Cindy Kim: Hi, everybody. Thank you for joining us today. My name is Cindy Kim, I'm a Program Manager in the Cross Border Activities Practice Area within the Large Business and International Division of the IRS. We are pleased to provide today's training on the new Schedule Q of the Form 5471 as well as Part 8 of the new Schedules K-2 and K-3 on the Form 1065. As you know, the 2017 Tax Cuts and Jobs Act, or TCJA changed much of the international tax rules, and therefore our tax forms had to adjust to these changing tax rules and regulations. This is our second webinar on the new international tax forms. Last year in September 2021, we held a webinar on the overview of the Form 5471, which is available for playback. So, if you need a refresher on the new Form 5471, I would encourage you to review and playback that webinar. We will provide a link to that webinar, as well as other helpful resources at the end of today's presentation. We also set up an email box in case you have any comments on today's presentation or you have any suggestions for future webinars. You will also find that email address at the end of today's presentation. The Form 5471 Schedule Q and Part 8 of the Schedules K-2 and K-3 for the Form 1065 report a controlled foreign corporation or CFC's income, deductions, taxes and assets by CFC income groups. As our presenters will explain today, this information is needed for many purposes, including the calculation of deemed paid foreign tax credits under Section 960. This area of the tax law is complex and today's webinar is meant to be instructional. We will try to break down the rules as it relates to the new schedule and explain it as simply as possible. Well, I'm very pleased to introduce our three esteemed presenters today. We have Anne Ng, Brian Sheba and Julie Goopta, who are all Senior Revenue Agents from the Cross Border Activities Practice Area within the LB&I Division of the IRS. I will now turn this over to Ann to start the presentation. Ann Ng: Thank you, Cindy. Let's look at the Schedule Q of Form 5471. Like Cindy said, a U.S. shareholder uses Schedule Q to report CFC's income, deductions, taxes and assets by CFC income groups for purposes of; the Subpart F high-tax exception, global intangible low-taxed income or GILTI high tax exclusion, the high tax kick-out from the passive category of income and the deemed paid credits for Subpart F and GILTI inclusions. So, Schedule Q is a required schedule for Categories 4, 5a and 5b filers of the 5471. Let's quickly review these three categories. But first, I want to put in a plug for the Form 5471 instructions, which is full of instructive information. You can find it on our website at IRS.gov. A Category 4 filer is a U.S. person who had control of a foreign corporation during the annual accounting period of the foreign corporation. A U.S.

person has control of a foreign corporation if at any time during that person's tax year, it owns more than 50% of the total combined voting power of all classes of stock of the foreign corporation entitled to vote or more than 50% of total value of shares of all classes of stock of the foreign corporation. Next, Categories 5a and 5b filers are also required to include Schedule Q in their Form 5471. A Category 5 filer is a U.S. shareholder who owns stock in a foreign corporation that is a CFC at any time during any tax year of the foreign corporation and who owns the stock on the last day in that year in which the foreign corporation was a CFC. The instructions to Form 5471 describes a Category 5a filer as a U.S. shareholder who doesn't qualify as either a Category 5b or 5c filer. So, a 5a filer is an unrelated Section 958(a) U.S.

shareholder, while a 5c filer is a related constructive U.S. shareholder. An unrelated Section 958(a) U.S. shareholder is defined as a U.S. shareholder with respect to a foreign controlled corporation, who owes within the meaning of Section 958(a), direct or indirect, the stock of a foreign controlled corporation and is not related as per Section 954(d)(3) to the foreign controlled corporation. A related constructive U.S. shareholder is defined as a U.S. shareholder with respect to a foreign controlled corporation, who does not own within the meaning of Section 958(a), so not directly or indirectly owning the stock of the foreign controlled corporation and is related as per Section 954(d)(3) to the foreign controlled corporation. You can find a good reference material for Category 5 filers in Rev. Proc. 2019-40. This and the next three slides we have for you screenshots of Schedule Q. I won't go too much into details, because my colleagues are going to cover them in depth. The first page requires the reporting of Subpart F income groups. But by the way, the Schedule Q is a separately printed schedule and is four pages long.

