This Schedule P Form 5471 guide explains the IRS Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations. Schedule P for Form 5471 reports previously taxed earnings and profits of the U.S. shareholder under the applicable categories. Shareholder-specific history and distributions are important. The balances should not be replaced with a CFC total from a different earnings and profits 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 P Form 5471 does and who prepares it
A required filer tracks the shareholder-specific previously taxed earnings and profits information covered by the schedule.
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 P) |
|---|---|
| IRS title | Previously Taxed Earnings and Profits of U.S. Shareholder of Certain Foreign Corporations |
| Guide period | the applicable reporting period |
| Target version | Dec 2020 |
| Availability | Current IRS catalog PDF |
| Last checked | October 31, 2026 |
Get the Schedule P 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 P 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 P Form 5471
- Shareholder prior inclusion records.
- Prior Schedule P balances.
- CFC distributions.
- Category workpapers.
- Ownership changes.
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 P 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 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.
Enter amounts in the functional currency of the foreign corporation as reported on Form 5471, page 1, item 1h. Pre-1987 U.S. dollar PTEP should be translated into the foreign corporation’s functional currency using the rules of Notice 88-70 and added to post-1986 amounts in the appropriate PTEP category.
Additional reporting conditions
Part II Dollar basis. Enter amounts in U.S. dollars. The U.S. shareholder’s U.S. dollar basis in PTEP is generally equal to the U.S. dollar amount of E&P that the U.S. shareholder previously included in gross income. See section 989(b) (1) and (3); and Regulations sections 1.951A-1(d)(1) and 1.965-1(b)(1) and (2). The U.S. shareholder’s U.S. dollar basis is used by the U.S. shareholder to determine the amount of foreign currency gain or loss on the PTEP that the U.S. shareholder is required to recognize under section 986(c). Columns (a) through (k).
Use columns (a) through (k) to report the opening balance of, current-year additions and subtractions to, and the closing balance of, the PTEP in the U.S. shareholder’s annual PTEP accounts with respect to a CFC. Columns (a) through (j) of Schedule P correspond to columns (e)(i) through (e)(x) of Schedule J. See Schedule J, earlier, for specific line instructions. Line 1b.
If there is a difference between last year’s ending balance on Schedule P and the amount that should be last year’s ending balance, taking into account modifications on Schedule P, include the difference on line 1b and attach an explanation for the difference. If there are multiple differences, include the explanation and amount of each such difference on the attachment.
Use Schedule Q to report the CFC’s income, deductions, taxes, and assets by CFC income groups for purposes of section 960(a) and (d).
Calculations and supporting information
Expand the Schedule Q if you are reporting with respect to more than two units. Specifically, if you are reporting with respect to more than two units, add to pages 1 to 4, as appropriate, new lines (3), (4), (5), etc., in all necessary locations.
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.
Exceptions and related reporting
If code 901j is entered on line A, enter on line 1m, column (i), the country code for the sanctioned country using the two-letter code (from the list at IRS.gov/ CountryCodes). 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 Q using code “TOTAL” that aggregates all amounts listed for each line and column in all other Schedules Q. Line B.
If category code “PAS” is entered on line A, a separate Schedule Q must be completed for each applicable grouping under Regulations section 1.904-4(c) (3). See Regulations sections 1.954-1(c)(1)(iii)(B) and 1.904-4(c)(3) through (5). Enter on line B the appropriate code from the table below for each of the following groups under Regulations section 1.904-4(c)(3).
All passive income received during the tax year that is subject to a withholding tax of 15% or greater must be treated as one item of income. See Regulations section 1.904-4(c)(3)(i).
All passive income received during the tax year that is subject to a withholding tax of less than 15% (but greater than zero) must be treated as one item of income. See Regulations section 1.904-4(c)(3)(ii).
All passive income received during the tax year that is subject to no withholding tax or other foreign tax must be treated as one item of income. See Regulations section 1.904-4(c)(3)(iii).
Further form details
All passive income received during the tax year that is subject to no withholding tax but is subject to foreign tax other than a withholding tax must be treated as one item of income. See Regulations section 1.904-4(c)(3)(iv).
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 |
|---|---|---|
| 1a | Balance at beginning of year (see instructions) | Use the date or tax period requested by this particular field. A payment date, acquisition date and return year can describe different facts. |
| 2 | Reduction for taxes unsuspended under anti-splitter rules | 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 | Previously taxed E&P attributable to distributions of previously taxed E&P from lower-tier foreign corporation | 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 | Previously taxed E&P carried over in nonrecognition transaction | 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. |
| 5 | Other adjustments (attach statement) | 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. |
Further selected fields
| Line or box | Label in the source form | What to check |
|---|---|---|
| 6 | Total previously taxed E&P (combine lines 1c through 5) | Follow the stated arithmetic and line references in sequence. Complete the referenced inputs first and retain the worksheet supporting the result. |
| 7 | Amounts reclassified to section 959(c)(2) E&P from section 959(c)(3) E&P | 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 | Actual distributions of previously taxed E&P | 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 | Amounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P | 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. |
| 10 | Amounts included as earnings invested in U.S. property and reclassified to section 959(c)(1) E&P (see | 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. |
A practical example
A shareholder receives a distribution from a CFC and has previously taxed earnings history. The preparer reviews the shareholder categories and prior balances before determining the supported current-year changes.
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 P Form 5471
- Keep shareholder-level and corporation-level balances separate.
- Preserve historical category information.
- Reconcile distributions and adjustments with related schedules.
Questions about Schedule P Form 5471
Does receiving or downloading this form mean I must file it?
A required filer tracks the shareholder-specific previously taxed earnings and profits information covered by the schedule. 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?
Keep shareholder-level and corporation-level balances separate. 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 shareholder prior inclusion records, prior Schedule P balances, CFC distributions. 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.
- Form 5471: PDF & Foreign Corporations Guide
- Schedule J (Form 5471): PDF & Accumulated Earnings and Profits (E&P) of Controlled Foreign Corporation Guide
- Schedule R (Form 5471): PDF & Distributions From a Foreign Corporation Guide
- Schedule I-1 (Form 5471): PDF & Information for Global Intangible Low-Taxed Income Guide