C3.ai, Inc. ("C3 AI," "C3," or the "Company") (NYSE: AI), the Enterprise AI application software company, today announced financial results for its fiscal third quarter ended January 31, 2023. Proc. "field, "58.Dividends paid to any other person with respect to your stock during the tax year"field, "59.Divide the number of days in the tax year you did not own such stock by the number of days in the tax year and multiply the result by line 56. Other penalties, such as an accuracy-related penalty under section 6662A, may also apply. 501 page is at IRS.gov/Pub501; the Form W-4 page is at IRS.gov/W4; and the . An example of an adjustment entered on Line 6 is the foreign taxes imposed on receipt of a distribution of PTEP from a lowertier foreign corporation. If the information required in a given section exceeds the space provided within that section, do not write See attached in the section and then attach all of the information on additional sheets. Worksheet - - U.S. Column (a) of the attached statement should provide a description of the type of other amount paid during the annual accounting period. For example, with respect to line a at the top of page 1 of Schedule P, there is a new code TOTAL that is required for Schedule P filers in certain circumstances. Foreign tax imposed by reason of a disregarded payment that is a remittance is assigned to the income groups based upon the assets of the payor. Foreign income is reported in one of six categories with an appropriate code, 951A, RBT (income re-source by treaty), 901 (j) (income earned from a . Do not include taxes paid or accrued by the foreign corporation with respect to its receipt of a PTEP distribution, even if those amounts were included in the total entered on line 5, column (l), of Schedule E, Part I, Section 1. The additional sheets must conform with the IRS version of that section. Do not include in column (e)(vi) E&P reported in column (e)(vii). That is, the exchange rate must be reported in terms of the amount by which the functional currency amount must be divided in order to reflect an equivalent amount of U.S. dollars. See Regulations section 1.951A-1(d)(1). Category 1a, 3, and 5a filers should list all direct owners of the SFC or CFC through which such filer indirectly owns the SFC or CFC as described in section 958(a)(2). Enter in functional currency the amount of the E&P reduction made by the foreign corporation for the current tax year that equals the amount required to be included in the income of the U.S. transferor. Otherwise, enter zero. Report the unsuspended taxes on line 2a of column (d) as a positive number. For line 1(a)(2), $75 of gross income is reported in column (ii), $5 of foreign tax is reported in each of columns (x) and (xii), and the checkbox in column (xiv) is not checked. If the person who is filing Form 5471 on behalf of others is married to a person identified in Item H and they are filing Form 1040 jointly, the statement described above does not have to be attached to the jointly filed Form 1040. In other words, are any amounts described in section 954(c)(2)(B) excluded from line 1a of Worksheet A? Column (e)(viii) is PTEP attributable to section 951A inclusions (section 959(c)(2) amounts). If a U.S. shareholder of a CFC is considered to have participated in a reportable transaction under the rules of Regulations section 1.6011-4(c)(3)(i)(G), the shareholder is required to disclose information for each reportable transaction. Section 956(a) amount. These numbers are used to uniquely identify the foreign corporation in order to keep track of the corporation from tax year to tax year. These codes are available at www.iso.org/iso-4217-currency-codes.html or www.currency-iso.org/en/home/tables/table-a1.html. Report the exchange rate using the divide-by convention specified under, Enter the exchange rate used in computing line 5d. If code 901(j) is entered on line a, enter on line b the country code for the sanctioned country using the two-letter codes (from the list at IRS.gov/CountryCodes). A negative $4 will be recorded on line 10, column (e)(x), of CFC1s Form 5471, Schedule E-1. Subtract line 45 from line 44. Income described in section 952(a)(5). Neither Corporation A nor Corporation B has any net deemed tangible income return that would reduce the GILTI inclusion of Corporation A or B. For example: Enter the deductions (including taxes) properly allocable to the amount on line 4 (or to which such deductions would be allocable if there were such gross income). See Regulations sections 1.901(m)-1 through 1.901(m)-8 for additional information. You are generally required to file Earnings and profits described in section 959(c)(1)(A) with respect to the U.S. shareholder after reductions (if any) for current year distributions that affect the U.S. shareholders section 959(c)(1) E&P account" field, "6. Report the inclusion as a positive amount in columns (e)(vi) through (e)(x), as applicable. 