The second page continues the reporting of Subpart F income groups. And the third page is the reporting of additional Subpart F income groups in Line 1. The recaptured Subpart F income group in Line 2. The tested income group, Line 3. The residual income group, Line 4, and the total at Line 5. And here we are at Page 4 the last page of Schedule Q. Brian will go over each of the line items and the specific columns of information that the schedule is asking for. And then Julie will show you an example how to complete this schedule. Brian it's all yours. Brian Sheba: Thank you, Anne. So why should you file a Schedule Q? The short answer is so that you can figure out your deemed paid credits. In general, a domestic U.S. shareholder of a CFC is deemed to pay all or a portion in the case of GILTI of the foreign income taxes paid or accrued by the CFC that are properly attributable to items of income of a CFC that the U.S. shareholder includes in its gross income under Section 951(a)(1) as Subpart F income and under Section 951A as GILTI. The domestic corporate U.S. shareholder may claim an indirect credit for such foreign taxes subject to certain limitations. Individuals, estates and trusts may also claim a foreign tax credit for foreign income taxes deemed paid with respect to a CFC if they make an election under Section 962. It's also important to note that this is not just an information return filing exercise.

The Schedule Q contains the information to properly compute the deemed paid foreign tax credit and report the same on the Form 1118. The first few lines of Schedule Q will dictate the number of Schedule Qs you must file based on the category of income and groupings of income if you have passive category income. On Line A you will enter a code to denote the particular category of income. This can include passive Section 901(j) sanctioned country income and general limitation categories of income. Because this is CFC level information, you will not have categories for 951A or foreign branches as these are U.S. shareholder level categories of income. If you have more than one of the categories of income referred to above for a CFC, you must also complete and file a separate Schedule Q using the code TOTAL that aggregates all amounts listed for each line in column in all other Schedule Qs. The code you enter on Line B corresponds to the rate and type of tax attributable to passive income of a tested unit. You may therefore need to complete several separate Schedule Qs for passive income subject to different rates and/or types of tax.

This code is necessary because Section 1.954-1(c) defines a single item of passive foreign personal holding company income as an amount that falls within a single group of passive income under the grouping rules in the Section 1.904-4(c) the high-tax kick-out rules. These rules group income by reference to the rate and type of tax imposed on the income. The high-tax kickout rules also require tested unit-by-tested unit reporting with respect to the income groups on lines 1a through 1j. The amount in each income group are therefore reported on separate rows corresponding to each tested unit. Schedule Q contains two other separate filing requirements. On Line C, file a separate Schedule Q for each separate category and/or passive grouping with respect to U.S.

source income and foreign source income. As U.S. source income should be rare, most taxpayers will check the foreign source income box. On Line D, indicate whether schedule Q reports foreign oil and gas extraction income or foreign oil related income per Section 907. This should be rare and only with respect to certain industries. Next, we will turn to some of the specific line numbers on the form. Perhaps the biggest thing you will notice from Schedule Q is that there are a lot of lines related to Subpart F income and only a single row dedicated to tested income for GILTI. The reason for this is that Section 960(a) properly attributable standard is based on Subpart F income groups, which are defined in the Section 960 and 954 regulations. So, depending on the activity of your CFC, you may have a lot of separate reporting to do particularly for foreign personal holding company income. This is because such income must be reported by tested unit, Subpart F income group, and high-tax kick-out grouping. As you can see from the schedule the foreign personal holding company income groupings are separately reported. Use lines 1a through 1e to enter the foreign personal holding company income of the CFC in the appropriate income group, which can be dividends, interest, rents, royalties and annuities, which together is one income group. Net gain from certain property transactions, net gain from commodities transactions, net foreign currency gain and income equivalence to interest, each of which is designated as a separate Subpart F income group under the regulations. For foreign-based company income other than foreign personal holding company income, the regulations identify as a single item of income of a CFC all foreign base company income that falls within both a single Section 904 category which is typically going to be general category income and a single category of foreign-based company sales income, foreign-based company services income, and full inclusion foreign-based company income. For example, with respect to Line 1f there is a single Subpart F income group within the general limitation category that consists all of a CFC's foreign base company sales income. Once you figure out your Subpart F income groups, a further sorting may be needed. Each line of Subpart F income groups will be further divided by tested units, where you will enter the name of each tested unit of the CFC, including the CFC itself, and the information required in each column for gross income, deductible expenses et cetera. As you total the units for each Subpart F income group, for example Line 1a, 1b, 1c et cetera, exclude from such total, any amounts reported with respect to income excluded from Subpart F income under the high-tax exception in Section 954(b)(4). These amounts are included in the total amount of residual income, which is reported below on Line 4 the residual income group total. That's it for Subpart F income. Let's now talk about tested income and GILTI. Use Line 3 to report tested income in the tested income group of the CFC. On each sub-line under Line 3, enter the name of each tested unit of the CFC again, including the CFC tested unit itself, and enter for each tested unit the information required in each column, gross income, expenses, et cetera. Based on the tentative gross tested income attributable to each tested unit without regard to any amounts excluded under the GILTI high-tax exclusion. A lot of you may be wondering about how the GILTI high-tax exclusion works on Schedule Q. If the GILTI high-tax exclusion applies with respect to any tested unit of the CFC as with the Subpart F income groups, include the total unit amounts reported for each column in the total reported on Line 4 and not on Line 3. In general, tested income will be in a single tested income group within the general category. Because Section 951A category income does not exist at the CFC level due to the global GILTI computation, there is no separate 904 category for tested income. A U.S. shareholder includes its GILTI, which is computed with respect to the tested income or tested loss of each CFC of the shareholder, in its Section 951A category. It follows that taxes properly attributable to a CFC's tested income that are deemed paid by the U.S. shareholder are generally deemed paid taxes in the Section 951A category, though there is a rare exception to treat these taxes as passive category. Next, we will move on to Line 4 and discuss residual income. Line 4 pertains to an income group within a Section 904 category, but that is not of a type that is included in one of the Subpart F income groups or a tested income group and is therefore assigned to the residual income group. Again, this will be entered on a tested unit basis, but do not enter in the tested unit lines amounts excluded under the Subpart F high-tax exemption and the GILTI high-tax exclusion in the total for each line 4 for each column, enter the sum for each tested unit plus the sum of the amounts excluded under that Subpart F high-tax exception and the GILTI high-tax exclusion in the appropriate column on Line 4. Reporting the correct amount of income and tax on line 4 is important, because under the regulations, taxes in the residual grouping are ineligible for a deemed-paid foreign tax credit.

