from International Computes. If you do not select the Schedule G
option this results in the loss of any Organizer overrides (even if the Organizer field is locked) for the questions in the International Compute Transfer table when you next run the International Compute > Transfer to US5471, US8865, US8858
for the binder.Response Rollover TY2020 to TY2021
Question | Description |
|---|---|
1 (including statement) | During the tax year, did the foreign corporation own at least a 10% interest, directly or indirectly, in any foreign partnership? |
2 | During the tax year, did the foreign corporation own an interest in any trust? |
3 (including statement) | During the tax year, did the foreign corporation own any foreign entities that were disregarded as separate from their owner under Regulations sections 301.7701-2 and 301.7701-3 or did the foreign corporation own any foreign branches (see instructions)? |
7 | During the tax year, was the foreign corporation a participant in any cost-sharing arrangement? |
8 | From April 25, 2014, to December 31, 2017, did the foreign corporation purchase stock or securities of a shareholder of the foreign corporation for use in a triangular reorganization (within the meaning of Regulations section 1.358-6(b)(2))? |
9a | Did the foreign corporation receive any intangible property in a prior year or the current tax year for which the U.S. transferor is required to report a section 367(d) annual income inclusion for the taxable year? |
10 | During the tax year, was the foreign corporation an expatriated foreign subsidiary under Regulations section1.7874-12(a)(9)? |
14 – 7 | During the tax year, did the CFC derive, in the conduct of a banking business, interest that is export financing interest? |
14 – 8 | During the tax year, was the CFC a regular dealer in property described in section 954(c)(1)(B), forward contracts, options contracts, or similar financial instruments (including notational principal contracts and all instruments referenced to commodities)? If so, did the foreign corporation derive any item of income, gain, deduction, or loss (other than any item described in section 954(c)(1)(A), (E), or (G)) from any transaction entered into in the ordinary course of its trade or business as a regular dealer? |
14 – 9 | During the tax year, was the CFC a securities dealer within the meaning of section 475? If so, did the foreign corporation derive any interest or dividend or equivalent amount described in section 954(c)(1)(E) or (G) from any transaction entered into in the ordinary course of its trade and business as a securities dealer? |
14 – 13 | During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of agricultural commodities not grown in the United States in commercially marketable quantities? |
14 – 14 | During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of personal property manufactured in the same counter under the laws of which the CFC is created or organized. |
14 – 15 | During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of personal property purchased or sold for use or consumption in the same country under the laws of which the CFC is created or organized? |
14 – 16 | During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of personal property manufactured by the CFC within the meaning of Regulations section 1.954-3(a)(4)(ii) or (iii)? |
14 – 17 | During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of personal property manufactured by the CFC within the meaning of Regulations section 1.954-3(a)(4)(iv)? |
14 – 18 | (a) During the tax year, did the CFC derive income in connection with the purchase from or sale to a related or unrelated person of personal property manufactured or sold for use outside the country under laws of which the CFC is created or organized (for example, property manufactured or sold by a disregarded entity of the CFC)? (b) During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related party (for example, purchase or sales commission income)? |
14 – 19 | During the tax year, was the CFC and eligible CFC (as defined in section 954(h)(2)) that derived qualified banking or financing income (as defined in section 954(h)(3))? |
14 – 20 | During the tax year, was the CFC a qualifying insurance company (as defined in section 953(e)(3)) that derived qualified insurance income (as defined in section 954(i)(2))? |
