Part VI. Information on Partner’s Section 951(a)(1) and Section 951A Inclusions

Use Part VI to include in gross income the appropriate amount of subpart F income inclusion and/or section 951(a)(1)(B) inclusion, and to complete Form 8992.

For each CFC listed in column (a) of Schedule K-3, Part VI, of which you’re a U.S. shareholder, include the amounts of subpart F income and section 951(a)(1)(B) inclusion reported on Part VI in determining the amount you report on Form 1120, Schedule C, line 16; or Schedule 1 (Form 1040), line 8.

Note that, for corporate partners, in determining the amount you report on Form 1120, Schedule C, line 16, the section 951(a) (1)(B) inclusion amounts reported in Schedule K-3, Part VI, may be reduced under Regulations section 1.956-1(a)(2).

For each CFC listed in column (a) for which you’re a U.S. shareholder, report the tested income and tested loss for each CFC in columns (c) and (d), respectively, of Schedule A (Form 8992) and include your share of each CFC’s items described in columns (i) through (n) of Schedule K-3, Part VI, in determining the amount to report in columns (e) through (j), respectively, of Schedule A (Form 8992).