That's all for the lines, next we will discuss some highlights of the instructions for the columns on Schedule Q. For column (i) and consistent with the reporting requirement on Form 1118, enter the two-letter code of each foreign country and U.S. possession within which income is sourced and/or to which taxes were paid or accrued. In column (ii) enter the amount of gross income of the CFC that is assigned to each income group within each Section 904 category.

Because of the way the rows require information to be reported, this will ensure that gross income and other column information is reported by separate income groupings for each tested unit. Proper reporting of gross income is thus critical to Schedule Q, and the properly attributable standard for deemed-paid taxes because it will drive the reporting of the rest of the columns on the schedule. The bulk of the columns on the schedule are for CFC deductions. For columns (iii) through (vii), deductions of the CFC, including for current year taxes, are allocated and apportioned to the income groups to determine the net income or loss in each income group and to identify the current year foreign income taxes that are attributable to the income in each income group for Section 960 purposes. Enter the expenses allocated and apportioned to the item of gross income reported for each tested unit. Also, remember to aggregate the amount of such expenses allocated and apportioned to each group. The purpose of most of the remaining columns are to take into account what happens when you have a disregarded payment, which are payments between the foreign branch and branch owner or payments between foreign branches with the same branch owner. Column (viii) is used to report current-year tax imposed solely by reason of the receipt of a disregarded payment that is a reattribution payment, and thus does not include remittances or contributions. The current year tax is generally allocated and apportioned to the income group or groups to which gross income is assigned by reason of the receipt of the reattribution payment. The reg cites you see on the screen should point you in the right direction. Report current-year taxes allocated and apportioned to the item of gross income reported for each tested unit as well as the aggregate amount of such foreign taxes in each group. Column (ix) is used to report current year 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. Foreign tax imposed by reason of a disregarded payment that is a remittance is assigned to the income groups based upon the tax book value of the assets of the payor taxable unit, so this allocation should be familiar as it is similar to how you already apportion interest expense under the asset method. Foreign tax imposed by reason of a disregard payment that is a contribution is assigned to the residual grouping and thus will not be eligible for a deemed paid credit. Column (x) is for current year foreign tax not imposed by reason of the receipt of a disregarded payment, that is reattribution payments, remittances and contributions. In allocating and apportioning foreign taxes to the appropriate grouping of income within a Section 904 category, see regulation Sections 1.904-6(a) and 1.861-20(d) for special fact patterns, such as items of foreign gross income without a corresponding U.S. item of income, foreign gross income from a U.S. non-recognition event or a U.S. recognition event that falls in a different U.S. taxable year. Compared to the pre-TCJA regs, the special fact patterns in 1.861-20 represent a refinement and provides rules to better define the properly attributable standard for deemed paid credits. The amount reported in Column (xii) for foreign taxes for which a credit is allowed may not be the same as the sum of the amounts in the other foreign tax columns if such columns include taxes that are not credible, including taxes paid or accrued to sanctioned countries, foreign taxes disallowed for back-to-back dividends or other payments under Sections 901(k) and (l), covered asset acquisitions under 901(m) for example, related to a step up basis difference as a result of a Section 338 election and taxes paid or accrued to United States or a subdivision thereof, for example, state taxes. As you can see from the title, Column (xiii) is not an income or expense item, but it's for assets. Why is there an asset column on this form? 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 United States person, under the rules of regulations 1.861-9 for purposes of apportioning interest expense. This rule uses the payor's asset apportionment percentages as a proxy for the accumulated earnings of the payor taxable unit from which the remittance is made.

