Does every US owner of a UK limited company have to file Schedule I-1?

No. Schedule I-1 attaches to the controlled foreign corporation filing categories rather than to every Form 5471. The Instructions for Form 5471 confirm that a sole owner of a CFC, described in Categories 4 and 5a, files Schedules E, G-1, H, H-1, I-1, J, M, P, Q and R. Category 2 and Category 3 filers are not brought into Schedule I-1 by those categories alone. Check the Filing Requirements for Categories of Filers chart at irs.gov/instructions/i5471.

Is UK Corporation Tax deducted on line 5 or reported on line 7?

Both, and for different purposes. Line 5 covers deductions including taxes properly allocable to line 4, so UK Corporation Tax reduces tested income there. Line 7 then reports tested foreign income taxes attributable to the CFC's tested income group, translated at the average rate under section 986. Line 6 sizes the inclusion; line 7 sizes any deemed-paid credit. Reporting the tax in only one place will produce a wrong figure somewhere downstream.

Why is my UK consultancy's QBAI figure almost nothing?

Because QBAI measures depreciable tangible property only. It is the quarter-end average adjusted basis, computed under the section 168(g) alternative depreciation system, of specified tangible property used to produce tested income. Leased offices, goodwill, software, client lists, cash and receivables are all outside it. A people-based UK business owns laptops and furniture and little else, so the 10 percent deemed tangible income return shelters a negligible share of its profit.

Can an individual shareholder use the tested foreign income taxes on line 7?

Not without a section 962 election. The deemed-paid credit under section 960(d) runs to a domestic corporation that is a US shareholder. The Instructions for Form 5471 confirm that where an individual US shareholder makes a section 962 election, inclusions under section 951 or 951A are treated as received by a corporate US shareholder for section 960 purposes, allowing a foreign tax credit. Without the election, line 7 is filed correctly and yields nothing.

Does Schedule I-1 change now that the QBAI shelter is being repealed?

Not for a 2025 tax year. The December 2025 revision of Form 5471 is used with the December 2021 revision of separate Schedule I-1, which still carries QBAI on line 8, so you complete it as instructed. The One Big Beautiful Bill Act changes take effect for tax years beginning after 31 December 2025. Check IRS.gov/Form5471 for future developments before finalising any later year.

Form 5471 Schedule I-1: GILTI Inputs for UK Firms

Q: What exchange rate goes in the conversion rate column?

The rate expressed as pounds per one US dollar, rounded to at least four places, under the divide-by convention required by the Instructions for Form 5471. You must not report dollars per pound. The IRS yearly average currency exchange rates table at irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates is already published in this direction, and shows 0.759 pounds to one US dollar for 2025, so it can be used without inversion.

Schedule I-1 of Form 5471 is the schedule that converts a UK company's own accounts into the four numbers a US shareholder needs to compute a section 951A inclusion: tested income or tested loss, qualified business asset investment, tested interest expense and tested interest income, plus the tested foreign income taxes the company paid. The IRS states the purpose plainly in the Instructions for Form 5471 at irs.gov/instructions/i5471: the schedule reports information determined at the CFC level, and that information is then used by the US shareholder to file Form 8992. Nothing is taxed on Schedule I-1 itself. It is a measurement schedule. But it is the schedule that decides how large the inclusion will be, and in the returns we prepare for owners of UK trading companies it is the single most consequential page of the whole Form 5471 package.

The practical problem for a UK reader is that Schedule I-1 was designed around a manufacturing-shaped controlled foreign corporation with plant, machinery and premises. A UK consultancy, a fund-adjacent management company or a professional practice owns almost nothing that qualifies for line 8. That single structural mismatch is why UK service businesses so often see nearly all of their profit converted into a current US inclusion, while an asset-heavy business with the same profit sees materially less. This guide walks the schedule line by line, ties each line to the Form 8992 computation, and then deals with the two issues UK-facing filings actually turn on: the near-nil QBAI figure, and the UK Corporation Tax that lands on line 7 and, for many individual shareholders, does nothing at all.

What is Schedule I-1 of Form 5471 and what does it report?

Schedule I-1, Information for Global Intangible Low-Taxed Income, is a separate schedule attached to Form 5471. The current version is the December 2021 revision, and it is used with the December 2025 revision of Form 5471 itself, as the Instructions for Form 5471 confirm on their cover page. You can pull the schedule directly from irs.gov/pub/irs-pdf/f5471si1.pdf and the parent form details from irs.gov/forms-pubs/about-form-5471.

