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CO online Form 5471 (Schedule J): What You Should Know
How to Prepare Schedule J of Form 5471 for Earnings and Profits on a Certain Foreign Entity How to Prepare Schedule J of Form 5471 to Report Earnings & Profits from a Certain Entity to a U.S. Corporate Entity | Form 5471 Schedule J for E&P Apr 23, 2025 — A new Schedule J of Form 5471 is issued to comply with the regulations under section 5948(g) and 5948(h). The new schedule was originally formulated for income tax purposes but can also be used for tax planning purposes to calculate E&P and to help the U.S. Tax Court understands the U.S. person's relationship to a “foreign non-corporate entity”. How to Calculate Earnings at a Foreign Corporation and When To Do It? The U.S. Tax Court recently ruled that a corporation located in Bermuda may not report profits from a U.S. branch of a foreign corporation as part of its U.S. gross income. If you are a U.S. person who will benefit from this, it would help to know that you can calculate how much income will be taxed on your “preferences” by using a simple, yet effective, tool called the Earnings and Profits Estimator (E&P). Earnings and Profits Estimator How E&P Works E&P is a free, easy-to-use tool that I developed for tax planning purposes. It uses multiple regression analysis to calculate how much income will be reported and taxed on the E&P of one or more controlled foreign corporations that are domiciled in the U.S. The IRS requires it be used only to help decide the amount of income tax needed to be paid or owed to the U.S., and it is not to be used in the determination of whether any tax is due. E&P is the U.S. person's personal relationship to a foreign person that may be domiciled in the U.S. The IRS treats each E&P in a given case similarly, so, in most instances, the only difference will be how many of the three categories of income are allocated, taxed and reported to the U.S. person.
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