Part VII. Information Regarding Passive Foreign Investment Companies (PFICs)

U.S. persons may be required to complete and file Form 8621 and/or include amounts in income with respect to PFICs owned through a partnership. This includes PFICs with respect to which no qualified electing fund (QEF) or section 1296 mark-to-market (MTM) election has been made and unpedigreed QEFs (section 1291 funds), as well as PFICs with respect to which a pedigreed QEF, a section 1296 MTM, or other election has been, or may be, made. For information regarding the requirement to file Form 8621, as well as certain filing exceptions, see Regulations section 1.1298-1 and the Form 8621 instructions.

Use the information provided in this Schedule K-3, Part VII (including any supplemental attachments (Table 6 or 7, from the Partnership Instructions for Schedules K-2 and K-3 (Form 1065), if applicable)), as instructed below, to complete Form 8621 with respect to each PFIC for which you have a filing obligation. Additionally, for any PFIC that you own through your interest in the partnership, use the information provided in this Schedule K-3, Part VII (including any supplemental attachments (Table 6 or 7, from the Partnership Instructions for Schedules K-2 and K-3 (Form 1065), if applicable)), to determine your income inclusion with respect to the PFIC (if any) and complete your U.S. federal income tax return.

If a PFIC reported on this Schedule K-3 also constitutes a CFC within the meaning of section 957 (PFIC/CFC) and you’re a U.S. shareholder (within the meaning of section 951(b)) with respect to that PFIC/CFC, the information on this schedule with respect to that PFIC/CFC may not be relevant to you. The box in Section 1, column (m), will be checked if the PFIC also constitutes a CFC. See section 1297(d) for additional information.

Section 1—General Information

Columns (a) through (e). General information. If you’re required to complete Form 8621 with respect to a PFIC reported on this schedule, use this information to complete the Form 8621 background information.

Columns (f) through (i). Summary of annual information. If you’re required to complete Form 8621 with respect to a PFIC reported on this schedule, enter this information on Form 8621, Part I, lines 1 through 4.

Note: If you’re making an election under Regulations section 1.1291-10, 1.1297-3, or 1.1298-3 with respect to a PFIC reported on this Schedule K-3, Part VII, you may need additional information from the partnership regarding the value of the PFIC shares reported in column (i) that isn’t reported here.

Column (j). Election made by partnership. If the partnership is a domestic partnership, this column will indicate to you (using the codes below) whether the partnership has made an election with respect to the PFIC which binds the partners. If the partnership is a foreign partnership, no code will be entered in this column; however, if certain information with respect to the PFIC is provided, you may be able to make certain elections with respect to the PFIC on Form 8621.

Partnership Election Codes for Column (j)

Note: In general, if the partnership is a domestic partnership and has made a pedigreed QEF or section 1296 MTM election with respect to a PFIC, the partnership isn’t required to complete Schedule K-3, Part VII, with respect to that PFIC if the partnership files Form 8621 for that PFIC. In that case, you may not be required to file Form 8621 with respect to that PFIC and income inclusions with respect to the PFIC, if any, will be figured by the partnership and reported to you on Schedule K-1, Part III. However, if the partnership is a domestic partnership that has made a pedigreed QEF or section 1296 MTM election with respect to a PFIC for which the partnership doesn’t file Form 8621, if the partnership owns stock of an unpedigreed QEF, or if the partnership is making a section 1296 MTM election with respect to stock in a PFIC in the current tax year if the current tax year isn’t the first year of the partnership’s holding period in the stock (non-initial section 1296 MTM election), it’s required to complete Schedule K-3, Part VII, with that PFIC’s information, and you may be required to file Form 8621 with respect to that PFIC. See Regulations section 1.1298-1(b)(2) and the Form 8621 instructions for additional information. Additionally, if the partnership marks to market stock of a PFIC as described in Regulations section 1.1291-1(c)(4), the partnership generally doesn’t need to report information about the PFIC in Schedules K-2 and K-3, Part VII. In such a case, the partnership should report its MTM gain or loss on Schedule K and report your share of those amounts in Schedule K-1, Part III. Note, however, in such a case there may be instances in which you’ll need additional information from the partnership to meet your tax obligations with respect to a PFIC for which the partnership has marked to market the stock as described in Regulations section 1.1291-1(c)(4), such as when the section 1291 rules apply to you because the stock wasn’t marked by the partnership in the first year of its holding period. In such instances, the partnership should provide you with the needed information and may use Schedule K-3, Part VII, to do so.

