987 gains/losses, Subpart F income, ECI, Global Intangible Low Taxed Income, CFC attribution, Section 245A Deduction, hybrid transactions, 163(j), FDII, etc; support the preparation of Forms 1118 and 1116 for foreign tax credits and supporting documentation; and determine and maintain supporting documentation for 861 allocations to foreign source income. Prepare and review Forms 5471 for controlled foreign corporations, Forms 8858 and 8865 for flow through foreign entities, Forms 1120, 1065 1120-S for U.S. companies with foreign operations, Form 1120-F for foreign corporations with U.S. trades or business/permanent establishments, and Forms 5472, 8804/8805, 1042/1042-S, 8828/8288-A/8288-B, etc.