Number of quarter-ends the foreign corporation was a C.F.C. See section 953(c)(3)(D) for special rules for this election. In addition to the separate category codes referred to above, if you have more than one of the categories of income referred to above, you must complete and file a separate Schedule J using code TOTAL that aggregates all amounts listed for each line and column in Part I of all other Schedules J. Complete a separate Schedule Q for each applicable separate category of income. A separate Schedule P should not be completed for the section 951A category. If a U.S. shareholder wholly owns the CFC, Schedule P should include the same information reported on Schedule J, Part I, column (e). Line 9b. See Regulations section 1.482-7(b)(1)(ii). Foreign income taxes reclassified from section 959(c)(2) previously taxed E&P to section 959(c)(1) previously taxed E&P should be reported as negative numbers in columns (e)(vi) through (e)(x) and as positive numbers in columns (e)(i) through (e)(v). Report as a positive number E&P attributable to distributions of PTEP from lower-tier foreign corporations. Amount excluded, reduction amount, or other amount not reported or reportable, "1.Gross foreign personal holding company income:", "1a.Dividends, interest, royalties, rents, and annuities (section 954(c)(1)(A)) (excluding amounts described in sections 954(c)(2) and (3))" field, "1b.Excess of gains over losses from certain property transactions (section 954(c)(1)(B))" field, "1c.Excess of gains over losses from commodity transactions (section 954(c)(1)(C))" field, "1d. Schedule Q (Form 5471), CFC Income by CFC Income Groups, is used to report the CFC's income in each CFC income group to the U.S. shareholders of the CFC so that the U.S. shareholders can use it to properly complete Form 1118 (Foreign Tax Credit - Corporations) to compute the high-tax exception, high-tax kickout, and Code Sec. A domestic corporation is deemed to pay foreign income taxes with respect to distributions of previously taxed E&P. See the instructions for Form 5471, Schedule I, Line 6 for details. This amount must be converted from functional currency to U.S. dollars using the average exchange rate for the year of the CFC. In item 1g, enter a brief description of the company's business activity. Do not report these amounts on line 1b. From the sale or other disposition of such a contract. Schedule Q (Form 5471) (Rev. As a result, the total amount entered on line 3 may not equal the sum of the amounts reported in columns (ii) through (xiii) on lines 3(1), 3(2), etc., if any tested units tentative tested income is excluded under the GILTI high-tax exclusion (these amounts are included in the total amounts reported on line 4).
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