CFC1, in turn, wholly owns the only class of stock of CFC2, a foreign corporation. Qualified Interest Expense Next, we will calculate "qualified interest expense". (b) Address of shareholder. Column (a) of the attached statement should provide a description of the type of other amount paid during the annual accounting period. With respect to foreign currency gain or loss on a distribution of GILTI: For a corporate U.S. shareholder, include the gain or (loss) as Other income on Form 1120, line 10, or on the comparable line of other corporate tax returns. Complete a separate Schedule Q for each applicable separate category of income. In other words, are any amounts excluded from line 3 of Worksheet A by reason of disregarding a branch or similar establishment (including a disregarded entity) of the CFC as separate from the CFC? F is also a 50% owner of foreign corporation FK. Also, if a U.S. shareholder is required to file Schedule A (Form 8992) or Schedule B (Form 8992) with respect to the CFC, the reference ID number on Form 5471 and the reference ID number on Schedule A (Form 8992) or Schedule B (Form 8992) for that CFC must be the same. See section 989(b). Employee benefit plan determinations The other Schedule Q can come into play when a company or organization is setting up or making changes to a pension or retirement savings plan, such as a 401 (k), or some other employee benefit plan. If previously taxed E&P (PTEP) were distributed, enter the amount of foreign currency gain or (loss) recognized on the distribution, computed under section 986(c). Every U.S. person described in Category 3 must complete Part II. You must round the result to more than four places if failure to do so would materially distort the exchange rate or the equivalent amount of U.S. dollars. Enter on line 5e dividends not reported on line 5a, 5b, 5c, or 5d. Proc. In general, see Regulations section 1.951A4(b)(2) to determine how to compute the CFCs tested interest income. In the case of an entity classification election that is made on behalf of a foreign corporation on Form 8832, Regulations section 301.6109-1(b)(2)(v) requires the foreign corporation to have an EIN for this election. 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. shareholders annual PTEP accounts with respect to a CFC. The foreign corporation reports on the cash basis. Exceeded guidance. When filing Schedule O, report acquisitions, dispositions, and organizations or reorganizations that occurred during your tax year. Form 5471, officially called the Information Return of U.S. An actual distribution is first out of PTEP, if any, and then out of the section 959(c)(3) balance. Do not net positions. Because Mr. Jackson has reduced his holding in the foreign corporation, he is required to complete Form 5471 and Schedule O. If possible, include a reasonable present value estimate for any PCTs that are priced using a method that does not involve the calculation of a present value. QBAI is the average of the CFC's aggregate adjusted bases, as of the close of each quarter of its taxable year, in specified tangible property used in its trade or business in the production of tested income, and for which a deduction is allowable under section 167. Subtract line 21b from line 21a" field, "21d.Net related person insurance income excluded under high-tax exception" field, "21e.Subtract line 21d from line 21c" field, "22.International boycott income (section 952(a)(3))" field, "23.Illegal bribes, kickbacks, and other payments (section 952(a)(4))" field, "24.Enter the portion of line 13h that is U.S. source income effectively connected with a U.S. trade or business (section 952(b))" field, "25.Exclusions under section 959(b) that apply to line 13h amount" field, "26.Section 954(c) subpart F Foreign Personal Holding Company Income. No 7004 Extension Required Some forms require the taxpayer to file Form 7004 in order to request an extension. during the tax year" field, "3. Form 5471 requires information and details about the corporation's ownership, stock transactions, shareholder and company transactions, foreign taxes, foreign bank and financial accounts, accumulated earnings and profits, and currency conversions. Taxes are deemed paid by a domestic corporation that is a U.S. shareholder or a foreign corporation that is a controlled foreign corporation with respect to distributions of PTEP that it receives. Category 1a, 1c, 3, 4, 5a, and 5c filers must complete Part II. A foreign corporation may have E&P in an income group within the general category, passive category, or section 901(j) category. Attach a statement with a description and the amount of any adjustments required before taking into account taxes deemed paid by the foreign corporation. A U.S. shareholder who is a Category 1 filer (defined above) must continue to file all information required (see