2025 Form 8865 (PDF)

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/f8865.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

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OMB No. 1545-0123

Attach to your tax return. Go to www.irs.gov/Form8865 for instructions and the latest information.

Department of the Treasury Internal Revenue Service

Information furnished for the foreign partnership’s tax year Attachment beginning , 2025, and ending , 20 Sequence No. 865

Name of person filing this return Filer’s identification number

Filer’s address (if you aren’t filing this form with your tax return)

Number and street. If P.O. box, see instructions. Apt. or suite no.

City or town State or province Country ZIP or foreign postal code

A Category of filer (see Categories of Filers in the instructions and check applicable box(es)): 1 2 3 4 B Filer’s tax year beginning , 20 , and ending , 20

C Filer’s share of liabilities: Nonrecourse $ Qualified nonrecourse financing $ Other $ D If filer is a member of a consolidated group but not the parent, enter the following information about the parent:

Name EIN

Address E Check if any excepted specified foreign financial assets are reported on this form. See instructions . . . . . . . . . . . . F Information about certain other partners (see instructions)

(4) Check applicable box(es) (1) Name (2) Address (3) Identification number Category 1 Category 2 Constructive owner

G1 Name and address of foreign partnership 2(a) EIN (if any)

2(b) Reference ID number (see instructions)

3 Country under whose laws organized

4 Date of organization

5 Principal place of business

6 Principal business activity code number

7 Principal business activity

8a Functional currency 8b Exchange rate (see instructions)

H Provide the following information for the foreign partnership’s tax year:

5 During the tax year, did the foreign partnership pay or accrue any interest or royalty for which the deduction is not allowed under section 267A? See instructions . . . . . . . . . . . . . . . . . . . . . . Yes No If “Yes,” enter the total amount of the disallowed deductions . . . . . . . . . . . . . . . . . . . . . $

7 Were any special allocations made by the foreign partnership? . . . . . . . . . . . . . . . . . Yes No

8 a Enter the number of Forms 8858, Information Return of U.S. Persons With Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs), attached to this return. See instructions . . . . . . . . . . . . . b Reserved for future use . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

9 How is this partnership classified under the law of the country in which it’s organized? . .

10 a Does the filer have an interest in the foreign partnership, or an interest indirectly through the foreign partnership, that’s a separate unit under Regulations section 1.1503(d)-1(b)(4) or part of a combined separate unit under Regulations section 1.1503(d)-1(b)(4)(ii)? If “No,” skip question 10b . . . . . . . . . . . . . . . . . . . . . . Yes No

b If “Yes,” does the separate unit or combined separate unit have a dual consolidated loss, as defined in Regulations section 1.1503(d)-1(b)(5)(ii)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No

For Privacy Act and Paperwork Reduction Act Notice, see the separate instructions. Cat. No. 25852A Form 8865 (2025) Created 12/8/25

Form 8865 (2025) Page 2

Does this partnership meet both of the following requirements?

1. The partnership’s total receipts for the tax year were less than $250,000.

2. The value of the partnership’s total assets at the end of the tax year was less than $1 million. ^. . . . . . . Yes No

11 Does this partnership meet both of the following requirements?

1. The partnership’s total receipts for the tax year were less than $250,000.

12 a Is the filer of this Form 8865 claiming a foreign-derived intangible income (FDII) deduction (under section 250) with respect to any transaction with the foreign partnership? If “Yes,” complete lines 12b, 12c, and 12d. See instructions . . Yes No

b Enter the amount of gross receipts derived from all sales of general property to the foreign partnership that the filer included in its computation of foreign-derived deduction eligible income (FDDEI) . . . . . . . . . . . .

c Enter the amount of gross receipts derived from all sales of intangible property to the foreign partnership that the filer included in its computation of FDDEI . . . . . . . . . . . . . . . . . . . . . . . . .

d Enter the amount of gross receipts derived from all services provided to the foreign partnership that the filer included in its computation of FDDEI . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

13 Enter the number of foreign partners subject to section 864(c)(8) as a result of transferring all or a portion of an interest in the partnership or of receiving a distribution from the partnership . . . . . . . . . . . . . . . . .

14 At any time during the tax year, were any transfers between the partnership and its partners subject to the disclosure requirements of Regulations section 1.707-8?. . . . . . . . . . . . . . . . . . . . . . . Yes No

interest you constructively own. See instructions.

EIN Name Address (if any)

Total ordinary income or loss

Check if

foreign partnership

Form 8865 (2025)

Form 8865 (2025) Page 3 Schedule B Income Statement—Trade or Business Income Caution: Include only trade or business income and expenses on lines 1a through 22 below. See the instructions for more information.

Form 8865 (2025) Page 4

Form 8865 (2025) Page 5

Form 8865 (2025) Page 6 Schedule N Transactions Between Controlled Foreign Partnership and Partners or Other Related Entities Important: Complete a separate Form 8865 and Schedule N for each controlled foreign partnership. Enter the totals for each type of transaction that occurred between the foreign partnership and the persons listed in columns (a) through (d).