The schedule is a single page with three columns: functional currency, conversion rate, and US dollars. Lines 1 through 10c are entered in the CFC's functional currency, and the instructions require the amounts on lines 6 through 10c to be converted into US dollars. In other words, the first half of the schedule is an exercise in restating UK accounts onto a US tax basis, and the second half is a currency translation exercise. Both halves are audited by the same reviewer at the IRS, and both are places where a UK filing goes wrong quietly rather than loudly.

One structural point catches out filers who learned the schedule under earlier rules. Schedule I-1 is no longer completed separately for each applicable category of income. It is completed once, covering general category income, passive category income, or both. If line 6 includes any passive category income, the code PAS goes in the separate category box at the top of the schedule, even where the same schedule also carries general category income. A foreign corporation with only general category income on line 6 takes the code GEN. A typical UK trading company falls into GEN.

Who has to complete Schedule I-1?

Schedule I-1 is a controlled foreign corporation schedule, so it attaches to the filing categories that exist because of CFC status rather than because of a formation or acquisition event. The Filing Requirements for Categories of Filers chart in the Instructions for Form 5471 is the controlling reference, and the instructions also give the plain-English case directly: if you are the sole owner of a CFC, meaning you are described in Categories 4 and 5a, you complete all six pages of Form 5471 and separate Schedules E, G-1, H, H-1, I-1, J, M, P, Q and R.

That is the ordinary UK fact pattern. A US citizen resident in London who owns 100 percent of a UK limited company is a Category 4 filer because they control the company and a Category 5a filer because they are a US shareholder of a CFC. Schedule I-1 is in scope in both capacities. The narrower Category 5b and 5c positions, which exist for unrelated section 958(a) US shareholders and related constructive US shareholders of foreign-controlled CFCs under Rev. Proc. 2019-40, carry reduced schedule sets, and you should read the chart rather than assume.

Two practical points follow. First, a Category 3 filer who merely acquired shares, and a Category 2 filer reporting an officer or director event, are not brought into Schedule I-1 by those categories alone. Second, and more usefully for loss-making UK companies, the instructions state that when a schedule is required but all amounts are zero, the schedule should still be filed showing zero amounts. A dormant or loss-making year does not remove Schedule I-1 from the package. Omitting it because there is nothing to report is a filing failure, not a simplification.

How do the Schedule I-1 lines actually work?

Line 1 is the CFC's gross income. The instructions note that this will generally be a positive amount, but a negative figure is permitted where cost of goods sold exceeds gross receipts. For a UK services company this is turnover restated on US principles, not the statutory turnover figure lifted from the Companies House accounts.

Line 2 is the exclusions block, drawn from Regulations section 1.951A-2(c), and it is where income leaves the tested pool altogether. The five sub-lines are:

Line 2a, effectively connected income: the CFC's income or loss described in section 952(b), broadly US-source income effectively connected with a US trade or business and not reduced or exempted by a US income tax treaty.
Line 2b, subpart F income: gross income or loss taken into account in determining subpart F income under section 952, computed after applying the section 954(b)(4) high-tax exception but before the earnings and profits limitation in section 952(c)(1).
Line 2c, high-tax exception income under section 954(b)(4): amounts excluded from foreign base company income and insurance income, and expressly including amounts excluded from tested income under the GILTI high-tax exclusion in Regulations section 1.951A-2(c)(7).
Line 2d, related party dividends: dividend income received from a related person as defined in section 954(d)(3), excluding amounts already captured on line 2b or line 2c.
Line 2e, foreign oil and gas extraction income: taxable income or loss from extraction of minerals from oil or gas wells located outside the United States and its territories, and from the sale or exchange of assets used in that trade or business.

Line 3 combines lines 2a through 2e and can be positive or negative. Line 4 is line 1 minus line 3, and is described in the instructions as gross income less total exclusions. Line 4 has a second life: it is the definition of gross tested income used later in the QBAI dual-use calculation, so a mistake on line 4 propagates into line 8.

Line 5 is deductions, including taxes, properly allocable to the amount on line 4, or that would be allocable if there were such gross income, under section 951A(c)(2)(A)(ii) and Regulations section 1.951A-2(c)(3). The phrase including taxes is the one UK filers need to read twice. UK Corporation Tax charged in the accounts is a deduction here. Line 5 will generally be positive, though a negative amount is permitted.