below) as long as: The section 965 SFC has accumulated E&P related to section 965 that is reportable on Schedule J (Form 5471), or. The amount of U.S. property held (directly or indirectly) by the CFC does not include any item that was acquired by the foreign corporation before it became a CFC, except for the property acquired before the foreign corporation became a CFC that exceeds the applicable earnings (as defined in section 956(b)) accumulated during periods before it became a CFC. See Regulations section 1.245A(e)-1(d) for more on maintenance of hybrid deduction accounts. Therefore, Schedule I-1 is completed once (for general category income, passive category income, or both). Schedule E must be completed even for non-corporate U.S. shareholders. Related person insurance income is any insurance income (within the meaning of section 953(a)) attributable to a policy of insurance or reinsurance for which the person insured (directly or indirectly) is a U.S. shareholder (as defined in section 953(c)(1)(A)) in a CFC (as defined in section 953(c)(1)(B)), or a related person (as defined in section 953(c)(6)) to such a shareholder. The balances in the previously taxed accounts of prior section 956 inclusions (see section 959(c)(1)(A)) and current or prior subpart F inclusions (see section 959(c)(2)) reduce what would otherwise be the current section 956 inclusion. The foreign income taxes reported on Schedule E may differ from the amount reported as income tax expense on line 21a of Schedule C. This is due in part to differences in the accounting for foreign tax redeterminations, disallowed taxes, and foreign income taxes reported in Other Comprehensive Income for U.S. GAAP purposes. If the foreign corporation is the tax owner of an FDE or FB and you are not a Category 1b, 4, or 5 filer of Form 5471, you must attach the statement described below in lieu of Form 8858. Report these amounts in U.S. dollars. See Regulations section 1.9603(c)(1). If the U.S. taxpayer engaged in multiple PCTs during the tax year with the foreign corporation and used different methods to price the PCTs, check the appropriate boxes on line 5c to indicate which methods were selected as the best method for one or more of the PCTs reported in the tax year. CFC2 reclassifies such amount as section 959(c)(1) previously taxed E&P on Schedule J. Proc. The adjusted issue price of a debt instrument is the issue price increased by the amount of original issue discount previously includible in gross income of any holder and decreased by payments other than payments of stated interest. This amount must be converted from functional currency to U.S. dollars using the average exchange rate for the year of the CFC. If so, did the foreign corporation derive any interest or dividend or equivalent amount described in section 954(c)(1)(E) or (G) from any transaction entered into in the ordinary course of its trade or business as a securities dealer? The reported amount should reflect the balance of the hybrid deduction accounts as of the close of the tax year of the CFC, and after all adjustments to the hybrid deduction accounts for the tax year (for example, to reflect hybrid deductions of the CFC, or hybrid dividends paid by the CFC). Use Schedule Q to determine the taxes attributable to each income group. If there are multiple differences, include the explanation and amount of each such difference on the attachment. Otherwise, attach a brief statement of the reason(s) it is not possible to include a present value estimate for one or more PCTs (for example, no revenue projections for a PCT that is priced based on a sales-based royalty from a comparable uncontrolled transaction). 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. See Regulations sections 1.954-1(c)(1)(iii)(B) and 1.904-4(c)(3) through (5). Enter the appropriate code on line a (at the top of page 1 of Schedule P). 2019-40, earlier, for more details. Report on line 9 the sum of tiered hybrid dividends received by the foreign corporation during its tax year. This column is used to report current tax imposed solely by reason of the receipt of a disregarded payment other than a reattribution payment, and which is therefore either a remittance or a contribution. CFC1 has a December 31 tax year end for both foreign and U.S. tax purposes. See section 959(a)(2) and (f)(1). If Yes, enter the amount from the current year Form 8990, line 31. Schedules Q and R have been added to its numerous schedules to accommodate recent legislative changes. See Temporary Regulations section 1.921-1T(b)(3). Check the Yes box on line 6a if the filer of this Form 5471 is claiming a deduction under section 250 with respect to foreign-derived intangible income (FDII), and enter the amounts requested on lines 6b, 6c, and 6d. Adjusted net foreign personal holding company income:", "14b.Expenses directly related to amount on line 2" field, "14c.Subtract line 14b from line 14a" field, "14d.Related person interest expense (see section 954(b)(5))" field, "14e.Other expenses allocated and apportioned to the amount on line 2 under section 954(b)(5)" field, "14f.Net foreign personal holding company income. See the instructions for Schedule I-1, No changes have been made to this schedule. Worksheet - - U.S. 