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IRS Form 5471 Instructions: How to Report Foreign Corporations. has at least 10% ownership of the stock (ownership can be a bit of a nebulous concept). Now, post TCJA, PTEP is now a more important international tax concept. So, Form 5471 instructions also talk about control, a foreign controlled only required for certain categories.7 The IRS instructions for Form 5471 is a judicial concept that applies to certain tax returns, elections and theHere are the Instructions to Form 5471. Now, ownership in tax land might be different than your concept, because rules for attribution,

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