Line 6 is line 4 minus line 5: tested income if positive, tested loss if negative. This is the number the whole schedule exists to produce, and it must be converted from functional currency to US dollars using the average exchange rate for the year of the CFC, under Regulations section 1.951A-1(d)(1).

Line 7 is tested foreign income taxes. If line 6 is a tested loss, the instructions require zero. If line 6 is tested income, you enter only those foreign income taxes properly attributable to the CFC's tested income group, translated to US dollars at the average exchange rate for the year under section 986.

Line 8 is qualified business asset investment, and it follows the same on-off switch: a tested loss on line 6 means zero on line 8; tested income means you enter QBAI, translated at the average rate. QBAI is defined in the instructions as the average of the CFC's aggregate adjusted bases, as of the close of each quarter of its tax year, in specified tangible property used in its trade or business in the production of tested income and for which a deduction is allowable under section 167. Adjusted basis must be determined using the alternative depreciation system under section 168(g), with depreciation allocated ratably to each day of the period to which it relates.

Lines 9a through 9d build tested interest expense under Regulations section 1.951A-4(b)(1). Line 9a is interest expense included on line 5. Line 9b is qualified interest expense. Line 9c is the tested loss QBAI amount. Line 9d subtracts the sum of 9b and 9c from 9a, floored at zero. Lines 10a through 10c build tested interest income under Regulations section 1.951A-4(b)(2): line 10a is interest income included in line 4, line 10b is qualified interest income, and line 10c is 10a minus 10b, floored at zero.

Which currency, and how is the exchange rate reported?

Every figure on lines 1 through 10c starts in the CFC's functional currency, which for a UK trading company is normally pounds sterling. Lines 6 through 10c are then translated to US dollars. Tested income on line 6 and QBAI on line 8 use the average exchange rate for the CFC's year under Regulations section 1.951A-1(d)(1); tested foreign income taxes on line 7 use the average exchange rate under section 986.

The convention for reporting the rate itself trips up more UK filings than the arithmetic does. The Instructions for Form 5471 require every exchange rate on the form to be reported using a divide-by convention rounded to at least four places. The rate must be expressed as the amount by which the functional currency figure must be divided to give the US dollar equivalent, which means units of foreign currency that equal one US dollar. The instructions are explicit that you must not report the rate as the number of US dollars that equal one unit of foreign currency, and that you must round to more than four places where four would materially distort the result.

Sterling is the currency where this bites hardest, because the market quote most UK accountants have in their head runs the other way. A rate of about 1.32 dollars to the pound is the quote you will see in a UK newspaper; it is not the number that belongs in the conversion rate column. Helpfully, the IRS yearly average currency exchange rates table at irs.gov/individuals/international-taxpayers/yearly-average-currency-exchange-rates is already published in the divide-by direction. The instruction on that page is to divide the foreign currency amount by the applicable yearly average rate, and the United Kingdom rate published for 2025 is 0.759 pounds to one US dollar. That figure can be dropped straight into the conversion rate column without inversion.

How does Schedule I-1 feed the Form 8992 computation?

The Instructions for Form 8992 at irs.gov/pub/irs-pdf/i8992.pdf describe the handoff precisely: the US shareholder files Schedule A (Form 8992) to report its pro rata share of amounts for each CFC from each CFC's Schedule I-1 (Form 5471). The mapping is line for line, and it is worth committing to memory because it tells you exactly which Schedule I-1 errors change the tax:

Schedule A column (c), tested income, comes from Schedule I-1 line 6, and column (d), tested loss, comes from the same line where it is negative.
Column (g), pro rata share of QBAI, comes from Schedule I-1 line 8, and only for a tested income CFC; a tested loss CFC gets no entry in this column.
Column (h), pro rata share of tested loss QBAI amount, comes from the tested loss QBAI figure at Schedule I-1 line 9c.
Column (i), pro rata share of tested interest income, comes from Schedule I-1 line 10c.
Column (j), pro rata share of tested interest expense, comes from Schedule I-1 line 9d.
Columns (e) and (f) are the shareholder's pro rata shares of tested income and tested loss under Regulations section 1.951A-1(d)(2) and 1.951A-1(d)(4).

