The functional currency of Domestic Corporation, CFC1, CFC2, and CFC3 is the U.S. dollar. However, if 20% or more of the foreign corporation's gross income is from U.S. sources, depreciation must be figured on a straight line basis according to Regulations section 1.312-15. The LLC should have provided you with a supplemental schedule for how to report. Enter on page 1, Item 1f, the six-digit code selected from the list below. In columns (a), (b), and (c), report only the foreign income taxes the foreign corporation pays or accrues attributable to the subpart F income group, the tested income group, and the residual income group, respectively. Enter the name of the payor entity in column (a). Proc. Domestic Corporation reports on CFC1s Form 5471, Schedule H, on line 2g, a positive adjustment for the $4 of tax on the PTEP distribution. The annual accounting period of an SFC (as defined in section 898) is generally required to be the tax year of the corporation's majority U.S. shareholder. Enter the amount of the U.S. shareholders subpart F income inclusion attributable to tiered hybrid dividends received by the CFC. Shareholder Calculation of Global Intangible Low-Taxed Income. Services, Savings Institutions & Other Depository Credit Intermediation, Real Estate Credit (including mortgage bankers & originators), Intl, Secondary Market, & Other Nondepos. These new columns have been added to reflect Regulations section 1.861-20(e). See Regulations section 1.367(b)-7. Under Sec. The partnerships average adjusted basis in the depreciable tangible property of the partnership is generally determined based on the average of the adjusted basis in the property as of the close of each quarter of the partnerships tax year that ends with or within the CFCs tax year. Inventories must be taken into account according to the rules of There is an election in effect under section 986(a)(1)(D) to translate foreign taxes using the exchange rate in effect on the date of payment. Proc. The total reported on Schedule E, Part I, Section 1, line 5, column (l), should be separated into columns (a) through (e) according to the type of income or E&P to which such taxes relate. Use line 4 to report the information required in columns (i) through (xvi) that is in a section 904 category but that is not of a type that is included in one of the subpart F income groups or a tested income group and is therefore assigned to the residual income group. 2006-45, 2006-45 I.R.B. The corporate U.S. shareholder should include the line 5e amount on Form 1120, Schedule C, line 14, column (a), or the comparable line of other corporate income tax returns. Subtract line 48 from line 47. Current year tax on all other disregarded payments.