9 Sodium chloride is an example of ionic bonding BECAUSE . Instructions for Form 5471(Rev. If the foreign surviving corporation had a deficit in E&P prior to a transaction described in section 381, such deficit is recharacterized as a hovering deficit after such nonrecognition transaction. The instructions to Form 5471, Schedule E note: "adjustments to foreign income taxes paid or accrued in a prior year should not be reflected on Schedule E in the year of adjustment. PTEP attributable to hybrid dividends under section 245A(e)(2) and reclassified as investments in U.S. property. This category includes a U.S. person who had control (defined below) of a foreign corporation during the annual accounting period of the foreign corporation. Lines 1a through 1c. Enter, in the space provided below the title of Form 5471, the annual accounting period of the foreign corporation for which you are furnishing information. Then Mr. Lyons is required to indicate that he is a 10% or more shareholder in corporations F, FI, and FJ. The corporate U.S. shareholder should include the line 5d amount on Form 1120, Schedule C, line 14, column (a), or the comparable line of other corporate income tax returns. REDWOOD CITY, Calif. -- (BUSINESS WIRE)--Mar. Section 6 of Rev. For more information, see Rev. See Regulations section 1.482-7(g) for more information on the methods applicable to PCTs. This amount does not include the amount of dividends that are not eligible for a deduction under section 245A and are instead entered on lines 5b, 5c, and 5d. Schedules E and E-1 are also relevant for non-corporate U.S. shareholders who do not make a section 962 election. Enter the CFCs qualified interest expense, as defined in Regulations section 1.951A4(b)(1)(iii). The Form 5471 schedules have various parts referred and need to ensure you know who needs to fill in part i or part ii for example. If the Schedule Q is being prepared to report the FOGEI or FORI of a CFC, check the box for Item D. Indicate the amount of FOGEI and FORI in each income group. Enter the current year E&P (or deficit in E&P) amount from the applicable line 5c of Schedule H (Form 5471). Changes to separate Schedule J (Form 5471). 2019-40 provides relief for certain types of Category 5 filers. Certain non-corporate U.S. shareholders may elect under section 962 to be taxed at corporate rates on section 951(a) amounts and the GILTI inclusion for the tax year, so as to be able to claim a credit for certain foreign taxes paid or accrued by the CFC. Such tax is related to previously taxed subpart F income. If a U.S. person has appropriately amended the immediately prior year return, including its Schedule E-1, to redetermine its U.S. tax liability, no adjustment should be included on this line. Enter the foreign corporations share of reasonably anticipated benefits (RAB) for the CSA during the tax year. Enter any income equivalent to interest, including income from commitment fees (or similar amounts) for loans actually made. Proc. For schedules that are completed by category (that is, Schedule E, I-1, J, P and Q), inclusion of a single instance of that schedule for any separate category will meet the requirement. The instructions have been updated for each of the aforementioned changes to Form 5471 and separate schedules. 1221. Enter unrealized gain or loss on line 8a and realized gain or loss on line 8b. "field, "52.Section 954(c) subpart F Foreign Base Company Services Income subtotal. Do not include any adjustments required to be reported on line 1b or 12. Line 10. If the name of either the person filing the return or the corporation whose activities are being reported changed within the past 3 years, show the prior name(s) in parentheses after the current name. When a schedule is required but all amounts are zero, the schedule should still be filed with one or more zero amounts. Worksheet- -Summary: This is an example of worksheet A, page 2, which is used to determine the shareholder's share of Subpart F income. Reporting other foreign financial assets. Check the box if taxes were paid on U.S. source income. For a noncorporate U.S. shareholder, enter the result on Schedule 1 (Form 1040), line 8m (other income - section 951(a) inclusion), or on the comparable line of other noncorporate tax returns. Do not report the exchange rate as the number of U.S. dollars that equal one unit of foreign currency. Certain penalties under sections 6038 and 6662 may be waived for certain persons under Rev. We ask for the information on this form to carry out the Internal Revenue laws of the United States. field, "4. As a result, if the foreign corporation has E&P for the tax period covered by this return that is subject to recapture as a result of a prior-year E&P limitation, add such recapture amount to the result from Worksheet A, line 69, and include the combined amount on line 1h (Other subpart F income). If an amount is entered on line 29, you must attach a statement that includes the following information. Any person required to file If necessary, enter negative amounts on line 15 of columns (a), (b), and (c) in amounts sufficient to reduce line 16, columns (a), (b), and (c), to zero. Proc. Category 5b and 5c filers are not required to file Schedule H for foreign-controlled corporations. Tentative section 956 amount. The U.S. filer made or accrued a base erosion payment to, or has a base erosion tax benefit with respect to, the foreign corporation. Column (ix). Enter the code which describes the PTEP group classification (as set forth in Regulations section 1.960-3(c)(2)). Therefore, Schedule I-1 is completed once (for general category income, passive category income, or both). The total present value