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Charges to statutory reserves.

the FDE due to currency or other

CFP set of columns. If you are completing

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Inventory adjustments. Inventories

restrictions or limitations imposed under

Schedule M for an FDE for which the tax

must be taken into account according to

the laws of any foreign country.

owner is a CFC, check the box for CFCs

the rules of sections 471 (incorporating

and complete lines 1 through 19 using the

Schedule M

the provisions of section 263A) and 472

headings in columns (a) through (f) of the

and the related regulations.

CFC set of columns.

Important: In translating the amounts

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Taxes. See the instructions for

Column (e). Use column (e) to report

from functional currency to U.S. dollars,

Schedule C, line 7.

transactions between the FDE and any

use the average exchange rate for the

U.S. person with a 10% or more direct

Attach a separate schedule that lists

FDE’s tax year. See section 989(b).

each applicable adjustment item. For

Report the exchange rate in the entry

interest in the CFP or any 10% or more

each adjustment item, indicate the

space provided at the top of Schedule M

U.S. shareholder of any corporation

adjustment amount and whether the

using the “divide-by convention” specified

controlling the CFC. If you are a Category

amount is a net addition or net

under Reporting Exchange Rates on

1 filer of Form 8865, or a Category 4 filer

subtraction. The separate schedule

Form 8858 on page 2.

of Form 5471, do not report transactions

should also show two totals, the total net

between yourself and the FDE under

Every U.S. person that is required to

additions amount to be entered on line 2,

column (e). Report the transactions only

file Schedule M (see Who Must File on

and the total net subtractions amount to

under column (b).

page 1) must file the schedule to report

be entered on line 3.

Line 6. Report on line 6 dividends

the transactions that occurred during the

received by the FDE that were not

Line 5. DASTM gain or (loss), reflecting

FDE’s annual accounting period ending

previously taxed under subpart F in the

unrealized exchange gain or loss, should

with or within the U.S. person’s tax year.

current year or in any prior year.

be entered on line 5 only for FDEs that

If a U.S. corporation is the U.S. person

use DASTM.

Lines 18 and 19. Report on lines 18 and

filing Schedule M and is a member of a

19 the largest outstanding balances

Line 7. Enter the line 6 functional

consolidated group, list the common

during the year of gross amounts

currency amount translated into U.S.

parent as the U.S. person filing Schedule

borrowed from, and gross amounts

dollars at the average exchange rate for

loaned to, the related parties described in

the FDE’s tax year. See section 989(b).

Column headings. There are 2 sets of

columns (b) through (f). Do not enter

Report the exchange rate using the

column headings above lines 1 through

aggregate cash flows, year-end loan

“divide-by convention” specified under

19. The first set of column headings is to

balances, average balances, or net

Reporting Exchange Rates on Form 8858

be used in cases where the tax owner is a

on page 2. If the FDE uses DASTM, enter

balances. Do not include open account

CFP. The second set of column headings

on line 7 the same amount entered on

balances resulting from sales and

is to be used in cases where the tax

line 6.

purchases reported under other items

owner is a CFC. If you are completing

listed on Schedule M that arise and are

Blocked income. The E&P or taxable

Schedule M for an FDE for which the tax

collected in full in the ordinary course of

income of the FDE, as reflected on

owner is a CFP, check the box for CFPs

business.

Schedule H, must not be reduced by all or

and complete lines 1 through 19 using the

any part of such E&P or taxable income

headings in columns (a) through (e) of the

that could not have been distributed by

Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the United

States. You are required to give us the information. We need it to ensure that you are complying with these laws and to allow us to

figure and collect the right amount of tax.

You are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless the

form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long as their

contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are

confidential, as required by section 6103.

The time needed to complete and file this form and related schedules will vary depending on individual circumstances. The

estimated burden for individual taxpayers filing this form is approved under OMB control number 1545-0074 and is included in the

estimates shown in the instructions for their individual income tax return. The estimated burden for all other taxpayers who file this

form is shown below.

Learning about the

Preparing and sending

Form

Recordkeeping

law or the form

the form to the IRS

8858

17 hr., 56 min.

4 hr., 10 min.

4 hr., 38 min.

Sch. M (8858)

24 hr., 9 min.

6 min.

30 min.

If you have comments concerning the accuracy of these time estimates or suggestions for making this form and related

schedules simpler, we would be happy to hear from you. See the instructions for the tax return with which this form is filed.

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Instructions For Form 8858 - Information Return Of U.s. Persons With Respect To Foreign Disregarded Entities Page 4

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