Form 5471 Schedule E part 1 - axes

Taxes Paid, Accrued or Deemed Paid on Accumulated Earnings and Profits (E&P) of a Foreign Corporation
For tax year 2020, the flow of taxes related to tax year 2018 to Schedule E-1 column b (Post-1986 and Pre-2018 E&P) is determined by the Year of Repatriation field on the International tab of Binder Properties. To accommodate the IRS column consolidation for tax year 2020, ONESOURCE Income Tax International will transfer PTEP information.
Enter Beginning Balances in the
Post-86 E&P
and
Taxes
screen (Foreign Entity > Beginning Balances – E&P and Taxes). Pre-87 amounts are entered at a basket and Section 959(c) classification level, and Post-86 taxes are tracked using the additional level of (PTI) PTEP category to distinguish between Section 965(a), Section 965(b), GILTI and other types of previously taxed earnings. ONESOURCE Income Tax International tracks Post-86 Taxes using the following PTEP categories:
  • Section 965(a)
  • Section 965(b)
  • Section 951A (GILTI)
  • Section 951(a)(1) (Subpart F)
  • Section 956 (Investment in U.S. Property)
  • Section 245A(e)(2)
  • Section 959(e)
  • Section 964(e)(4)
During Subpart F calculations, these beginning balances are adjusted for current year taxes, Subpart F and GILTI deemed paid credits, and received from lower tier entities. Use the Post-86 Tax Reconciliation Report (International Reports, Subpart F, Post ’86 E&P and Taxes – Detail) in the Subpart F module to reconcile the information transferred to Form 5471 Schedule E-1.
Since repatriation may have occurred in either 2017 or 2018, to determine if the proper placement of tax year 2018 959(c)(3) taxes is column b (Post-1986 and Pre-2018 E&P), ONESOURCE looks to the Year of Repatriation field on the
International
tab of the Binder Properties. If the Year of Repatriation is set to 2018, taxes entered in the Post-86 E&P and Taxes workpaper with a Tax Year of 2018 will be associated with column b (Post-1986 and Pre-2018 E&P).
When the
International Compute, Transfer to US5471, US8865, US8858
runs, tax activity is transferred by basket directly to the Organizer Schedule E-1.

Manual data entry rows

ONESOURCE Income Tax International does not capture all the information requested on Schedule E-1. You must manually enter data for the following rows and it is retained for all baskets other than a Section 901(j) basket during subsequent transfers:
  • 2. Adjustment for foreign tax redetermination
  • 3a. Taxes unsuspended under anti-splitter rules
  • 3b. Taxes suspended under anti-splitter rules
  • 5a. Taxes carried over in nonrecognition transactions
  • 5b. Taxes reclassified as related to hovering deficit after nonrecognition transaction
  • 7. Other adjustments
  • 12. Taxes on amounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P
  • 13. Other
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