of all platform contributions made by the U.S. taxpayer during the tax year should be entered even if only a portion (or none) of the value of those platform contributions was included in the U.S. taxpayer's taxable income as platform contribution transaction (PCT) payments during the tax year. Exempt insurance income under section 953(e) and certain investment income of a qualifying insurance company or a qualifying insurance branch (sections 953(a)(2) and 954(i)). Column (e)(iii) is PTEP described in the following three subgroups (which are aggregated into a single PTEP group). Category 4 filers should list all direct owners of the CFC. Enter the line 5c functional currency amount translated into U.S. dollars at the average exchange rate for the foreign corporation's tax year. Check the box on line F if Form 5471 has been completed using alternative information (as defined in section 3.01 of Rev. Also enter foreign income taxes disallowed under section 901(l), which generally applies to certain taxes paid on gain and income other than dividends if the minimum holding period is not met with respect to the underlying property, or if the corporation is obligated to make related payments with respect to positions in similar or related property. Enter this amount in U.S. dollars. Persons With Respect to Certain Foreign Corporations. Line 22. For example, the Form 1040 page is at IRS.gov/Form1040; the Pub. Dividends, interest, rent, or royalty income from related corporate payors described in section 954(c)(3) or (6). In general, tested income will be in a single tested income group within the general category. On pages 2 and 3, Schedule E-1, former line 15 is now line 13 and now requests filers to combine lines 8 through 12 in columns (a), (b), and (c). In column (a), report E&P described in section 959(c)(3) and earned after the repeal of section 902, that is, post-2017 E&P not previously taxed (post-2017 section 959(c)(3) balance). The foreign corporation reports on the cash basis. On page 2, Schedule E-1, columns (a), (b), and (c) have been repurposed. Column (e)(iv) is PTEP originally attributable to inclusions under section 951A and reclassified as investments in U.S. property (section 959(c)(1)(A) amounts). See instructions for Schedule J, Column (e), for specific information about the ten PTEP group columns. These are reported in column (e). The name of the person filing Form 5471 is generally the name of the U.S. person described in the category or categories of filers (see Categories of Filers, earlier). Click on "Open File" and select the form 5471 and open it with the program. 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. Such taxes may include, but are not limited to, certain taxes on the purchase or sale of oil and gas (section 901(f)), certain taxes used to provide subsidies (section 901(i)), and taxes for which no credit is allowed because of the boycott provisions of section 908. Proc. To determine the appropriate code, see Categories of Income in the Instructions for Form 1118. Any other current-year tax is allocated and apportioned among the section 904 categories under the rules of Regulations section 1.904-6(a) based on the portion of the foreign taxable income (as characterized under federal income tax principles) that is assigned to a particular section 904 category. In general, see Regulations section 1.951A4(b)(2) to determine how to compute the CFCs tested interest income. This form is Schedule Q. The taxes added or deducted on line 2g of Schedule H include both foreign income taxes reported in Part I of Schedule E as well as the taxes reported in Part III of Schedule E that are not creditable foreign income taxes. However, Category 1c and 5c filers are not required to file Schedule P for foreign-controlled corporations. If the information is not filed within 90 days after the IRS has mailed a notice of the failure to the U.S. person, an additional $10,000 penalty (per foreign corporation) is charged for each 30-day period, or fraction thereof, during which the failure continues after the 90-day period has expired. If the failure continues 90 days or more after the date the IRS mails notice of the failure to the U.S. person, an additional 5% reduction is made for each 3-month period, or fraction thereof, during which the failure continues after the 90-day period has expired. "field, "65.Translate the amount on line 64 from functional currency to U.S. dollars at the average exchange rate. Enter the amounts on lines 1 through 10c in the CFC's functional currency. As a result, previous line 5a is now line 5. Enter on line 7 E&P as of the close of the tax year before actual distributions or inclusions under section 951(a)(1) or section 951A during the year. Changes to separate Schedule M (Form 5471). Attach a statement detailing any differences between the starting and ending balance reported on line 8c. "field, "64.Amount of line 61 that applies to section 954(c) subpart F Foreign Base Company Sales Income. Do not include any foreign currency gain or loss with respect to PTEP within the reclassified section 965(b) PTEP group or the section 965(b) PTEP group. For purposes only of taking into account income described in section 953(a) (relating to insurance income), a CFC also includes a foreign corporation that is described