The checkbox in Column (xiv) is for the line corresponding to any item of income with respect to which the Subpart F high-tax exception or GILTI high-tax exclusion applies. If any amount is excluded under these rules, do not include it in the total for the respective Line 1 or Line 3 row, but instead add the amount to the total for Line 4. Schedule Q contains some components in computing the GILTI high-tax exclusion. However, other compute components are included elsewhere for computing the GILTI high-tax exclusion. At this point, I'm going to turn things over to Julie and she is going to go over an example for you. Thank you, Julie. Julie Goopta: Thank you, Brian.

We will now cover an example to demonstrate how the forms work in action and go over how the Schedule Q is completed in practice. This example can also be found in the Schedule Q, Form 5471 instructions. In this example, we assume that CFC1 is wholly owned by a domestic corporation and all the foreign taxes mentioned here are not withholding taxes. So, here we see that there are three entities with Subpart F income and foreign taxes reported by the U.S. Taxpayer in the Schedule Q of Form 5471. The first is CFC1, which has activity that generates its own income and foreign taxes and there are also two disregarded entities DRE1 and DRE2 which also report their own income and foreign taxes. On Line 1(a)(1), CFC1 reports gross income of $50 in Column 2 (ii)

and reports foreign tax of $20 in Columns 10 (x) and 12 (xii), and also checks the high-tax checkbox in Column 14 (xiv). Now moving on to the disregarded entities. On Line 1(a)(2), DRE1 reports gross income of $100 in Column 2 (ii), and reports $5 of foreign tax in Columns 10 (x)

and 12 (xii) respectively. On Line 1(a)(3), DRE2 reports gross income of $75 in Column 2 and reports $3 of foreign tax in Columns 10 and 12 respectively. As a result, the amount reported as gross income in Column 2 (ii) on Line 1(a), is the sum of income from DRE1 on Line 1(a)(2) of $100 and DRE2 on Line 1(a)(3) of $75 which is equal to $175. Similarly, the amounts reported in Columns 10 (x) and 12 (xii) on Line 1(a) are the sum of the foreign tax amounts reported for DRE1 on Line 1(a)(2) of $5 and from DRE2 on Line 1(a)(3) of $3 which is equal to $8. Now, it's important to note that for CFC1, the amounts that we're seeing on Line 1(a)(1) on the previous slide are not included in the totals reported on Line 1(a). CFC1's gross income of $50 and its foreign tax amount of $20 are included in the totals for each respective column on Line 4 because the high-tax election was checked for this entity. As a result, the amount reported on Line 4, Column 2 (ii) equals $50 and the amount reported in Column 10 (x) on Line 4 is $20. One final thing to note on this slide is the amounts are reported on the Total column in this simplified example. But if there was more than one unit to report, other than CFC1, each unit should be listed separately on Line 4(1) and 4(2) and so on. On this slide, we see Page 4 of the Schedule Q and we can see that no amount is reported on Line 4, Column 12 (xii), because foreign income taxes attributable to high-tax exception or high-tax exclusion income are not creditable.

Finally, this last slide illustrates how Schedule Q information from the example that we just covered flows over to Form 1118 Schedule C in order to report the deemed paid taxes properly attributable to the Subpart F inclusion. There are two items to note here. First is that Column 5a contains the Form 1118 Schedule C code to report the Subpart F income grouping, In this case DIRRA means dividends, interest, rents, royalties, and annuities, per the Form 1118 instructions.

