This Schedule M Form 5471 guide explains the IRS Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons. Schedule M for Form 5471 organizes the related-party transactions described in the applicable instructions. The identity of the counterparty and transaction category matter. Cash flow summaries alone may not identify the categories required by the schedule.
Reviewed October 31, 2026. This is an independent guide. The version and availability information below identifies the IRS documents used for this page.
What Schedule M Form 5471 does and who prepares it
A required Form 5471 filer discloses the covered transactions between the CFC and shareholders or other related persons.
For the connected reporting route, see Form 5471. Keep the role of that document separate from the task explained on this page.
| Official form | Form 5471 (Schedule M) |
|---|---|
| IRS title | Transactions Between Controlled Foreign Corporation and Shareholders or Other Related Persons |
| Guide period | the applicable reporting period |
| Target version | Dec 2021 |
| Availability | Current IRS catalog PDF |
| Last checked | October 31, 2026 |
Get the Schedule M Form 5471 PDF and check its status
Use the IRS source to confirm the document before completing a real filing. The download link is a reference to the official file; it is not a statement that every copy inside the PDF may be printed and submitted. Follow any instructions about electronic filing, scannable copies, recipient copies or attachments.
Which version of Schedule M Form 5471 should you use?
This form follows a revision or continuing-use format rather than a new title for every calendar year. Check the revision printed on the document and the period requested inside it. A revision date, transaction date and tax year are different pieces of information. The current document should be read with the instructions that apply to the actual transaction or return.
Records to gather for Schedule M Form 5471
- Related-party transaction ledger.
- Counterparty ownership information.
- Intercompany agreements.
- Balances and payments.
- Foreign corporation books.
Keep a working reconciliation with these records. It should show the source of each reported item, any correction made before filing and the reason a different amount appears on a connected form. This is especially useful when a statement is corrected or a prior-year balance continues into the current calculation.
How to work through Schedule M Form 5471
- Confirm applicability. Start with the purpose, filer category and version of the form. Complete any eligibility or applicability question before spending time on the numerical calculation.
- Prepare the source workpapers. Gather the records listed below and reconcile their totals. Keep prior-year balances, current-year transactions and estimated payments separate where they serve different purposes.
- Complete dependent calculations first. When a line refers to another form, schedule or worksheet, finish that supporting calculation first. Preserve any classification, limitation and carryforward information.
- Follow the line sequence. Use the actual line labels and arithmetic in the applicable form. A line number from an older version may refer to something different after a revision.
- Reconcile the filing package. Check names, identifying numbers, tax periods, totals and required attachments. Then use the filing method, signature process and deadline that apply to this filer and form.
Form-specific IRS instructions and reporting details
The following points retain the operative wording of the IRS documents linked above. Read each point with its stated conditions and the applicable form version. References to another form or section describe a connected requirement; they do not mean that every reader must file every referenced document.
A foreign corporation may qualify as an expatriated foreign subsidiary under Regulations section 1.7874-12(a)(9) if such foreign corporation is a CFC with respect to which an expatriated entity, as defined in Regulations section 1.7874-12(a)(8), is a U.S. shareholder. Certain transactions involving an expatriated foreign subsidiary and/or its U.S. shareholders may be subject to special rules.
If the answer to Question 10 is “Yes,” attach a statement providing the name and EIN of the domestic corporation or partnership, as defined in Regulations section 1.7874-12(a)(6), and the relationship of the foreign corporation to the domestic corporation or partnership.
During the tax year, did the CFC have any gains or losses that (a) arise out of commodity hedging transactions; (b) are active business gains or losses from the sale of commodities (and substantially all of the corporation’s commodities are property described in section 1221(a)(1), (2), or (8)); or (c) are foreign currency gains or losses (as defined in section 988(b)) attributable to any section 988 transactions?
Additional reporting conditions
10 During the tax year, did the CFC receive dividends* or interest** from a related person that (a) is a corporation created or organized under the laws of the same country under the laws of which the CFC is created or organized, and (b) has a substantial part of its assets used in its trade or business located in the same foreign country? *Dividends (other than dividends with respect to any stock, which are attributable to E&P of the distributing corporation accumulated during any period during which the person receiving such dividend did not hold such stock directly or indirectly through a chain of one or more subsidiaries each of which meets requirements (a) and (b)). **Interest (other than interest that reduces the payor’s subpart F income or creates or increases a deficit that may reduce the subpart F income of the payor or another CFC).
11 During the tax year, did the CFC receive, from a corporation In other words, are that is a related person, rents or royalties* for the use of, or any amounts privilege of using, property within the country under the laws of described in section which the CFC is created or organized? 954(c)(3)(A)(ii) *Rents or royalties (other than rents or royalties that reduce the excluded from line 1a payor’s subpart F income or create or increase a deficit that of Worksheet A? may reduce the subpart F income of the payor or another CFC).
Calculations and supporting information
Every U.S. person described in Category 4 must file Schedule M to report the transactions that occurred during the foreign corporation’s annual accounting period ending with or within the U.S. person’s tax year.
Every U.S. citizen or resident described in Category 2 must complete Part I. Every U.S. person described in Category 3 must complete Part II. See Regulations section 1.6046-1(i) for rules on determining when U.S. persons constructively own stock of a foreign corporation and are therefore subject to the section 6046 filing requirements. Name of person filing Form 5471. The name of the person filing Form 5471 is generally the name of the U.S. person described in the applicable category or categories of filers (see Categories of Filers, earlier).