in section 957(b); and for purposes only of taking into account related person insurance income, a CFC includes a foreign corporation described in section 953(c)(1)(B). Name of the partnership representative (if any). The balance of foreign income taxes paid or accrued with respect to the three income groups that is entered on line 16 should equal zero after taking into account the reductions. A U.S. shareholder who is a Category 1 filer (defined previously) and who is an unrelated section 958(a) U.S. shareholder with respect to a foreign-controlled corporation (defined below) may complete Form 5471 for that foreign-controlled corporation and complete only the information required of a Category 1b filer. The third quarter of the tax year" field, "1d. These amounts are included in the total amount of residual income, which is reported on line 4. PTEP attributable to section 1248 amounts under section 959(e). Section 965 specified foreign corporation (SFC). Enter foreign currency transaction gain or loss reported on the income statement. Attach a statement that includes an explanation and the dollar amount of each such adjustment, along with a total that equals the amount entered on line 1b. Except for columns (a), (b), and (c), which are new this year, this amount should equal the amount that was reported as the balance on line 18 of the prior year Schedule E-1. The REMIC sends Schedule Q to the investor and a copy to the IRS. During the tax year, did the CFC receive, from a corporation that is a related person, rents or royalties* for the use of, or privilege of using, property within the country under the laws of which the CFC is created or organized? A U.S. shareholder who is a Category 1 filer (defined above) must complete Form 5471 and file all information required of a Category 1a filer if that U.S. shareholder does not qualify as a Category 1b or 1c filer. Revenue $66.7 million. Instead, if the foreign corporation is required to file a U.S. income tax return (for example, Form 1120-F), attach the statements to that return.. 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 group. If a U.S. corporation that owns stock in a foreign corporation is a member of a consolidated group, list the common parent as the U.S. person filing Information described in a code listed above qualifies as alternative information only if information described in any preceding code is not readily available (as defined in section 3.04 of Rev. These columns now request information pertaining to subpart F income, tested income, and residual income, respectively. Sum of the amounts from lines 13b, 13d, 13e, 14b, 15b, and 16b. This rule uses the payors asset apportionment percentages as a proxy for the accumulated earnings of the payor taxable unit from which the remittance is made. Such taxes are reported in Part III. See section 989(b). Also, on line 15, report any other reductions to the three income groups in columns (a), (b), and (c) necessary to achieve a zero balance on line 16. hrs 2020 section q: assets and income final version 05/07/2020 ***** note about branchpoints: where there is more than one jump within a branching box, Fill & Sign Online, Print, Email, Fax, or Download Use the December 2020 revision of the schedule. The current year tax is allocated and apportioned to the income group to which an amount of gross income is assigned by reason of the receipt of the reattribution payment. See Regulations section 1.245A-5(f) for further guidance on tiered extraordinary reduction amounts. Because columns (b) and (c) are new this year, the prior year ending balances in columns (b) and (c) will not carry forward to new columns (b) and (c). CFC1, in turn, wholly owns the only class of stock of CFC2, a foreign corporation. (b) During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related party (for example, purchase or sales commission income)? The attached statement must include a totals line that ties into the amounts reported in each column of line 14. See section 965 and the regulations thereunder for exceptions. See Regulations section 1.367(b)-7(b)(1) and (d)(1). Distributions also are taken into account before the section 956 inclusion is determined. Enter the amounts in this schedule in the functional currency of the foreign corporation as reported on Form 5471, page 1, Item 1h Functional Currency. Line 3. A corporation that uses an accrual method of accounting must use accrued payments and accrued receipts for purposes of computing the total amount to enter on each line of Schedule M. Schedule O is used to report the organization or reorganization of a foreign corporation and the acquisition or disposition of its stock. However, insurance income does not include exempt insurance income (as defined in section 953(e)). During the tax year, did the CFC derive income (either directly or through a branch or similar establishment, for example, disregarded entity) in connection with the purchase or sale from, to, or on behalf of a related person, of personal property manufactured in the same country under the laws of which the CFC is created or organized? See specific instructions for Item FAlternative Information Under Rev. ", "40.Section 954(c) subpart F Foreign Personal Holding Company Income subtotal.

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