Form 8992 then does the arithmetic on its own face. Part I sums the pro rata shares of net tested income and net tested loss and combines them at line 3 to give net CFC tested income; if that is zero or less you stop. Part II line 2 computes the deemed tangible income return by multiplying the Schedule A line 1 column (g) total by 10 percent. Line 3a is total tested interest expense, line 3b is total tested interest income, and line 3c subtracts 3b from 3a to give specified interest expense, floored at zero. Line 4 is net deemed tangible income return, being line 2 less line 3c, floored at zero. Line 5 subtracts line 4 from net CFC tested income to give the inclusion. Form 8992 details are at irs.gov/forms-pubs/about-form-8992.

The routing of the result matters for UK-based owners. The Instructions for Form 8992 direct a corporate shareholder to line 17 of Form 1120, Schedule C, and an individual shareholder to line 8o of Schedule 1 (Form 1040). Any section 250 deduction is claimed separately on Form 8993, not on Form 8992.

Why does line 8 leave a UK services company so exposed?

Here is the gap almost nobody addresses honestly for a UK audience. The deemed tangible income return is a 10 percent return on QBAI, and QBAI is a measure of depreciable tangible property. Specified tangible property means tangible property used in the production of tested income for which a section 167 deduction is allowable, held at adjusted basis computed under the section 168(g) alternative depreciation system, averaged across the four quarter-ends of the year. A UK consultancy, a fund-adjacent management company, a design studio, a recruitment business or a professional practice typically owns laptops, monitors, a few desks and perhaps some leasehold fit-out. Nothing else on the balance sheet qualifies.

What does not count is the longer list, and it is the list that describes most UK service businesses: leased office space, since the property is not owned; goodwill and intangibles, since they are not tangible property; cash and receivables; investments; the value of the team; and the client list. Software is an intangible. A brand is an intangible. So a UK company generating substantial profit from people and know-how carries a QBAI figure that is a rounding error against its tested income, and 10 percent of a rounding error is a smaller rounding error.

The consequence is arithmetic, not opinion. If QBAI is near nil, the deemed tangible income return is near nil, and Form 8992 line 5 lands within a fraction of a percent of net CFC tested income. Effectively all tested income becomes a current inclusion. An otherwise identical UK company holding owned premises, plant or a vehicle fleet would shelter a meaningful slice of the same profit. The provision was written to exempt a routine return on tangible capital, and a business that runs on people rather than capital is, by design, outside the shelter. In the returns we prepare, this is the single most common reason a UK founder's US tax bill is larger than the guidance they read online led them to expect.

Two refinements are worth knowing because they occasionally rescue a small amount of QBAI. Dual-use property, meaning tangible property used to produce both tested income and other income, counts as specified tangible property in the same proportion that line 4 tested income bears to total gross income produced by that property. And where the CFC is a partner in a partnership holding depreciable tangible property, Regulations section 1.951A-3(g) gives the CFC a share of the partnership's average adjusted basis, determined by reference to the distributive share of gross income produced by the property that is included in the CFC's gross tested income.

How does UK Corporation Tax become tested foreign income taxes on line 7?

UK Corporation Tax paid by the UK company is a foreign income tax, and where it is properly attributable to the CFC's tested income group it belongs on Schedule I-1 line 7, translated at the average rate under section 986. The UK rates are published at gov.uk/corporation-tax-rates: a main rate of 25 percent on profits above 250,000 pounds, a small profits rate of 19 percent on profits of 50,000 pounds or less, and marginal relief between those thresholds, with both thresholds reduced proportionately for short accounting periods and for the number of associated companies. Those rates have applied from 1 April 2023.

Note the double role UK Corporation Tax plays on this schedule. It is deducted on line 5 as a tax properly allocable to line 4, which reduces tested income on line 6. It is then reported again on line 7 as tested foreign income taxes. That is not duplication; the two lines serve different downstream users. Line 6 sizes the inclusion. Line 7 sizes the deemed-paid foreign tax credit available to a shareholder entitled to claim one.

And that is the second gap. An individual US shareholder living in the UK who has not made a section 962 election cannot use the amount on line 7. The deemed-paid credit under section 960(d) runs to a domestic corporation that is a US shareholder. The Instructions for Form 5471 spell out the exception: where an individual who is a US shareholder of a CFC makes a section 962 election, inclusions under section 951 or 951A are treated as received by a corporate US shareholder for purposes of section 960, and that shareholder may then claim a foreign tax credit for foreign income taxes deemed paid, under sections 962(a)(1) and 951A(f)(1)(A). Without that election, line 7 is completed accurately, filed dutifully, and produces nothing.

