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  • videocam Live Online with Live Q&A
  • calendar_month January 5, 2026 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Calculating and Reporting Foreign E&P: Categorizing PTEP, Form 5471 Schedules H, P & R, Foreign Tax Credits

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Description

Tracking foreign E&P is crucial for determining the taxation of distributions, as well as current and previously taxed E&P, and available foreign tax credits. Although foreign E&P is not defined, IRC Section 964 explains how it is calculated—substantially like a domestic corporation's E&P. The accompanying regulations provide guidelines for the differences between the two.

The regulations outline the three-step approach to calculating E&P:


Step 1. Prepare a local country profit and loss statement for the year from the books of account regularly maintained by the corporation for accounting to its shareholders.


Step 2. Make the accounting adjustments necessary to conform the foreign profit and loss to U.S. GAAP.


Step 3. Make the further adjustments necessary to conform the U.S. GAAP profit and loss to certain U.S. tax accounting standards.


Further complicating matters, the OBBBA introduced significant revisions to the foreign taxation regime. Among these is the extension of the look-through rule under Section 954(c)(6) and revised tax rates for GILTI/NCTI and FDII/FDDEI. Applying the regulations and complying with numerous reporting requirements can be overwhelming for international tax practitioners.

Listen as our panel of international tax experts guides you through calculating and reporting foreign E&P for CFCs.

Presented By

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. Mr. McCormick is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Monday, January 5, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Foreign E&P: introduction

II. OBBBA modifications

III. Calculating

IV. Ordering rules

V. Current

VI. Previously taxed earnings and profit

VII. Foreign tax credits

VIII. Retroactive allocations

IX. Reporting

The panel will cover these and other key issues:

  • Reporting distributions on new Schedule R, Form 5471
  • How OBBBA changes affect foreign E&P
  • Categorizing previously taxed earnings and profits
  • Reporting foreign E&P on Schedules H and P of Form 5471
  • Notice 2019-01 and the ordering rules

Learning Objectives

After completing this course, you will be able to:

  • Understand the purposes of Form 5471 and various schedules, the categories of U.S. persons required to file, and the reporting requirements
  • Verify the impact of important guidance contained in IRC Notice 2019-01
  • Categorize foreign income into required categories on Schedule J
  • Distinguish the tax provisions under Subpart F from the GILTI provisions
  • Calculate GILTI on CFC income
  • Establish that the reporting of foreign E&P on Schedules H and P is correct
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.


BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .