Worksheet - - U.S. Shareholder's Pro Rata Share of Earnings of a C.F.C. Invested in U.S. Property Worksheet - - U.S. Shareholder's Pro Rata Share of Earnings of a C.F.C. Invested in U.S. Property Summary: This is an example of Worksheet B, used to calculate the U.S. shareholder's share of earnings of a C.F.C. from investment in U.S. property and to translate the amount from functional currency to U.S. dollars. The line items to be completed are: "1. Amount of U.S. property (as defined in sections 956(c) and (d)) held (directly or indirectly) by the C.F.C. as of the close of:" "1a. The first quarter of the tax year" field "1b. The second quarter of the tax year" field "1c. The third quarter of the tax year" field "1d. The fourth quarter of the tax year" field "2. Number of quarter-ends the foreign corporation was a C.F.C. during the tax year" field "3. Average amount of U.S. property held (directly or indirectly) by the C.F.C. as of the close of each quarter of the tax year. (Add lines 1a through 1d. Divide this amount by the number on line 2.)" field "4. U.S. shareholder's pro rata share of the amount on line 3" field "5. 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. shareholder’s section 959(c)(1) E&P account" field "6. Section 956(a)(1) amount. Subtract line 5 from line 4" field "7. Applicable earnings:" "7a. Current earnings and profits" field "7b. Line 7a plus accumulated earnings and profits" field "8. Enter the greater of line 7a or line 7b" field "9. Distributions made by the C.F.C. during the tax year" field "10. Subtract line 9 from line 8" field "11. Earnings and profits described in section 959(c)(1)" field "12. Applicable earnings. Subtract line 11 from line 10" field "13. Section 956(a)(2) amount. U.S. shareholder's pro rata share of the amount on line 12" field "14. Section 956(a) amount. Enter the smaller of line 6 or line 13" field "15. Amount of E&P described in section 959(a)(2) with respect to the U.S. shareholder" field "16. Tentative section 956 amount. Subtract line 15 from line 14." field "17. Amount of deduction under section 245A, if any, that the shareholder would be allowed if the shareholder received a hypothetical distribution within the meaning of Regulations section 1.956-1(a)(2). If the shareholder is not a U.S. corporation, this amount is zero" field "Section 956 inclusion. Subtract line 17 from line 16" "19. Translate the amount on line 18 from functional currency to U.S. dollars at the year-end spot rate (as provided in section 989(b)). Enter the result here and on line 2 of Schedule I" field