The point is sharpened by basketing. The instructions note that GILTI inclusion amounts and taxes with respect to the tested income group are generally treated as income and deemed paid taxes in the section 951A separate category, citing Regulations sections 1.904-4(g) and 1.904-6(e). The inclusion therefore sits in its own foreign tax credit basket. An individual without a section 962 election has an inclusion in that basket and no taxes in it, and cannot import credits from the general category to cover it. The UK tax was genuinely paid, it is genuinely reported on line 7, and it is genuinely stranded.

For completeness, the credit is haircut even where it is available. IRS Notice 2025-77, at irs.gov/pub/irs-drop/n-25-77.pdf, sets out the background: prior to the One Big Beautiful Bill Act, section 960(d)(1) deemed a domestic corporate US shareholder to have paid 80 percent of the product of its inclusion percentage and the aggregate tested foreign income taxes of its CFCs, effectively a 20 percent reduction. The notice confirms that the Act changed that reduction from 20 percent to 10 percent.

How does Schedule I-1 interact with Schedule Q and Schedule J?

Schedule Q reports the CFC's income, deductions, taxes and assets by CFC income groups for purposes of section 960(a) and (d). Its line 3 is the tested income group, defined by reference to Regulations section 1.960-1(d)(2)(ii)(C). That is the same tested income group referenced in the line 7 instruction on Schedule I-1, so the two schedules have to agree. If line 7 reports UK Corporation Tax as attributable to the tested income group, Schedule Q must carry that tax in the same group, by tested unit.

The high-tax interaction is where Schedule Q and Schedule I-1 diverge in a way that looks like an error but is not. Schedule Q line 3 is completed by tested unit based on tentative gross tested income without regard to amounts excluded under the GILTI high-tax exclusion, and any tested unit amounts actually excluded under that exclusion are carried into the line 4 residual income group instead. So the line 3 total may legitimately fail to equal the sum of the amounts shown on lines 3(1), 3(2) and so on. On Schedule I-1 the same election appears in a different place, as an exclusion on line 2c. A reviewer who does not know both conventions will chase a reconciliation that does not exist.

Schedule J reports accumulated earnings and profits in functional currency under sections 964(a) and 986(b). Its link to Schedule I-1 runs through the inclusion rather than the inputs. Once Form 8992 produces the inclusion, Schedule A column (l) allocates it back to each tested income CFC, and the Instructions for Form 8992 state that this allocation is used in completing Schedule J and Schedule P for each CFC. That is how a section 951A inclusion becomes previously taxed earnings and profits, so that a later dividend from the UK company is not taxed twice. Two conventions matter here: a separate Schedule J should not be completed for the section 951A category, with section 951A previously taxed earnings and profits reported on the general category Schedule J instead; and the instructions confirm that Schedule J reporting is required whether or not a section 962 election was made.

A worked example: a UK consultancy's Schedule I-1

The following figures are illustrative only and are chosen to show the mechanics, not to represent any client. Assume a UK consultancy with a 31 December 2025 year end, wholly owned by a US citizen resident in London who has not made a section 962 election, with a functional currency of pounds sterling and no US activity. Assume the IRS yearly average rate for 2025 of 0.759 pounds to one US dollar, applied under the divide-by convention.

Line 1 gross income is 1,000,000 pounds. There is no effectively connected income, no subpart F income, no high-tax exclusion election, no related party dividends and no oil and gas income, so lines 2a through 2e and line 3 are nil, and line 4 is 1,000,000 pounds. Line 5 deductions properly allocable comprise 700,000 pounds of salaries, rent and overheads plus 75,000 pounds of UK Corporation Tax at the 25 percent main rate on 300,000 pounds of taxable profit, giving 775,000 pounds. Line 6 tested income is therefore 225,000 pounds, which divided by 0.759 gives 296,443 US dollars.

Line 7 tested foreign income taxes is the 75,000 pounds of UK Corporation Tax, which divided by 0.759 gives 98,814 US dollars. Line 8 QBAI is the alternative depreciation system quarter-end average basis of the laptops, monitors and office furniture, assumed at 12,000 pounds, giving 15,810 US dollars. There is no borrowing, so lines 9a through 9d are nil. Bank interest of 800 pounds included in line 4 gives line 10a of 800 pounds and, with no qualified interest income, line 10c of 800 pounds, or 1,054 US dollars.