Column 5b further refines this Subpart F grouping classification based upon the type of taxes paid. In this example, Category 4 reflects that the passive income received was not subject to withholding tax, but is subject to a foreign tax other than withholding tax. Please note the codes in Form 1118 instructions coincide with the codes used on Form 5471 Schedule Q. So now that we've covered a practical example of how to complete the Schedule Q, I now turn it back over to Ann. Ann Ng: Thank you, Julie. Next up, we are going to talk about two new hot off the press schedules that the service released for tax year 2021. The Schedule K-2 and K-3 of Form 1065.

Based on this simple structure, in general, the two U.S. partners, U.S. U.S. Person A and domestic Corporation B should each get a Schedule K-3 Part 8 from the domestic partnership P with respect to the two CFCs Y and Z related to the partners' interest in the foreign corporations through the partnership under Section 960. Partnership P completes Form 5471 Schedule Q and attaches it to the completed Schedule K-3 Part 8. We want you to know at this point, that partnership P does not complete a Schedule K-3, Part 8 for the foreign partner but may need to complete other parts of Schedule K-3 for the foreign partner. Schedule K-2 of Form 1065 is a separately printed schedule. This and the next slide we have for you the screenshots of Part 8 of Schedule K-2, the Partnership's interest in foreign corporation income under Section 960. By the way, you'll find Part 8 of Schedule K-2 at Pages 14 and 15. This is the continuation of Part 8 of Schedule K-2 at Page 15. The Schedule K-3 Part 8 is asking for the Partner's, as opposed to the partnership's, interest in the foreign corporation income under Section 960. You'll also notice that the types of information that Part 8 of both Schedules K-2 and K-3 are asking for is based on the information of Schedule Q of Form 5471. Here we have the continuation of Part 8 of Schedule K-3 at Page 16. Up next is Julie. She'll go over these two schedules in more detail.

Julie. Julie Goopta: Thank you, Ann. So, I will now start off by covering the purpose of each new schedule. Schedule K-2 is an extension of Schedule K of the Form 1065 and is used to report items of international tax relevance from an operation of a partnership. Schedule K-3 is an extension of Schedule K-1 of the Form 1065 and is generally used to report to partners their share of the items reported on Schedule K-2. These two schedules are new for tax year 2021.

Today we are focusing on Part 8 of both Schedules K-2 and K-3. For Schedule K-2, the partnership must complete a separate Schedule K-2 Part 8 for each CFC with respect to which it has a direct or indirect interest, unless the partnership does not have a direct or indirect partner that is a domestic corporation that is a U.S. shareholder or a domestic corporation that is eligible to make a 962 election to claim the deemed paid foreign tax credit with respect to such CFC. For Schedule K-3 Part 8, Part 8 must be completed and provided to both, A, direct partners that are domestic corporation U.S. shareholders or that may be eligible to make a Section 962 election and B, direct partners who may have direct or indirect partners who may be eligible to claim the indirect credit. Moving on to the filing requirements for Part 8. Please note that a partnership that does not have or receive sufficient information or notice regarding a direct or indirect partner must presume the partner is eligible to claim the indirect credit and must complete Schedules K-2 and K-3 accordingly. More information on filing requirements and a more detailed description of items of international tax relevance are further discussed in the FAQ link posted at the end of this presentation. However, one item to know is that Part 8 is not required to be completed with respect to dormant foreign corporations as defined in Section 3 of Rev Proc 92-70.

The partnership's and the partner's share of the CFC's net income in each of the Subpart F income groups, tested income group and residual income group by unit is reported on Lines 1 through 4. The Lines in Schedules K-2 and K-3 Part 8 mirror those lines on Form 5471 Schedule Q.