Columns (k) through (n). Information regarding elections. Use the information provided in these columns to make certain elections with respect to a PFIC on Form 8621, Part II. If you don’t intend to make any election with respect to a PFIC reported on this Schedule K-3, Part VII, you may generally ignore these boxes for that PFIC.

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Note: If you’re making an election under Regulations section 1.1291-9, 1.1297-3, or 1.1298-3 with respect to a PFIC/CFC, or a PFIC that is a former PFIC within the meaning of Regulations section 1.1291-9(j)(2)(iv), you may need additional information from the partnership that isn’t reported on this Schedule K-3, Part VII, including information with respect to the PFIC’s E&P.

Section 2—Additional Information on PFIC or Qualified Electing Fund (QEF)

Note: The partnership will complete Section 2 with respect to each PFIC reported in Section 1, and each line completed with respect to a PFIC in Section 1 corresponds to the same line in Section 2. If the PFIC has no current year activity or has no other information for the partnership to report in columns (c) through (o), the partnership will only include the name and employer identification number (EIN) or reference ID number of the PFIC in columns (a) and (b) and will leave columns (c) through (o) blank with respect to that PFIC.

QEF Information

Columns (c) and (d). Partner’s share of ordinary earnings and of net capital gain. This information is to assist you in determining your income inclusions from certain PFICs with respect to which a QEF election has been, or may be, made.

If the partnership is a domestic partnership that has made a pedigreed QEF election with respect to a PFIC, and the domestic partnership files Form 8621 for that PFIC, that PFIC will typically not be reported in Schedule K-3, Part VII. In that case, your share of the domestic partnership’s QEF inclusions, if any, will be reported to you in Schedule K-1, Part III. However, in the event the domestic partnership doesn’t file Form 8621 for a PFIC for which the domestic partnership has made a pedigreed QEF election, or if the domestic partnership owns stock of an unpedigreed QEF, you may be required to file Form 8621 for that PFIC. See Regulations section 1.1298-1(b)(2) for additional information.

If you’re required to file Form 8621 for a PFIC reported in Schedule K-3, Part VII, enter the amounts from columns (c) and (d) on Form 8621, Part III, lines 6a and 7a, respectively, and include these amounts in gross income on your U.S. federal income tax return unless you’re making an election under section 1294 with respect to the QEF for the current tax year. If you’re making a section 1294 election with respect to the QEF for the current tax year, use the rest of Form 8621, Part III, lines 8 and 9, to determine the amount of deferred tax with respect to the QEF for the current tax year.

Note: If your interest in the partnership constitutes an applicable partnership interest within the meaning of section 1061(c) or the regulations thereunder, you may need additional information not reported on this Schedule K-3 from the QEF with respect to its computation of its net capital gain (as defined in Regulations section 1.1293-1(a)(2)) to perform certain computations under section 1061 or the regulations thereunder. The partnership may aid you in obtaining the information from the QEF, though the QEF isn’t required to provide it. See section 1061 and Regulations sections 1.1061-4 and -6 for more information.

Section 1296 Mark-to-Market Information

Columns (e) and (f). FMV of PFIC shares at beginning and end of tax year. This information is to assist you in determining your gain or loss from certain PFICs with respect to which an MTM election under section 1296 has been, or may be, made (MTM PFIC), including PFICs with respect to which the partnership is making a non-initial section 1296 MTM election.