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. Category 4 and 5 filers are subject to the subpart F rules for: All other types of FSC income (including section 923(a)(2) nonexempt income within the meaning of Instructions for Form 5471, Information Return of U.S. If there is more than one old reference ID number, you must enter a space between each such number. Form 5471 filers generally use the same category of filer codes used on Form 1118. If you have other foreign financial assets, you may be required to file Form 8938, Statement of Specified Foreign Financial Assets. If the tax is paid or accrued by the pass-through entity, enter the name of such entity instead of the name of the foreign corporation. Section 5 of Rev. The amounts reported on line 1(a)(1) would not be included in the total for line 1(a), but the amount reported on line 1(a)(2) would be included in the total reported on line 1(a). Otherwise, check No. Apply Regulations section 1.385-3(b)(3)(iii)(E) to determine when a debt instrument is treated as issued for purposes of Regulations section 1.385-3(b)(3)(iii). If a section 338 election is made with respect to a qualified stock purchase of a foreign target corporation for which a Form 5471 must be filed: A purchaser (or its U.S. shareholder) must attach a copy of Form 8883, Asset Allocation Statement Under Section 338, to the first Form 5471 for the new foreign target corporation (see the Instructions for Form 8883 for details); A seller (or its U.S. shareholder) must attach a copy of Form 8883 to the last Form 5471 for the old foreign target corporation; A U.S. shareholder that files a section 338 election on behalf of a foreign purchasing corporation that is a controlled foreign corporation pursuant to Regulations section 1.338-2(e)(3) must attach a copy of Form 8023, Elections Under Section 338 for Corporations Making Qualified Stock Purchases, to the Form 5471 filed with respect to the purchasing corporation for the taxable year that includes the acquisition date (see the Instructions for Form 8023 for details). Sum of the amounts from lines 13b, 13d, 13e, 14b, 15b, and 16b. The term base erosion tax benefit generally means any U.S. deduction that is allowed under chapter 1 for the tax year with respect to any base erosion payment. See Regulations section 1.482-7(e) for rules on a determining and updating controlled participants RAB share. Line 11. Form 5471, Schedule I-1, captures CFC income inclusions by U.S. shareholders under Section 951A. On line 3, the phrase (total of lines 2a-2e) has been replaced with (combine lines 2a through 2e) to reflect the fact that negative amounts can be entered on lines 2a through 2e. 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. See Regulations section 1.482-7(b)(1)(ii). New line c has been added at the top of Schedule E to accommodate reporting of treaty countries in cases where a resource by treaty code is entered on line a. 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. Reflect differences between the income tax expense (benefit) reported for book purposes and the income taxes deducted or added to E&P. See section 965 and the regulations thereunder for exceptions. 2019-40 for more details. During Year 1, Domestic Corporation reports an inclusion under section 951(a)(1) of $100 as a result of subpart F income of CFC3. Enter the line 5c functional currency amount translated into U.S. dollars at the average exchange rate for the foreign corporation's tax year. Any listed transaction, which is a transaction that is the same as or substantially similar to one of the types of transactions that the IRS has determined to be a tax avoidance transaction and identified by notice, regulation, or other published guidance as a listed transaction. During its annual accounting period, the foreign corporation paid income taxes of 30,255,400 Yen to Japan. A tax reported on Schedule E, Part I, Section 1, line 5, column (l) for which column (c) was checked because such tax was unsuspended in the current year, should be included as a positive amount in column (a), (b), (c), or (e), as appropriate. Consistent with the reporting requirement on Form 1118, enter the two-letter code (from the list at IRS.gov/CountryCodes) of each foreign country and U.S. possession within which income is sourced and/or to which taxes were paid or accrued. from investment in U.S. property and to translate the amount from functional currency to