Form 5471 Schedule J, Accumulated Earnings of Controlled Foreign Corporations: Line-by-Line

Deep Dive Into Additional Categories, Classifications, and Sections of Complex Schedule J

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, November 9, 2021

Recorded event now available

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Course Materials

This course will provide tax advisers with a practical, in-depth guide to completing Form 5471's recently revised Schedule J, Accumulated Earnings & Profits (E&P) of Controlled Foreign Corporations. The panel will take a line-by-line approach to the form, discussing each of the income items listed in the various sub-sections of IRC 959, and detail how to identify the Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income required in Part II. This is an advanced level webinar for attendees well versed in prior revisions of Form 5471.


The impact of the 2017 tax reform law added to the complexity and compliance burden of virtually all foreign tax information reporting. Multiple provisions in the law increased the calculation, payment, and reporting obligations on U.S. taxpayers with foreign income or assets and foreign taxpayers with activities subject to U.S. tax jurisdiction. The law created new forms and modified several of the most complicated existing schedules.

Form 5471 was already considered one of the most complicated reporting obligations in the U.S. offshore information tax reporting regime before tax reform, notably Schedule J, Accumulated Earnings and Profits (E&P) of Controlled Foreign Corporations. However, the deemed repatriation provisions necessitated a modification of Schedule J, involving a longer and significantly more complicated set of calculations.

The new Schedule J contains additional categories of accumulated E&P and new requirements to calculate and disclose reclassifications within various sub-sections of IRC 959 that were not present in prior revisions of the form. The Schedule also contains an additional part and several new columns requiring taxpayers to report current and recaptured Subpart F income. The new calculations create additional burdens to an already complex form.

Listen as our panel of veteran advisers provides an in-depth, line-by-line, and column-by-column guide to the changes tax reform made to completing Schedule J.



  1. Prior versions of Schedule J
    1. Seven (7) lines of calculations
    2. Five (5) columns of income/E&P classifications
    3. All references to post-1986 balances and carry-forward amounts
  2. Income classifications in revised Schedule J
  3. Calculation questions
  4. Part II Nonpreviously Taxed E&P Subject to Recapture as Subpart F Income (Section 952(c)(2))


The panel will discuss these and other specific changes to Schedule J:

  • Lines and columns required to report accumulated E&P balances concerning categories of previously taxed E&P necessitated by income inclusions under Section 965(a) and GILTI
  • How this schedule incorporates Subpart F inclusions and recaptures
  • How to handle deficit calculations after nonrecognition transactions
  • Reclassification lines


Diosdi, Anthony
Anthony V. Diosdi

Diosdi Ching & Liu

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax...  |  Read More

Dougherty, Alison
Alison N. Dougherty, J.D., LL.M., CPA


Ms. Dougherty specializes in U.S. international tax reporting, compliance, consulting, planning, and structuring as a...  |  Read More

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