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Form 5471 Schedules J, P, H, E: Calculating and Reporting E&P and Foreign Tax Credits

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 Wednesday, December 20, 2023

Recorded event now available

or call 1-800-926-7926

This course will explain and simplify the preparation of Form 5471, Schedules J, P, H, and E for tax preparers grappling with the requirements of these detailed schedules, including the most recent changes made to these schedules.


Properly preparing Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, and its related Schedules J, P, H, and E is complex and crucial. With penalties of $10,000 for not filing the form itself and foreign tax credits at stake, not getting this form and its schedules right could prove costly. Preparing this form requires understanding the underlying and perpetually changing foreign rules that govern this reporting obligation.

Legislative changes have dictated continual changes to Form 5471. Schedule J and Schedule P report accumulated E&P and previously taxed E&P (PTEP) respectively of a CFC in its functional currency. Foreign income is reported in one of six categories with an appropriate code, 951A, RBT (income re-source by treaty), 901(j) (income earned from a sanctioned country), FB (QBUs), in addition to the more familiar passive and general income categories.

Schedule H, Current E&P, is completed by Category 4 and 5 filers to report the foreign corporation's E&P in the CFC's functional currency. Preparing this form includes making appropriate foreign book adjustments to comply with U.S. GAAP and tax reporting requirements.

Schedule E contains seven columns that necessitate reporting accurately and claiming the foreign tax credit after tax reform. Preparers must understand the limitation on FTCs imposed by Sections 901 (what constitutes a tax) and 909 (foreign tax credit splitting) when completing this schedule. Numerous updates have been made to Schedule E this year, including a new "TOTAL" code required for certain taxpayers. Pages 2 and 3 of Schedule E-1 require that taxpayers report amounts in all columns, including column (c), in U.S. dollars rather than the functional currency.

Listen as our panel provides expert insights into the preparation of Schedules J, P, H, and E with Form 5471 and the underlying regulations that mandate their preparation.



  1. Form 5471: an overview
  2. Underlying rules and regulations
  3. Anticipated guidance
  4. Schedule E, Income, War Profits, and Excess Profits Taxes Paid or Accrued
  5. Schedule H, Current E&P
  6. Schedule J, Accumulated E&P of CFCs
  7. Schedule P, PTEP of U.S. Shareholder of CFCs


The panel will review these and other critical issues:

  • Determining which category filers are required to complete Schedules J, P, H, and E of Form 5471
  • Categorizing foreign income into the required categories on Schedule J
  • Understanding the applicable Code sections and regulations relative to Schedules J, P, H, and E of Form 5471
  • Identifying foreign income that is creditworthy


Diosdi, Anthony
Anthony V. Diosdi

Diosdi & 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, CPA

Managing Member
Googolplex Tax

Ms. Dougherty provides U.S. tax reporting, compliance, consulting, planning, and structuring solutions to U.S. and...  |  Read More

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