U.S. dollars. Lines 9 and 24. "field, "44.Shareholders pro rata share of line 40. Check the Yes box on line 17b if any controlling section 245A shareholder (as defined in Regulations section 1.245A-5(i)(2)) made an election to close the tax year of the foreign corporation such that no amount is treated as an extraordinary reduction amount or tiered extraordinary reduction amount as to any U.S. shareholder of the foreign corporation. A foreign corporation may need to report E&P with respect to all categories of income listed in the Instructions for Form 1118, with the exception of foreign branch category income. Proc. Also, see the Instructions for Form 8886. If the foreign corporation uses DASTM, the tax balance sheet on Schedule F should be prepared and translated into U.S. dollars according to Regulations section 1.985-3(d), rather than U.S. GAAP. 2019-40, earlier, for more details. Use column (c) to report the aggregate amount of the foreign corporation's pre-1987 section 964(a) E&P accumulated since 1962 and not previously distributed or deemed distributed. For line 1(a)(1), gross income of $50 is reported in column (ii), foreign tax of $20 is reported in each of columns (x) and (xii), and the checkbox in column (xiv) is checked. Do not report any part of a distribution that is not from earnings and profits. The amount to be entered is computed after application of the high-tax exception in section 954(b)(4), but before application of the E&P limitation in section 952(c)(1)(A). Report a PTEP distribution by a lower-tier foreign corporation in Section 2 only if foreign income taxes are deemed paid under section 960(b) by the foreign corporation with respect to such PTEP distribution. Any person who fails to file or report all of the information required within the time prescribed will be subject to a reduction of 10% of the foreign taxes available for credit under sections 901 and 960. 55, available at, A U.S. person described in Category 1, 3, 4, or 5 (shareholder) does not have to file Form 5471 if. Subtract the sum of lines 14d and 14e from line 14c" field, "14g.Net foreign personal holding company income excluded under high-tax exception" field, "14h.Subtract line 14g from line 14f" field, "15.Adjusted net foreign base company sales income:", "15b.Expenses allocated and apportioned to the amount on line 3 under section 954(b)(5)" field, "15c.Net foreign base company sales income. Column (e)(vii) is E&P treated as PTEP under section 965(b)(4)(A) (section 959(c)(2) amounts). The Schedule E instructions specify that the foreign corporation must translate these amounts into U.S. dollars at the average exchange rate for the tax year to which the tax relates in accordance with the rules of section 986(a). Form 5471 Schedule Q The latest instructions for the Form 5471 series of forms states that a reference ID number (defined below) is required on line 1b(2) only in cases where no EIN was entered on line 1b(1) for the foreign corporation. Report the opening balance, current year additions and subtractions, and the closing balance in the foreign corporation's E&P described in section 959(c)(3). For a corporate shareholder, enter the result from line 1a on Form 1120, Schedule C, line 16a; enter the result from line 1b on Form 1120, Schedule C, line 16b; and enter the remaining lines 1c through 1h, 2, and 4 on Form 1120, Schedule C, line 16c; or on the comparable line of other corporate tax returns. On pages 2 and 3, Schedule E-1 former line 11 is now line 10 and clarifies that only columns (d) and (e)(i) through (e)(x) may have entries on line 10. For the foreign corporations annual accounting period with respect to which reporting is being made on this Form 5471, if the foreign corporation is required to file a U.S. income tax return (for example, Form 1120F), check the Yes box if the foreign corporation has previously disallowed interest expense under section 163(j) carried forward to the current tax year. These amounts are included in the total amount of residual income, which is reported on line 4. Certain filers may be able to use alternative information (as defined in section 3.01 of Rev. The corporate U.S. shareholder should include the line 5c amount on Form 1120, Schedule C, line 14, column (a), or the comparable line of other corporate income tax returns. Foreign gross income that arises from a disregarded payment that is treated as a remittance for U.S. tax purposes is assigned to an income group by reference to the income groups to which the assets of the payor taxable unit are assigned (or would be assigned if the taxable unit were a United States person) under the rules of Regulations section 1.861-9 for purposes of apportioning interest expense. Instead, they should be reported in the year to which such taxes relate. 