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Schedules Q & R, Form 5471: Reporting CFC Income by CFC Income Groups and Distributions From a Foreign Corporation

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, February 14, 2023

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This webinar will explain preparing the recently added Schedule Q, Certain Foreign Corporation (CFC) Income by CFC Income Groups, and Schedule R, Distributions From a Foreign Corporation, of Form 5471. Our panel of international tax veterans will discuss the legislative background necessitating the addition of these schedules and provide a line-by-line review of Schedules Q and R for international tax practitioners.


Form 5471, Information Return of U.S. Persons With Respect To Certain Foreign Corporations, is one of the most comprehensive and complex forms required of foreign tax professionals. Schedules Q and R have been added to its numerous schedules to accommodate recent legislative changes. Schedule Q was added to facilitate the computation of the foreign tax credit considering the high-tax exception, high-tax kickout, Section 962 elections, and Section 960 deemed taxes paid.

Schedule R was added to report distributions from foreign corporations required under Sections 245A, 959, and 986(c). Columns (a) through (d) report the nature and amount of these distributions. All distributions made during a tax year should be reported on this schedule.

Specific line items on Schedules Q and R should agree with amounts reported elsewhere on Form 5471; tax software often cannot ensure these schedules are appropriately completed. International tax practitioners need to grasp the nuances of these new schedules and ensure they are correctly prepared.

Listen as our panel of international tax reporting experts provides advice and the background necessary to prepare Form 5471 Schedules Q and R correctly.



  1. Form 5471 and Controlled Foreign Corporations
  2. Schedule Q, CFC Income by CFC Income Groups
    1. Background
    2. Line-by-line review
  3. Schedule R, Distributions From a Foreign Corporation
    1. Background
    2. Line-by-line review
  4. Best practices


The panel will review these and other critical issues:

  • Which category of filers are required to complete Schedules Q and R?
  • Categorizing tested income on Schedule Q
  • Reporting property transfers and the related liability on Schedule R
  • Applicable tax guidance requiring the addition of schedules Q and R
  • Interplay and agreement with other Form 5471 Schedules


Naumoski, Darko
Darko Naumoski, CPA

WilkinGuttenplan CPAs & Advisors

Mr. Naumoski, joined the firm in 2017, specializes in international taxation and planning strategies....  |  Read More

Diaz Colon, Franchelly
Franchelly (Chelly) Diaz Colon, CPA, MSL

Senior Manager
WilkinGuttenplan CPAs & Advisors

Ms. Diaz Colon specializes in international tax matters including CFC/PFIC rules, cross-border mergers and...  |  Read More

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