Now run those figures through Form 8992. Schedule A column (c) carries tested income of 296,443 dollars and column (e) the same, since ownership is 100 percent. Column (g) carries QBAI of 15,810 dollars, column (i) tested interest income of 1,054 dollars, and column (j) nil. Part I line 3 net CFC tested income is 296,443 dollars. Part II line 2 deemed tangible income return is 10 percent of 15,810, or 1,581 dollars. Line 3a is nil and line 3b is 1,054, so line 3c specified interest expense is zero after the floor. Line 4 net deemed tangible income return is 1,581 dollars. Line 5 gives an inclusion of 294,862 dollars.

That inclusion is 99.5 percent of tested income. Line 8 sheltered roughly half a percent of the profit. Meanwhile line 7 reports 98,814 dollars of genuine UK Corporation Tax which, absent a section 962 election, this shareholder cannot claim as a deemed-paid credit, and there is no section 250 deduction on Form 8993 either. The full 294,862 dollars goes to line 8o of Schedule 1 (Form 1040) at ordinary rates. That gap between the tax actually paid to HMRC and the credit available on the US return is the entire reason a section 962 election is on the table for owners of profitable UK service companies.

What changes for tax years beginning after 31 December 2025?

The One Big Beautiful Bill Act, Public Law 119-21, enacted on 4 July 2025 and cited in the What's New section of the Instructions for Form 5471, reshapes this area for tax years beginning after 31 December 2025. Two of its changes are already reflected in IRS guidance. The reduction in deemed-paid tested foreign income taxes moves from 20 percent to 10 percent, per Notice 2025-77. And the Act repeals the deemed tangible income return, so the 10 percent QBAI shelter that Form 8992 line 2 computes ceases to apply for those later years, with the regime renamed by reference to net CFC tested income.

For a UK reader the practical read is straightforward, and slightly ironic. The QBAI disadvantage described above is a disadvantage relative to asset-heavy CFCs, and that relative disadvantage disappears once the shelter disappears for everyone. In absolute terms, a UK services company whose QBAI was already near nil sees very little change from the repeal itself, because it was never sheltering anything. Asset-heavy structures see the larger swing. Separately, the improvement in the deemed-paid haircut helps only shareholders who can access deemed-paid credits at all, which returns the individual UK-resident owner to the same section 962 question.

Do not let that future state change what you file now. The December 2025 revision of Form 5471 is used with the December 2021 revision of separate Schedule I-1, and that schedule still has QBAI on line 8. For a 2025 tax year filed during 2026, you complete line 8 as the instructions direct. Check IRS.gov/Form5471 for future developments before finalising any later year, since the Act's changes are still being worked through in forms and guidance.

The Schedule I-1 errors we correct most often on UK filings

Reporting the conversion rate as dollars per pound. The instructions require the divide-by convention, expressed as units of foreign currency per one US dollar, rounded to at least four places. Sterling filings get this wrong more often than any other currency because the market quote runs the other way.
Leaving Schedule I-1 out of a loss-making or dormant year. The instructions require the schedule to be filed with zero amounts where it is required at all.
Entering QBAI on line 8 or tested foreign income taxes on line 7 in a tested loss year. Both lines require zero where line 6 is negative.
Computing QBAI from the UK statutory accounts net book value. The measure is adjusted basis under the section 168(g) alternative depreciation system, averaged at each quarter end, not UK depreciation or capital allowances.
Omitting UK Corporation Tax from line 5. The line covers deductions including taxes properly allocable to line 4, and leaving it out overstates tested income on line 6.
Completing Schedule I-1 once per separate category. The schedule is now completed once, coded GEN or PAS at the top, with PAS required whenever line 6 includes passive category income.
Using a different reference ID number on Schedule A (Form 8992) from the one on Form 5471. The Instructions for Form 8992 require the two to match for each CFC.
Assuming line 7 delivers a credit to an individual. Without a section 962 election, tested foreign income taxes reported on line 7 give an individual US shareholder no deemed-paid credit.

The through-line in all of these is that Schedule I-1 is a measurement schedule feeding a computation schedule. Every figure on it is used somewhere else, by someone who cannot see your working. Get line 6 wrong and the inclusion is wrong. Get line 8 wrong and the shelter is wrong. Get the conversion rate direction wrong and every dollar column on the page is wrong by a factor of roughly 1.7. In UK company filings, the difference between a clean Form 5471 package and a costly one is almost always decided on this single page.