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Form 5471 automated preparation

Schedule Q: Line 1 Subpart F Income Groups

Subpart F Income information is reported in the line 1 section of Schedule Q at a unit level. Refer to the
Schedule Q Lines 1 and 4 Grouping
 column on the 5471 Schedule Q Grouping Report for more information regarding the unit breakdown for a divisional consolidation processing Intercompany Transactions at the division level. Each source code will be analyzed to determine the Schedule Q instance where amounts will be reported.
For the passive basket, source codes amounts are aggregated by matching the Withholding Tax Rate from the mappings on the
Passive Source Grouping
 screen or the entries in binder properties (for source code 61 and full inclusion source codes), as well as the US/Foreign source indicator from the
Source Code Definition
 screen. For the general basket, source code amounts are separated between FOGI and non-FOGI and then aggregated by reference to the US/Foreign source indicator. Lastly, 901(j) basket amounts are aggregated by US/Foreign source.
Within a specific Schedule Q, the
Line 1 Subpart F Income Group
 section requires the separation of income and expenses by Subpart F category (DIRRA, FBC Sales, FBC Services, etc.) To determine the sub-category of Subpart F income a source code amount relates to, the system refers to the
Passive Source Grouping
 screen and binder properties (for passive) and the Subpart F Type in the
Source Code Definition
 screen (for general limitation).
Schedule Q Field
Data Source
Unit Name
Entity Properties > Name
Unit Column i (Country Code)
Binder Properties > Country of Incorporation
Unit Column ii (Gross Income)
E&P by Source Code After Dividend LT Report > Total Gross Income less 959(b) Dividends
Unit Column iii (Definitely Related Expenses)
Expenses with an international Account Types >=4100 specifically allocated in the Income Sourcing Workpaper, excluding interest, R&D and taxes
Unit Column iv (Related Person Interest Expense)
E&P by Source Code After Dividend LT Report > International Account Type = 5170
Unit Column v (Other Interest Expense)
E&P by Source Code After Dividend LT Report > International Account Types = 5160 & 5100
Unit Column vi (Research & Experimental Expenses)
E&P by Source Code After Dividend LT Report > International Account Types = 4000 – 4004 and 4041 - 4043
Unit Column vii (Other Expense)
E&P by Source Code After Dividend LT Report > Total Deductions
Less
Columns iii through vi Amounts
Plus
E&P by Source Code After Dividend LT Report > International Account Types 2000 – 2800
Less (for legal entity line only)
Subpart F Deemed Distribution by Source Code Report > Eliminate Negatives + Basket/Category Netting + PFIC/Boycott Income
Plus (for legal entity line only)
Subpart F Deemed Distribution by Source Code Report > 952(c)(1) Reduction + Qualified Deficits
Unit Column x (Other Current Year Taxes)
E&P by Source Code after Dividend LT Report > Total Taxes less 959(b) Taxes
Unit Column xii (Foreign Taxes for which Credit Allowed)
Column x * FC/US blended rate from the Current Year Taxes Paid Accrued screen
Unit Column xiii (Average Asset Value)
Interest Apportionment Information Screen > Operating Assets (all source codes)
Average Asset Override if not blank OR
(Beginning of Year + (End of Year Override or End of Year from Intl Compute)) / 2
Subpart F Income Group Total Row
Sum the Unit amounts (for each column populated), backing out amounts related to source codes that qualified for non-Subpart F treatment on the Section 954(b)(4) High Tax Election Report

This article applies to:

  • Product: ONESOURCE International Tax
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