However, in the case of a consolidated return, enter the name of the U.S. parent in the field for “Name of person filing Form 5471.” Reference ID number of foreign corporation. Use the reference ID number shown on Form 5471, page 1, item 1b(2).
Part I Column (d). Enter the date the shareholder first acquired 10% or more (in value or voting power) of the outstanding stock of the foreign corporation. Column (e). Enter the date the shareholder acquired (whether in one or more transactions) an additional 10% or more (in value or voting power) of the outstanding stock of the foreign corporation.
Exceptions and related reporting
The purchase represented 10% ownership of the foreign corporation. On July 1, 2025, Alex made a gift of 5,000 shares of foreign Corporation X to his child. Because Alex has reduced his holding in the foreign corporation, he is required to complete Form 5471 and Schedule O.
To show the required information about the disposition, Alex completes Section D as follows. • Enters his name in column (a). • Enters “common” in column (b). • Enters “July 1, 2025” in column (c). • Enters “gift” in column (d). • Enters “5,000” in column (e)(1). • Enters “-0-” in column (f) because the disposition was by gift. • Enters the name and address of his child in column (g).
Further form details
A foreign corporation may have PTEP in a PTEP group within any of the separate categories of income, with the exception of foreign branch category income. See Regulations section 1.960-3(c)(1). If code 901j is entered on line a, enter on line b the country code for the sanctioned country using the two-letter code (from the list at IRS.gov/CountryCodes). Note: A separate Schedule P should not be completed for the section 951A category.
Reclassified section 951A PTEP and section 951A PTEP that is in the section 951A category should be reported on the Schedule P completed for the general category. Note: For purposes of this Schedule P, include in each separate category of income, foreign source and U.S. source income. Important.
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 P using code “TOTAL” that aggregates all amounts listed for each line and column of all other Schedules P.
Further form details
Specific Instructions for Schedule Q Name of person filing Form 5471. The name of the person filing Form 5471 is generally the name of the U.S. person described in the applicable category or categories of filers (see Categories of Filers, earlier). However, in the case of a consolidated return, enter the name of the U.S. parent in the field for “Name of person filing Form 5471.” Reference ID number of foreign corporation. If applicable, use the reference ID number shown on Form 5471, page 1, item 1b(2). Line A.
Complete a separate Schedule Q for each applicable separate category of income. Enter the appropriate code from the table below for the separate category of income with respect to which the Schedule Q is being completed.
Schedule M to report the transactions that occurred during the foreign corporation’s annual accounting period ending with or within the U.S. person’s tax year.
Reading the lines and boxes
These selected labels come from the linked target PDF. They are a reading aid, not a replacement for the full line instructions or a completed calculation. Match the label and document version before transferring any amount.
| Line or box | Label in the source form | What to check |
|---|---|---|
| 1 | Sales of stock in trade (inventory) | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 2 | Sales of tangible property other than stock | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 3 | Sales of property rights | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 4 | Platform contribution transaction payments | Reconcile the relevant payment or withholding record with the tax period and category requested here. A reported payment is not necessarily the final tax liability. |
| 5 | Cost sharing transaction payments received | Reconcile the relevant payment or withholding record with the tax period and category requested here. A reported payment is not necessarily the final tax liability. |
Further selected fields
| Line or box | Label in the source form | What to check |
|---|---|---|
| 6 | Compensation received for technical, | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 7 | Commissions received | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 8 | Rents, royalties, and license fees received | Check the applicable line instructions and keep the source workpaper with the return records. Transfer only the information that matches the field and reporting period. |
| 9 | Hybrid dividends received (see instructions) | Follow the stated arithmetic and line references in sequence. Complete the referenced inputs first and retain the worksheet supporting the result. |
| 10 | Dividends received (exclude hybrid dividends, | Follow the stated arithmetic and line references in sequence. Complete the referenced inputs first and retain the worksheet supporting the result. |
A practical example
A CFC buys services from one related party and makes another type of payment to a shareholder. The preparer separates the transaction categories and checks the counterparty relationships before completing the disclosure.
This example illustrates the order of the review. It does not assume an unverified deduction, exemption, treaty rate or final tax amount. The applicable form instructions and the actual records determine the result.
Common mistakes to avoid with Schedule M Form 5471
- Use the applicable related-person definitions.
- Keep transaction categories identifiable.
- Reconcile the reported amounts with the underlying entity records and other disclosures.
Questions about Schedule M Form 5471
Does receiving or downloading this form mean I must file it?
A required Form 5471 filer discloses the covered transactions between the CFC and shareholders or other related persons. The form purpose and the applicable filing or furnishing conditions determine the action. Downloading a blank PDF does not itself create a filing obligation or establish eligibility for a tax benefit.
Is the revision date always the same as the tax year?
No. Some forms show a tax year, while continuing-use forms show a revision date and ask separately for the reporting period. Check the actual document and instructions. Do not relabel a payment or transaction solely because it was reported in a later calendar year.
What should I do if the underlying information is wrong?
Use the applicable related-person definitions. Keep the original record and the correction trail. The issuer correction process, an amended return and an updated certificate can be different procedures. Choose the process that matches the document and the actual error.
Which records should I keep with the completed form?
Retain the source documents, applicable worksheets, submitted version and filing or furnishing confirmations. For this form, the working file should include related-party transaction ledger, counterparty ownership information, intercompany agreements. Keep continuing balances and prior-year support for as long as they remain relevant under the applicable recordkeeping rules.
Related forms and next steps
Use these guides when the connected issue applies to your records. Each page has its own purpose, reporting year and availability status.