International Compute Transfer to Schedule G
Line 14 Question | Source of Data |
|---|---|
1 – De minimis applies | If de minimis applies (Section 954(b)(3) Report > 954(b)(3)(A) Test Result = No Subpart F) then · Response = Yes · Description = De minimis · Amount = Section 954(b)(3) Report > Subpart F Gross Income (FC) Else · Response = No · Description = “” · Amount = NONE |
2 – High Tax Exception applies | If the high tax exception applies (Subpart F Deemed Distribution Report > Total Sec954(b)(4) Adjustments # 0) then · Response = Yes · Description = High Tax · Amount = Subpart F Deemed Distribution Report > Total Sec954(b)(4) Adjustments Else · Response = No · Description = “” · Amount = NONE |
3 – FPHCI, FBC Sales and FBC Services reduced by deductions | If de minimis does not apply and E&P by SC After Dividend LT Report > Total Deductions + Total Taxes for Source Codes with Subpart F Types 2 (FPHCI), 3 (FBC Sales), 4 (FBC Services) > 0 then · Response = Yes · Description = Deductions taken into account · Amount = E&P by SC After Dividend LT Report > Total Deductions + Total Taxes for Source Codes with Subpart F Types 2, 3, 4 Else · Response = No · Description = “” · Amount = NONE |
6 – Receipt of non-Intercompany Rents / Royalties | If Full Inclusion does not apply (Section 954(b)(3) Report > 954(b)(3)(B) Test Result = N/A) and Section 954(b)(3) Report > Other E&P Column > Gross Rents + Gross Royalties/License Fees > 0 then · Response = Yes · Description = Active rents / royalties · Amount = Section 954(b)(3) Report > Other E&P Column > Gross Rents + Gross Royalties/License Fees Else · Response = No · Description = “” · Amount = NONE |
10 – Receipt of I/C dividends and interest (Same country exception applies) | If E&P by Source Code after Dividend LT Report > I/C Interest Income + I/C Dividend Income (excluding 959(b)) non-Subpart F amounts > 0 and the Payor & Recipient Country of Incorporation (Binder Properties) is the same*** then · Response = Yes · Description = Same country dividends / interest · Amount = E&P by Source Code after Dividend LT Report > I/C Interest Income + I/C Dividend Income (excluding 959(b)) non-Subpart F amounts Else · Response = No · Description = “” · Amount = NONE ***Regardless of the Intercompany Transaction level, Interest will always refer to the legal entity payor divisional consolidation’s country of incorporation. |
11 – Receipt of I/C rents and royalties (Same country exception applies) | If E&P by Source Code after Dividend LT Report > I/C Rent Income + I/C Royalty Income non-Subpart F amounts > 0 and the Payor & Recipient Country of Incorporation (Binder Properties) is the same*** then · Response = Yes · Description = Same country rents / royalties · Amount = E&P by Source Code after Dividend LT Report > I/C Rent Income + I/C Royalty Income non-Subpart F amounts Else · Response = No · Description = “” · Amount = NONE ***If the Intercompany Transaction level is Division, Rents & Royalties will refer to the payor division’s country of incorporation. |
12 – Receipt of I/C dividends, interest, rents and royalties (Same country exception does not apply) | If E&P by Source Code after Dividend LT Report > I/C Rent Income + I/C Royalty Income + I/C Interest Income + I/C Dividend Income (excluding 959(b)) non-Subpart F amounts not reported on questions 10 and 11 > 0 then · Response = Yes · Description = Look Thru · Amount = E&P by Source Code after Dividend LT Report > I/C Rent Income + I/C Royalty Income + I/C Interest Income + I/C Dividend Income (excluding 959(b)) non-Subpart F amounts not reported on questions 10 & 11 Else · Response = No · Description = “” · Amount = NONE |
21 – Subpart F exceeds current year E&P | If Subpart F Deemed Distribution Report > Total 952(c)(1)(A) Reduction > 0 then · Response = Yes · Description = Earnings & Profits limitation · Amount = Subpart F Deemed Distribution Report > Total 952(c)(1)(A) Reduction Else · Response = No · Description = “” · Amount = NONE |
22 – Other Subpart F reductions | If Subpart F Deemed Distribution Report > Total Deficits - 952(c)(1)(B)/(C) (Qualified Deficit Utilization) > 0 then · Response = Yes · Description = Qualified Deficit - 952(c)(1)(B) · Amount = Subpart F Deemed Distribution Report > Total Deficits - 952(c)(1)(B)/(C) Else · Response = No · Description = “” · Amount = NONE |