Subtract line 16b from line 16a" field, "16d.Net foreign base company services income excluded under high-tax exception" field, "16e.Subtract line 16d from line 16c" field, "17.Adjusted net foreign base company oil-related income:", "17b.Expenses allocated and apportioned to line 5 under section 954(b)(5)" field, "17c.Subtract line 17b from line 17a" field, "18.Adjusted net full inclusion foreign base company income:", "18a.Enter the excess, if any, of line 12 over line 8" field, "18b.Expenses allocated and apportioned under section 954(b)(5)" field, "18c.Net full inclusion foreign base company income. Proc. No penalty will be imposed with respect to any portion of an underpayment if the taxpayer can demonstrate that the failure to comply was due to reasonable cause with respect to such portion of the underpayment and the taxpayer acted in good faith with respect to such portion of the underpayment. 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). 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. Enter the name of each QBU and enter the information required for columns (i) through (xiv) for each QBU on lines 4(1), 4(2), etc., but do not enter amounts excluded from subpart F income under the subpart F high-tax exception (those amounts are reported on lines (1), (2), etc. Instructions for Form 5471, Information Return of U.S. Audited separate-entity financial statements of the foreign corporation that are prepared on the basis of the generally accepted accounting principles of the jurisdiction in which the foreign corporation is organized (local-country GAAP). For more information, see section 898 and Rev. 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. Part I Taxes for Which a Foreign Tax Credit Is Allowed, Item H Person(s) on Whose Behalf This Information Return Is Filed, Treasury Inspector General for Tax Administration, The identifying information on page 1 of Form 5471 above Schedule A; see, Schedule E-1 (included with separate Schedule E), 1. from investment in U.S. property and to translate the amount from functional currency to U.S. dollars. 2, 2023-- 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 . "field, "41.Section 954(c) subpart F Foreign Base Company Sales Income subtotal. Enter the CFCs qualified interest expense, as defined in Regulations section 1.951A4(b)(1)(iii). Enter foreign income taxes properly attributable to PTEP and not previously deemed paid (from Schedule E, Part I, Section 2, line 5, column (i)). During the tax year, did the CFC derive, in the conduct of a banking business, interest that is export financing interest? 55, available at IRS.gov/irb/2003-28_IRB#RP-2003-47, for procedural rules regarding the election under section 953(d). Line 22. "field, "67.Translate the amount on line 66 from functional currency to U.S. dollars at the average exchange rate. 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). Domestic Corporation, a U.S. shareholder, wholly owns the only class of stock of CFC1, a foreign corporation. Column (d): Amount of E&P distribution in foreign corporation's functional currency. If for any reason a reference ID number falls out of use (for example, the foreign corporation no longer exists due to disposition or liquidation), the reference ID number used for that foreign corporation cannot be used again for another foreign corporation for purposes of Form 5471 reporting. Subtract line 45 from line 44. The different rules are applicable for individuals, as well as corporations, estates, and trusts. 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. Schedule M. In translating the amounts from functional currency to U.S. dollars, use the average exchange rate for the foreign corporation's tax year. The only foreign taxes of the distributing foreign corporation that may be treated as deemed paid under section 960(b) are foreign taxes paid, accrued, or deemed paid by the distributing foreign corporation with respect to the receipt of a PTEP distribution from another lower-tier foreign corporation below the distributing foreign corporation. 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? The schedules are: Form 5471 Schedule A - Stock of the Foreign Corporation Form 5471 Schedule B - U.S. Shareholders of Foreign Corporations Form 5471 Schedule C - Income Statement 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. 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. If applicable, use the reference ID number shown on Form 5471, page 1, Item 1b(2). The U.S. dollar column should reflect such amounts translated into dollars under U.S. GAAP translation rules. "field, "45.Shareholders pro rata share of export trade income that applies to line 44 amount. Warehouse Clubs and Supercenters, All Other Miscellaneous Store Retailers (including tobacco, candle, & trophy shops), Fuel Dealers (including Heating Oil and Liquefied Petroleum), Other Direct Selling Establishments (including door-to-door retailing, frozen food plan providers, party plan merchandisers, & coffee-break service providers), Other Transit & Ground Passenger Transportation, Support Activities for Air Transportation, Support Activities for Rail Transportation, Support Activities for Water Transportation, Other Support Activities for Road Transportation, Other Support Activities for Transportation, Warehousing & Storage (except lessors of mini-warehouses & self-storage units), Motion Picture & Video Industries (except video rental), Telecommunications (including paging, cellular, satellite, cable & other program distribution, resellers, & other telecommunications, and Internet service providers), Data Processing, Hosting, & Related Services, Other Information Services (including news syndicates & libraries, Internet publishing & broadcasting), Real Estate Credit (including mortgage bankers & originators), All Other Nondepository Credit Intermediation, Activities Related to Credit Intermediation (including loan brokers, check clearing, & money transmitting), Other Financial Investment Activities (including portfolio management & investment advice), Direct Life, Health, & Medical Insurance & Reinsurance Carriers, Direct Insurance & Reinsurance (except Life, Health & Medical) Carriers, Other Insurance Related Activities (including third-party administration of insurance and pension funds), Open-End Investment Funds (Form 1120-RIC, U.S. Income Tax Return for Regulated Investment Companies), Other Financial Vehicles (including mortgage REITs and closed-end investment funds)Offices of Bank Holding Companies and Offices of Other Holding Companies are located