1221 Form 8865 (Schedule G) (PDF)

Official source: IRS Forms, Instructions & Publications (https://www.irs.gov/pub/irs-pdf/f8865sg.pdf), retrieved 2026-10-03. U.S. Government work (17 U.S.C. § 105).

* Total must include any amounts included on an attached statement. See instructions.

For Paperwork Reduction Act Notice, see the Instructions for Form 8865. Cat. No. 71017D Schedule G (Form 8865) (Rev. 12-2021)

Schedule G (Form 8865) (Rev. 12-2021) Page 2 Part III Allocation Percentages of Partnership Items With Respect to Section 721(c) Property (see instructions)

(c) Related foreign

1. Income

(b) Related domestic

partners

(a) U.S. transferor

2. Gain

(b) Related domestic

partners

(a) U.S. transferor

3. Deduction

(b) Related domestic

partners

(a) U.S. transferor

4. Loss

(b) Related domestic

partners

Part I,

(a) U.S. transferor

line number

transferor partners partners transferor partners partners transferor partners partners transferor partners partners

number

1 % % % % % % % % % % % % 2 % % % % % % % % % % % % 3 % % % % % % % % % % % % 4 % % % % % % % % % % % % Part IV Allocation of Items to U.S. Transferor With Respect to Section 721(c) Property (see instructions)

partners

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Part I, line number	(a) Book	(b) Tax	(a) Book	(b) Tax	(a) Book	(b) Tax	(a) Book	(b) Tax	(b) Tax	(b) Tax	(b) Tax
1
2
3
4
Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Part V Additional Information(see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.	Yes	No
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	2

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	3

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	4

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	5

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	6a

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	6b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	7a

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . .

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
. . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	1 During the tax year, did an acceleration event or partial acceleration event (as described in Regulations section 1.721(c)‐4 or Regulations section 1.721(c)‐ 5(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 During the tax year, did a termination event (as described in Regulations section 1.721(c)‐5(b)) occur with respect to one or more section 721(c) properties? 3 During the tax year, did a successor event (as described in Regulations section 1.721(c)‐5(c)) occur with respect to one or more section 721(c) properties? 4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐5(f))? . . . 5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in Regulations section 1.721(c)‐5(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 aWas any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . b

Part I, line number	1. Income		2. Gain		3. Deduction		4. Loss
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 7 aWas a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c)‐6(b)(2)(iii)) filed with respect to each section 721(c) property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? See Regulations section 1.721‐6(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .	7b

Schedule G (Form 8865) (Rev. 12-2021)