Form 5471: Reporting Interests in Foreign Corporations
Published November 7, 2026
Form 5471 is used by certain U.S. persons who are officers, directors, or shareholders in certain foreign corporations. The form and its schedules support the reporting required by sections 6038 and 6046 of the tax code.
The Instructions for Form 5471 (Rev. December 2025) explain which pages and schedules each category of filer must complete. This post is general information. It does not cover every category or every schedule.
Who must file
The instructions list several categories of filers. Each category sets which parts of the form apply. If you fit more than one category, do not repeat information, but complete all the items that apply to you.
The instructions give an example. A sole owner of a controlled foreign corporation fits Categories 4 and 5a. That owner completes all six pages of Form 5471 and several separate schedules.
Which revision applies
The instructions say they are for the December 2025 revision of Form 5471. Some separate schedules keep older December revisions: 2024 for Schedules H-1 and Q, 2023 for Schedule G-1, 2021 for Schedules E, H, I-1, and M, 2020 for Schedules J, P, and R, and 2012 for Schedule O. Check the revision date on each schedule you file.
A separate form for each corporation
Complete a separate Form 5471, and the schedules that apply, for each foreign corporation. A single form does not cover two corporations.
Control: more than 50%
For Category 4, a U.S. person has control of a foreign corporation if, at any time during its tax year, it owns stock with more than 50% of the total combined voting power. It also has control if it owns more than 50% of the total value of all classes of stock. A person in control of a corporation that, in turn, owns more than 50% of another corporation is also treated as being in control of that other corporation.
Category 5: a 10% shareholder
A Category 5 filer is a U.S. shareholder who owned stock in a controlled foreign corporation (CFC) at any time during the foreign corporation's tax year. The shareholder must also have owned that stock on the last day of the year in which the corporation was a CFC.
A U.S. shareholder, for this purpose, is a U.S. person who owns, directly, indirectly, or constructively, 10% or more of the total combined voting power or value of the stock of a CFC.
When and where to file
Attach Form 5471 to your income tax return. If a partnership or exempt organization return applies, attach it there instead. File both by the due date, including extensions, for that return.
Zero amounts still need a schedule
When a schedule is required but all amounts are zero, file the schedule with zero amounts. The instructions say a single schedule covers every separate category for schedules that are completed by category.
Penalties
A $10,000 penalty applies for each annual accounting period of each foreign corporation when the information required by section 6038(a) is not furnished on time. If the information is not filed within 90 days after the IRS mails a notice, an additional $10,000 penalty applies. It applies for each 30-day period, or part of one, that the failure continues. The additional penalty is limited to $50,000 for each failure.
Related forms
A U.S. owner of a foreign fund may have a separate filing duty. For that, read Form 8621: Reporting Shares in a Foreign Investment Company. For a report of foreign financial assets, read Form 8938: Reporting Foreign Financial Assets to the IRS.
Checklist
- Identify each foreign corporation in which you are an officer, director, or shareholder.
- Check your ownership percentage against each category.
- Prepare one Form 5471 and its schedules for each corporation.
- Attach the form to your return and file by the return's due date, including extensions.
- Keep copies of the schedules, even when the amounts are zero.
This is general information only. It is not tax advice for your situation.
Sources: Sources: IRS, Instructions for Form 5471 (Rev. December 2025) (https://www.irs.gov/pub/irs-prior/i5471--2025.pdf) This is general information, not advice about your specific return.
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