1167 is available at IRS.gov/Pub. Subtract line 48 from line 47. For example, if you are the sole owner of a CFC (that is, you are described in Categories 4 and 5a), complete all six pages of Form 5471 and separate Schedules E, H, I-1, J, M, P, Q, and R. Note: Complete a separate Form 5471 and all applicable schedules for each applicable foreign corporation. During the tax year, was the CFCs foreign personal holding company income, foreign base company sales income, or foreign base company services income reduced so as to take into account any deductions (including taxes)? Report the total of the amounts listed in column (l) on this line 5. Use column (e) to report the running balance of the foreign corporation's PTEP, section 964(a) E&P accumulated since 1962 that have resulted in deemed inclusions under subpart F, or amounts treated as PTEP under section 965(b)(4)(A). "field, "57.Divide the number of days in the tax year that the corporation was a CFC by the number of days in the tax year and multiply the result by line 56. January 2022) (Use with the December 2021 revision of Form 5471 and separate Schedules E, G-1, H, I-1, and M; the December 2020 revision of separate Schedules J, P, Q, and R; and the December 2012 revision of separate Schedule O.) Enter foreign income taxes that are disallowed under section 901(k), which generally applies to certain taxes paid on dividends if the minimum holding period is not met with respect to the underlying stock, or if the corporation is obligated to make related payments with respect to positions in similar or related property. No amount should be reported in column (xii) of line 4 as foreign tax on residual amounts are not creditable. E&P described in section 959(c)(3) is generally E&P of the foreign corporation that has not been included in gross income of a U.S. shareholder under section 951(a)(1) or section 951A. 2019-40 for more details. Column (e)(v) is PTEP described in the following three subgroups (which are aggregated into a single PTEP group). Special rules apply for foreign corporations that use the U.S. dollar approximate separate transactions method of accounting (DASTM) under Regulations section 1.985-3. Subtract line 11 from line 10" field, "13. For line 4(1), $300 of gross income is reported in column (ii) and $105 of foreign tax is reported in column (x). 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. 2007-64, 2007-42 I.R.B. If an individual, estate, or trust that is a U.S. shareholder of a CFC makes an election under section 962 (962 electing shareholder), any inclusions under section 951 or 951A of the U.S. shareholder will be treated as received by a corporate U.S. shareholder for purposes of section 960. Proc. However, if a passive foreign investment company (as defined in section 1297) with respect to the shareholder is not a CFC, then such corporation is not a section 965 SFC. See Related constructive U.S. shareholder below for instructions pertaining to when Form 5471 may be completed as a Category 5c filer. See Multiple filers of same information, earlier. Add lines 1a through 1g" field, "3.Gross foreign base company sales income (see section 954(d))" field, "4.Gross foreign base company services income (see section 954(e))" field, "5.Gross foreign base company oil-related income (see section 954(g)) after application of section 954(b)(8)" field, "6.Gross foreign base company income. Report distributions from current and accumulated earnings and profits. The person that files the required information on behalf of other persons must complete a joint Form 5471 according to the applicable column(s) of the Filing Requirements for Categories of Filers, earlier. A separate Schedule Q is required for foreign oil and gas extraction income (FOGEI) and foreign oil related income (FORI). Form 5471, Information Return of U.S. The instructions have been updated for each of the aforementioned changes to Form 5471 and separate schedules. Taxpayers no longer have the option of entering FOREIGNUS or APPLIED FOR in a column that requests an EIN or reference ID number with respect to a foreign entity. Rule of thumb - always inquire about underlying partnerships and corporations when investing more than 10% in a foreign entity. See generally Regulations section 1.482-7 for more information on determining whether stock-based compensation is directly identified with, or reasonably allocable to, the intangible development activity (IDA) under the CSA. The following entries should be made on the 2021 Form 5471, Schedule E, General Category, Part I, Section 1, for CFC1. However, this amount is reduced (but not below zero) by the following liabilities. If the corporation does not itself incur intangible development costs, then it should only report cost sharing transaction payments made on line 20. Enter the reduction to the column (b) tested income group for tested income taxes not deemed paid. See section 