Form 5471 Schedule O - Organization or Reorganization of Foreign Corporation, and Acquisitions and Dispositions of its Stock

Schedule O amounts are either entered manually in Organizer or imported using ONESOURCE Excel Add-In or ONESOURCE Workpapers. For tax years 2013 and later, ONESOURCE Income Tax automatically transfers organizational chart information for foreign entities to the
Form 5471 Schedule O Part II Section F
or
Form 8858
depending on the binder’s attributes. The organizational chart is transferred to Organizer when you select the
Transfer to US5471, US8865 and US8858 (Organization Chart)
option on the
International Compute
screen.
ONESOURCE Income Tax builds the ownership structure from the information in the top consolidation’s
International Members
screen, as well as the
Country of Incorporation/Organization
and
Tax Classification
fields on the
International
tab of
Foreign and Foreign Tax Credit Binder Properties
.
The Organizer has separate folders for the automated and any manually created organization chart under the
Foreign Corporation
folder for
Schedule O, Part II, Section F: Organization Chart – INTL and Organization Chart – User Prepared
. By default, the structure transferred from the International Computes is marked for suppression from print and e-file and entries from the
User Prepared
folder will print/e-file. To include the organizational chart transferred from computes with Schedule O, select
Manually entered in the Suppress Print and E-File of Organizational Chart Information
(for any entity under the Organization Chart – INTL folder) to print/e-file the system generated entries and suppress any data in the
User Prepared
section.
If you modify the information transferred from international computes to the Organizational Chart – INTL section, select
Lock the entity information transferred in from International Compute
option (for any entity listed) to prevent update the next time transfer is run.
When you select the
Transfer to US5471, US8865 and US8858
(Organization Chart) option on the
International Compute
screen ONESOURCE Income Tax uses the ownership structure defined in the
International Members
screen of the selected top consolidation to create the organization chart transferred to the Form 5471. An individual entry under the
Organizer Chart – INTL
folder is created for each entity in the chain of ownership from the foreign corporation filing the return to the top tier FTC parent.
  • The transfer of the organization chart does not require that E&P, Look Through or Subpart F calculations are run.
  • Select the
    Lock the entity information transferred in from International Compute
    option to prevent additional updates to the Organizer screens. Using this checkbox is particularly important if you manually update the International chart.
The Parent entity selected in the top consolidation binder’s
Domestic Members
screen will be identified as the top tier filer. Any Foreign Tax Credit entity without a parent will be considered owned 100% by this parent. The order of entities in the
Organization Chart – INTL
folder is as follows:
  • FTC Parent from domestic members screen
  • FTC legal entities sorted by tier and company name
  • Foreign legal entities (non-partnership entities) ordered by tier and company name
  • Foreign partnerships appear immediately below its highest tier owner
  • Foreign disregarded entity immediately below its related Divisional Consolidation
  • Unrelated FTC entities by company name
  • Unrelated foreign entities by company name
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