As we saw earlier, the CFC's net income and taxes in each of these groups is figured on Form 5471 Schedule Q, and the partnership need only report its share of income on Schedule K-2 and the partner's share of such amounts on Schedule K-3. As with the Schedule Q generally a partnership must file a separate Schedule K-2 and K-3 Part 8 for each category of income, and if applicable for the passive category of income, separate schedules for the high-tax kick-out groupings under Treasury regulation Section 1.904-4(c)(3). Moving to Columns (i) through (iii) instructions for Schedule K-2 and K-3, Part 8 reports both the partnership's share and the partner's share of the CFC's net income in each income group and functional currency. Columns (i) and (ii) are the only columns that the partnership reports in Part 8 because Form 5471, Schedule Q contains the other information that the partner needs to determine is deemed paid credit. Column (iii) does not need to be completed on either this K-2 or the K-3. Another item to note is Part 1 Box 8 of the Schedules K-2 and K-3. This box is checked on both schedules to indicate the attachment of Form 5471 Page 1 and 5471 Schedule Q to the K-3 for each CFC with respect to which the partnership has an interest. So going back to Column (i), consistent with the reporting requirement on Form 1118, enter the two letter code of each foreign country or U.S. possessions within which income is sourced and/or to which taxes are paid or accrued. Do not enter Various or OC for the country code. And finally for the partnership, Column (ii) reports that share of the CFC's net income by income groups and by units as reported in Column 11 (xi) of the Schedule Q. Lastly, on Schedule K-3 Column (ii), the partnership reports each partner's share of the net income in the income group by unit and country. And again do not include any amounts in Column (iii). Now, moving on to how we can use Schedule K-3 to complete the Form 1118, the partner will use each Schedule Q attached to the Schedule K-3 to determine the total net income in the Subpart F income groups of the CFC in order to report on Column 6 of Form 1118 Schedule C, and the total current year taxes by Subpart F income groups of the CFC to report on Column 7. The partner uses the information from the Schedule K-3 to complete Column 8(a) of Form 1118 Schedule C. This will allow the partner to figure the taxes deemed paid with respect to Section 951(a)(1) inclusions by Subpart F income group. Similarly, the partner will use Schedule Q attached to the Schedule K-3 to determine the total tested taxes in each tested income group to report on Form 1118, Schedule D, Column 8 and the CFC's tested income to report on Form 1118 Schedule D Column 6. The partner uses information from Schedule K-3 Part 8 to complete Column 5 of Form 1118, Schedule D, Part 1.

Now we will move on to two examples that will comprehensively demonstrate how the Schedules K-2 and K-3 are completed. In this first example, in year one, USP, a domestic partnership has two domestic corporate partners with equal interests in the partnership. USP wholly owns CFC. CFC earns passive category interest income of 100u sourced from Country X and pays withholding tax of $20 to a foreign country. USP completes Form 5471 including Schedule Q for CFC. The code for Country X is X. So, starting with Form 5471 Schedule Q, USP will report the following, Line A reports PAS for the passive category of income. The applicable passive grouping code on Line B is (i) which per the instructions applies to all passive income received during the tax year that is subject to withholding tax of 15% or greater. Since the CFC is reporting foreign personal holding company interest income, it completes Line (a)(1) and inserts the country code in Column (i), reported in the example as X, the net income in Column (xi) is reported in the example as 100u and the tax in Column (xii) is reported in the example as $20. Please note this example is also included in the Schedule K-3 instructions for the partner. Moving to Schedule K-3 Part 8, USP reports the following to each of its partners. Line B again reports passive and on Line C, the passive grouping is again (i) for passive income received during the tax year that is subject to a withholding of 15% or greater. Line 1 also remains the same as the Schedule Q reporting, except that the partner's share of the income is reported instead of the CFC's total income in that grouping. In this example, Column (i) would report Country X again and Column (ii)

reports 50u. Lastly on Form 1118, Schedule C with respect to the passive category, each domestic corporate partner reports the information received on Schedule K-3 and includes the attached Schedule Q. As you can see, Column 5(a) corresponds with the Subpart F income group DIRRA reported on the Schedule Q and Schedule K-3, Part 8. Column 5(b) corresponds with the passive grouping (i) as reported on Schedule Q and Schedule K-3, Part 8, Column 5(c) corresponds with the unit CFC reported on the Schedule Q and Schedule K-3, Part 8, Column 6 corresponds to the net income reported on Schedule Q, Column xi, Column 7 correspond to the taxes reported on Schedule Q Column 12. And lastly, Column 8(a) corresponds to the share of income reported on the Schedule K-3 Part 8 Column (ii). And that completes the example to show how Schedule Q, Schedule K-2 and Schedule K-3 of Form 1065 and the Form 1118 all tied together. I will now pass it back to Cindy who will end the session with a few closing remarks. Cindy Kim: Thank you, Julie. As I mentioned at the beginning of today's presentation, here are some resources to help you learn more about these new schedules. We provide the instructions to the Form 5471, Schedule Q as well as the partnership and partner level instructions to the Schedule K-2 and K-3. And as Julie mentioned, there is an FAQ for the Schedules K-2, and K-3 which provides the latest information on the schedules. I also mentioned earlier that we held a webinar on an overview of the Form 5471 last September, that is also linked here. And finally, here's our email address, in case you have any comments on today's topics, or if you have any suggestions for future events. Thank you to all our presenters today. Excellent job. And thank you for joining us today. We hope you found today's session to be helpful. Have a great day everybody.