959(a). Line 9. See Notice 88-71, 1988-2 C.B. Lines 13g, 14d, 15d, 16d, 18d, and 19d. During the tax year, did the CFC receive, from a person other than a related person within the meaning of section 954(d)(3), rents or royalties that were derived in the active conduct of a trade or business? Certain penalties under sections 6038 and 6662 may be waived for certain persons under Rev. Proc. This adjustment is necessary because foreign taxes imposed on PTEP distributions do not reduce current year E&P. Exceeded guidance. Do not include adjustments required to be reported on line 6 or 12. See the instructions for Schedule C, Line 21, earlier. Enter on page 1, Item 1f, the six-digit code selected from the list below. The top margin of the summary return must be labeled Filed Pursuant to Rev. Certain transactions resulting in a loss of at least $10 million in any single year or $20 million in any combination of years. More than 50% of the total value of shares of all classes of stock of the foreign corporation. During Year 2, CFC3 distributes $40 to CFC2. A U.S. person has acquired stock in a foreign corporation when that person has an unqualified right to receive the stock, even though the stock is not actually issued. 851, available at, Enter foreign currency transaction gain or loss reported on the income statement. Also, new lines 14 and 29 were added for reporting other amounts received (line 14) and other amounts paid (line 29). In other words, are any amounts excluded from line 1a of Worksheet A by reason of the look-through rule described in section 954(c)(6)? From the sale or other disposition of such a contract. Certain transactions involving an expatriated foreign subsidiary and/or its U.S. shareholders may be subject to special rules. 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). 2019-40 for definitions of terms. For line 3(1), $200 of gross income is reported in column (ii), $70 of foreign tax is reported in each of columns (x) and (xii), and the checkbox in column (xiv) is checked. See section 960(d). For details, see the Instructions for Form 8918. CFC2, in turn, wholly owns the only class of stock of CFC3, a foreign corporation. 2006-45, 2006-45 I.R.B. Report the inclusion as a positive amount in columns (e)(vi) through (e)(x), as applicable. In other words, are any amounts that are derived in connection with property that does not satisfy section 954(d)(1)(A) excluded from line 3 of Worksheet A (that is, income excluded by reason of Regulations section 1.954-3(a)(2))? If the foreign corporation is the owner of a qualified business unit(s) (QBU) with a different functional currency, translate the E&P of the QBU(s) to the foreign corporations functional currency. As a result, the amount reported on line 4, column (ii), is increased by $50 and the amount reported in column (x) on line 4 is increased by $20. Gains and losses from the sale or exchange of any property that, in the hands of the CFC, is property described in section 1221(a)(1). On pages 2 and 3, Schedule E-1 combines former lines 9 and 10 on one line 9 to report both taxes deemed paid with respect to inclusions under sections 951(a)(1) and 951A and clarifies that amounts may only be reported in columns (a) and (b) with respect to line 9. Filers are permitted to enter both an EIN and a reference ID number. (a) During the tax year, did the CFC derive income in connection with the purchase from or sale to a related or unrelated person of personal property manufactured or sold for use outside the country under the laws of which the CFC is created or organized (for example, property manufactured or sold by a disregarded entity of the CFC)? Persons With Respect to Certain Foreign Corporations. 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. Schedule H is only prepared for the general, passive, and section 901(j) categories of income. https://www.andrewmitchel.com - Hundreds of additional chartshttps://www.tax-charts.com - Tax flowchartshttps://www.intltax.typepad.com - Discussions of new . As a result of the deletion of line 14, all subsequent lines have been renumbered, as appropriate. "As we enter Q4 FY 23, we are seeing . Category 3: A person acquires stock in total of stock ownership exceeds 10%. Report income taxes on line 21. This example can also be found in the Schedule Q, Form 5471 instructions. An amount equal to the deficit reported in column (a), (b), or (c) of line 5a is included as a positive amount on line 5b of column (a), (b), or (c), respectively. Name of person filing Form 5471 Street address City State (if U.S. address) ZIP code (if U.S. address) Region (if foreign address) ZIP code (if foreign address) Country (if foreign address) Identifying number Annual tax year beginning Annual tax year ending Mark any applicable Category filer checkboxes.

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