Form 5471 Worksheet A - Can anyone explain how to fill in section 1?

There is no such thing as a foreign base company. There is only foreign base company income. One of the types of foreign base company income is foreign personal holding company income (or "FPHCI").

Generally, all interest is treated as FPHCI unless it is certain interest from related parties. Although I have calculated subpart F income for thousands of companies, I have never filled out Worksheet A. I assume that the interest would be included on the worksheet.

Generally, foreign base company sales income only includes income related to purchase and sales of personal property from or to related parties.

Andrew

Thanks for taking the time to reply. I've been fobbed off by the IRS when trying to get information about this from the Philadelphia office. "Sorry, that's way beyond our level of training." I was told.

So any passive income the CFC receives is considered FPHCI (if I understand you correctly).

And sales of products manufactured by the company then probably don't go on line 3.

Is it the case that line 8, (Gross foreign base company income) is the total of all sales, service, oil, and passive income, including those listed on line 1 (FPHCI)?

If so, FPHCI is less than 5% of line 8, and less than $1 million, so I enter zero on line 11, and skip to line 22 (assuming the skipped lines count as zero), that gives me subpart F income of 0.

Does that sound correct, given the assumptions above?

Tony