Form 5471 (Schedule J) online Kentucky 2020-2025

Form 5471 (Schedule J) online Kentucky: What You Should Know

For the purposes of this section, an CFC is a foreign corporation that is taxed as a C corporation under Code and that either 1) is controlled by one or more persons who are U.S. persons in a transaction or 2) directly or indirectly controls any U.S. person. For purposes of this section, an E&P is an amount of earnings derived by a CFC for U.S. federal income tax purposes from (i) earnings or other taxable income distributed from a branch or an S corporation of which it is the surviving corporation or (ii) from any lease or similar agreement made by a CFC. Generally, the term E&P is synonymous to E&P income for tax purposes. A CFC's E&P is determined by taking into effect the tax effects of a distribution from its retained earnings. When that distribution is not, itself, income from the CFC, it is treated as if it were income from a branch of the corporation, regardless of whether the CFC has any U.S. shareholders. Form 5471 Schedule J: Accumulated E&P of CFC For purposes of this section, a CFC is treated as if it had U.S. shareholders for the purposes of this section regardless of whether the CFC has any current or past U.S. shareholders. Any amounts paid as dividends to such shareholders are not subject to federal income tax because they are treated as payment of capital to the U.S. shareholders for U.S. federal income tax purposes.

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