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Form 5471 Schedule P Part I - Previously Taxed Earnings and Profits of U.S. Dollars (Tax year 2021)
To accommodate the IRS column consolidation for tax year 2020, ONESOURCE Income Tax International will transfer PTEP information as follows:
Schedule P Part I Column | ONESOURCE PTEP Category |
|---|---|
(a) Reclassified section 965(a) PTEP | 959(c)(1)(A) 965(a) OWN & SUB |
(b) Reclassified section 965(b) PTEP | 959(c)(1)(A) 965(b) OWN & SUB |
(c) General section 959(c)(1) PTEP | 959(c)(1)(A) Investment in U.S. Property + Subpart F + Excess Passive Assets (Section 959(c)(1)(B)) OWN & SUB |
(d) Reclassified section 951A PTEP | 959(c)(1)(A) GILTI OWN & SUB |
(e) Reclassified section 245A(d) PTEP | 959(c)(1)(A) 245A(e)(2), 959(e) and 964(e)(4) OWN & SUB |
(f) Section 965(a) PTEP | 959(c)(2) 965(a) OWN & SUB |
(g) Section 965(b) PTEP | 959(c)(2) 965(b) OWN & SUB |
(h) Section 951A PTEP | 959(c)(2) GILTI OWN & SUB |
(i) Section 245A(d) PTEP | 959(c)(2) 245A(e)(2), 959(e) and 964(e)(4) OWN & SUB |
(j) Section 951(a)(1)(A) PTEP | 959(c)(2) Subpart F OWN & SUB |
ONESOURCE creates a single Schedule P that represents the consolidated group ownership. During Subpart F calculations, the U.S. Dollar basis of Previously Taxed E&P is calculated using beginning balance information from the
PTI in US$ Basis
data entry screen and amounts calculated on the Post-86/Pre-87 PTI Exchange Gain/Loss reports. These U.S. Dollar amounts will be multiplied by the aggregate ownership of related FTC binders that are 10% or greater shareholders or those with CFC Overrides set to Treat as a US. Shareholder over the sum of the related and unrelated qualified FTC ownership percentage.When the
International Compute > Transfer to US5471, US8865, US8858
runs, earnings & profits activity is transferred by basket directly to the Organizer Schedule P Part II as follows:Tax Return Line | Column(s) | Source of Data |
|---|---|---|
1a. Balance at beginning of year | a – b, d | PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(1)(A) (for PTEP category)For a – b ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
c | PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(1)(A) for PTEP categories related to 956 and Subpart FPlus PTI in US$ Data Entry screen | Pre 87 tab | Beginning Balance U.S. Dollar section for 959(c)(1)Plus PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(1)(B))Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
e | PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(1)(a) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4)Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
f – h, j | PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(2) (for PTEP category)Plus for j ONLY PTI in US$ Data Entry screen | Pre 87 tab | Beginning Balance U.S. Dollar section for 959(c)(2))For f-g & j ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
i | PTI in US$ Data Entry screen | Post 86 tab | Beginning Balance U.S. Dollar section | 959(c)(2) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4)Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
1b. Beginning balance adjustments | a – b, d | PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(1)(A) (for PTEP category)For a – b ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
c | PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(1)(A) for PTEP categories related to 956 and Subpart FPlus PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(1)(B)Plus PTI in US$ Data Entry screen | Pre 87 tab | Made in Current Year Adjustment U.S. Dollar section for 959(c)(1))Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
e | PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(1)(A) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4))Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
f – h, j | PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(2) (for PTEP category)Plus for j ONLY PTI in US$ Data Entry screen | Pre 87 tab | Made in Current Year Adjustment U.S. Dollar section for 959(c)(2))For f – g & j Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
i | PTI in US$ Data Entry screen | Post 86 tab | Made in Current Year Adjustment U.S. Dollar section | 959(c)(2) (for PTEP categories 245A(e)(2), 959(e) and 964(e)(4))Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
3. Previously taxed E&P attributable to distributions of previously taxed E&P from lower tier foreign corporation | a – b, d | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Lower Tier Dividends - Sec 959(b) | 959(c)(1)(a) (for PTEP category) For a – b ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
c | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Lower Tier Dividends - Sec 959(b) | 959(c)(1)(a) for PTEP categories 956 and Subpart F Plus PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Lower Tier Dividends - Sec 959(b) | 959(c)(1)(B)) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
e | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Lower Tier Dividends - Sec 959(b) | 959(c)(1)(a) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4)) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
f – h, j | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Lower Tier Dividends - Sec 959(b) | 959(c)(2) (for PTEP category) For f – g & j Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
i | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Current Subpart F and GILTI Inclusions | 959(c)(2) Subpart F column) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
7. Amounts reclassified to section 959(c)(2) EP from section 959(c)(3) EP | h | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Current Subpart F and GILTI Inclusions | 959(c)(2) GILTI column |
j | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | 959(c)(2) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4)) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
8. Actual distributions of previously taxed income | a – b, d | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(1)(a) (for PTEP category) * -1 For a – b ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
c | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(1)(a) for PTEP categories related to 956 and Subpart F * -1 Plus PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(1)(B) * -1) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
e | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(1)(a) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4) * -1 Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
f – h, j | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(2) (for PTEP category) * -1 For f – g & j Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
i | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current Distributions | 959(c)(2) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4) * -1 | |
9. Amounts reclassified to section 959(c)(1) EP from section 959(c)(2) EP | a – b, d | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(1)(a) (for PTEP category) For a – b ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
c | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(1)(B) Plus Pre-87 PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Current 956/956A Inclusions for 959(c)(2) * -1 Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
e | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(1)(a) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4 Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
f – h, j | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(2) (for PTEP category) Plus for j ONLY Pre-87 PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section |Current 956/956A Inclusions for 959(c)(2)) For f – g & j ONLY Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
i | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(2) for PTEP categories related to 245A(e)(2), 959(e) and 964(e)(4 Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership | |
10. Amounts included as earnings invested in U.S. property and reclassified to section 959(c)(1) EP | c | PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section | Total Current 956/956A Inclusions | 959(c)(1)(a) 956 Plus Pre-87 PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section |Current 956/956A Inclusions for 959(c)(1) Less Pre-87 PTI Exchange Gain/Loss Report | PTI - U.S. DOLLAR BASIS Section |Current 956/956A Inclusions for 959(c)(2) *-1)) Multiplied by Aggregate Related FTC US Shareholder Ownership / Aggregate Related and Unrelated FTC US Shareholder Ownership |
Rows Requiring Manual Data Entry
ONESOURCE Income Tax International does not capture all the information requested on Schedule P. Data must be manually entered for the following rows and will be retained for Passive and General Limitation (but not a Section 901(j) basket) during subsequent transfers:
2. Reduction for taxes unsuspended under anti-splitter rules
4. E&P carried over in nonrecognition transaction
5. Other adjustments
11. Other adjustments
note
Before transferring new results, the
International Compute
deletes existing information in the schedule in any row that is populated by computes. However, information entered in Organizer in the lines listed in the Rows Requiring Manual Data Entry
section are retained during subsequent international compute transfers for Passive and General Limitation. All data you enter in any row for a Section 901(j) basket is deleted when the International Compute > Transfer to US5471, US8865, US8858
runs. You must check the Schedule P
box on the INTL Transfer Options
page in Organizer on the 5471
navigation tree to retain Schedule P information entered on a row populated by calculations or in a Section 901(j) basket by preventing additional transfers to the schedule from International Computes. If you do not check the box, you will lose any Organizer overrides (even if the Organizer field is locked) for Schedule P, unless otherwise noted, when you next run International Compute > Transfer to US5471, US8865, US8858
for the binder.