Paul Kelly, a resident of Boston, Massachusetts, owns 51 of the 100 outstanding IslewoodCo, a corporation headquartered

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Paul Kelly, a resident of Boston, Massachusetts, owns 51 of the 100 outstanding IslewoodCo, a corporation headquartered in Dublin, Ireland. The remaining 19 outstar shares are owned by diverse foreign interests. IslewoodCo purchases furniture from Paul Kelly for resale. All of IslewoodCo's purchases and sales are in the euro, with 75% of its sales to customers in Ireland and 25% of its sales to customers in Finland. Paul Kelly, as President, is the only officer and director of IslewoodCo. The small business tax rate in Ireland is 12.5%. Both Paul Kelly and IslewoodCo are on the calendar year. IslewoodCo does not pay any dividends. Neither Paul Kelly nor IslewoodCo own an interest in any other foreign entities. In addition, none of the shares are considered securities or debt for U.S. tax purposes. During 2015, assume the average exchange rate for the euro was $1.35 or 60.74 per U.S. dollar, which was also the spot rate on December 31, 2015. IslewoodCo keeps all its cash in a non-interest bearing account. Paul Kelly acquired his shares of IslewoodCo, as did all the other foreign shareholders, on January 1, 2015, based on his capital contribution of 5,100,000 for common shares. Paul Kelly timely files his return with the Kansas City Service Center, without ever pursuing an extension.

The chartered accountant in Dublin provides the following information about IslewoodCo for the year ended When filing Form 5471, Paul Kelly is a Category 2 filer because he is a U.S. citizen who is an officer or director of IslewoodCo and he has acquired at least 10% of his shares during 2015. He is a Category 3 filer because he is a U.S. shareholder (at least 10% shareholdings). He controls a foreign corporation, IslewoodCo, for an uninterrupted period of at least 30 days during 2015 and is a Category 4 filer. He is a Category 5 filer because he is a U.S. shareholder of IslewoodCo, which was a CFC, on the last day of the 2015 tax year.

Paul Kelly will report $2,756,757 of Subpart F income, which constitutes foreign-base company sales income from IslewoodCo's purchase of furniture from Paul and IslewoodCo's resale to customers in Finland. Twenty-five percent of net income from sales in Finland is 6 4 million, of which Paul's 51% share was

Please change all 2015 dates in the attached fact pattern
to 2022. Please disregard any potential section 965 transition tax requirements (deem those
requirements to be in the past and prepare the Form 5471 as if those requirements no longer
apply).
Assignment:
Please prepare Form 5471, including any necessary schedules or attachments thereto, for the
2022 tax year. Please print the form and carefully read the instructions, line by line, to ensure
that you complete the form completely and accurately. Please let me know if you have any
questions or are missing any information. Paul Kelly's address is as follows:
678 Maple Street
Boston, MA 02215
His SSN is 123-45-6789.
InglewoodCo's reference number is FS1234 and it was incorporated on 1/1/2022 and its
principal place of business is Ireland. Its principal activity code is 423200. InglewoodCo's
principal business activity is furniture sales and its functional currency is the Euro.
The name and address of the location of InglewoodCo's books and records is:
John Shea, Controller
17 Shamrock Lane
Dublin, Ireland