under, Lessors of Residential Buildings & Dwellings (including equity REITs), Lessors of Nonresidential Buildings (except Mini-warehouses) (including equity REITs), Lessors of Mini-warehouses & Self-Storage Units (including equity REITs), Lessors of Other Real Estate Property (including equity REITs), Commercial & Industrial Machinery & Equipment Rental & Leasing, Lessors of Nonfinancial Intangible Assets (except copyrighted works), Surveying & Mapping (except Geophysical) Services, Specialized Design Services (including interior, industrial, graphic, & fashion design), Management, Scientific, & Technical Consulting Services, Scientific Research & Development Services, Marketing Research & Public Opinion Polling, All Other Professional, Scientific, & Technical Services, Business Service Centers (including private mail centers & copy shops), Other Business Support Services (including repossession services, court reporting, & stenotype services), Travel Arrangement & Reservation Services, Other Support Services (including packaging & labeling services, & convention & trade show organizers), Educational Services (including schools, colleges, & universities), Offices of Physicians (except mental health specialists), Offices of Physicians, Mental Health Specialists, Offices of Mental Health Practitioners (except Physicians), Offices of Physical, Occupational & Speech Therapists, & Audiologists, Offices of All Other Miscellaneous Health Practitioners, Outpatient Mental Health & Substance Abuse Centers, Freestanding Ambulatory Surgical & Emergency Centers, Other Ambulatory Health Care Services (including ambulance services & blood & organ banks), Community Food & Housing, & Emergency & Other Relief Services, Spectator Sports (including sports clubs & racetracks), Promoters of Performing Arts, Sports, & Similar Events, Agents & Managers for Artists, Athletes, Entertainers, & Other Public Figures, Independent Artists, Writers, & Performers, Museums, Historical Sites, & Similar Institutions, Other Amusement & Recreation Industries (including golf courses, skiing facilities, marinas, fitness centers, & bowling centers), RV (Recreational Vehicle) Parks & Recreational Camps, Rooming & Boarding Houses, Dormitories & Workers Camps, Special Food Services (including food service contractors & caterers), Automotive Mechanical & Electrical Repair & Maintenance, Automotive Body, Paint, Interior, & Glass Repair, Other Automotive Repair & Maintenance (including oil change & lubrication shops & car washes), Electronic & Precision Equipment Repair & Maintenance, Commercial & Industrial Machinery & Equipment (except Automotive & Electronic) Repair & Maintenance, Home & Garden Equipment & Appliance Repair & Maintenance, Other Personal & Household Goods Repair & Maintenance, Other Personal Care Services (including diet & weight reducing centers), Drycleaning & Laundry Services (except Coin-Operated), Religious, Grantmaking, Civic, Professional, & Similar Organizations (including condominium and homeowners associations), Electronic Federal Tax Payment System (EFTPS), Instructions for Form 5471 - Introductory Material, Filing Requirements for Categories of Filers, Computer-Generated Form 5471 and Schedules, Item EExcepted Specified Foreign Financial Assets, Item FAlternative Information Under Rev. A U.S. shareholder who is a Category 5 filer (defined above) must complete Form 5471 and file all information required of a Category 5a filer if that U.S. shareholder does not qualify as a Category 5b or 5c filer. Do not include foreign income taxes that are disallowed and are reported on Schedule E, Part III. On pages 2 and 3, Schedule E-1, former line 16 is now line 14 and has been reserved for future use. Proc. See Categories of Filers, earlier. Rul. These headings must comport to those used on the Schedule M (Form 5471) to which this statement is attached. Category 5 filers, a U.S. person is: An estate or trust that is not a foreign estate or trust, as defined in Enter the CFCs gross income. See Regulations section 1.960-1(d)(3)(ii)(C). See the instructions for lines 1 through 4. Proc. 501 page is at IRS.gov/Pub501; the Form W-4 page is at IRS.gov/W4; and the . Enter the expenses allocated and apportioned to the item of gross income reported for each QBU or tested unit as well as the aggregate amount of such expenses allocated and apportioned to each group. Ladies and gentlemen, closed captioning is available for today's presentation. Attach a statement explaining why such taxes were not deemed paid under section 960. The purpose of Section 2 is to track deemed-paid foreign income taxes with respect to current year PTEP distributions from lower-tier foreign corporations to the foreign corporation with respect to which this Schedule E (Form 5471) is being completed (the foreign corporation). See Regulations section 1.245A-5(d) for further guidance on tiered extraordinary disposition amounts. All persons identified in Item F must attach a statement to their income tax return that includes the information described in the instructions for Item F. Shareholders are not required to file the information checked in the chart, later, for a foreign insurance company that has elected (under section 953(d)) to be treated as a domestic corporation and has filed a U.S. income tax return for its tax year under that provision. The total reported on Schedule E, Part I, Section 2, line 5, column (i) should be broken out on Schedule E-1, line 6, columns (e)(i) through (e)(x) based on the type of PTEP to which such taxes relate. Corporate U.S. shareholders should enter the foreign-source portion of any subpart F income inclusions attributable to the sale or exchange by a CFC of stock of another foreign corporation that is eligible for the section 245A dividends received deduction pursuant to section 964(e)(4). Such taxes are also reported on Schedule E, Part III, column (g). Any person who fails to file or report all of the information requested by section 6046 is subject to a $10,000 penalty for each such failure for each reportable transaction. Otherwise, enter zero. See Regulations section 1.9603(c)(1). 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. 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. Enter the amount of any dividend income received by the CFC from a related person as defined in section 954(d)(3). 2019-40 for more details. The Form 5471, Schedule J, for CFC1 should include PTEP of $70x with respect to the aggregate section 951A inclusions of Corporation A and Corporation B.
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