If the partnership is a domestic partnership and has made an MTM election under section 1296 with respect to a PFIC (other than a non-initial section 1296 MTM election), and the domestic partnership files Form 8621 for that MTM PFIC, that MTM PFIC will typically not be reported in Schedule K-3, Part VII. In that case, your share of the domestic partnership’s MTM gain or loss, if any, will be reported to you in Schedule K-1, Part III. However, in the event the domestic partnership doesn’t file Form 8621 for an MTM PFIC or if the domestic partnership is making a non-initial section 1296 MTM election with respect to a PFIC, you may have a reporting obligation for that PFIC. See Regulations section 1.1298-1(b)(2) for additional information. A partnership is also not required to complete Schedule K-3, Part VII, with respect to a PFIC if it has marked stock of a PFIC to market as described in Regulations section 1.1291-1(c)(4), though it may provide you with certain information in Schedule K-3, Part VII, if the PFIC stock isn’t marked to market in the first year of the partnership’s holding period.

If you’re required to file Form 8621 with respect to an MTM PFIC reported in Schedule K-3, Part VII, enter the amount from column (f) on Form 8621, Part IV, line 10a. You may need additional information from the partnership regarding your share of its adjusted tax basis in the MTM PFIC stock to complete the rest of Form 8621, Part IV. Your share of the partnership’s adjusted tax basis in the MTM PFIC stock may be equal to your share of the fair market value (FMV) of the stock at the beginning of the prior tax year reported in column (e) of Schedule K-3, Part VII, Section 2. However, your share of the partnership’s adjusted tax basis in the MTM PFIC stock may not be equal to the FMV of the stock at the beginning of the prior tax year, depending on the amounts of prior year income inclusions and the amounts allowed a deduction with respect to the MTM PFIC. Once you determine your share of the partnership’s adjusted tax basis in the MTM PFIC shares, enter this amount on Form 8621, Part IV, line 10b, and use the rest of Form 8621, Part IV, lines 10c through 12, to determine your MTM gain or loss to include on your U.S. federal income tax return.

Additionally, if the partnership is a domestic partnership and is making a non-initial section 1296 MTM election with respect to a PFIC, you should use the information for that PFIC from columns (g) through (o) of Schedule K-3, Part VII, Section 2, and the corresponding instructions described below to determine whether you have received an excess distribution with respect to the PFIC stock, or whether your distributive share of the domestic partnership’s section 1296(a) gain for the tax year (if any) is treated as an excess distribution. This will help you determine any corresponding additions to tax and interest charges under section 1291. For special rules related to RICs that are shareholders of PFICs with respect to which a non-initial section 1296 MTM election has been made, see Regulations section 1.1296-1(i)(3).

Section 1291 and Other Information

Generally, this information is to assist you in satisfying any information reporting obligations for, and in figuring income inclusions with respect to, section 1291 funds. However, except as otherwise provided, this information may be relevant to PFICs with respect to which a pedigreed QEF election, a section 1296 MTM election (including a non-initial section 1296 MTM election), or other election has been made by you or the partnership.

Column (g). Dates PFIC shares were acquired. This information is provided to help you assess your holding period in the PFIC stock through your ownership in the partnership. Unless also provided in column (g) of Section 1, with respect to an acquisition of stock in the PFIC during the partnership’s tax

14 Partner's Instructions for Schedule K-3 (Form 1065) (2025)

year, these dates don’t need to be entered on Form 8621 or on your U.S. federal income tax return.

Note: The dates entered in this column (g) will be the dates the partnership acquired the PFIC stock. If you acquired your partnership interest after the date listed with respect to a PFIC, you may have a different holding period with respect to the PFIC stock.

Column (h). Amount of cash and FMV of property distrib- uted by PFIC during the current tax year. Your share of the amount of cash and FMV of property distributed by the PFIC during the tax year may be reported on different parts of Form 8621, or not reported at all on Form 8621.

Note: Deemed distributions by QEFs aren’t reported in Schedule K-3, Part VII. If you make, or have made, an election under section 1294 and are deemed to have received a distribution from the QEF, this information is required to complete Form 8621, Parts III and VI. See section 1294(f) and Temporary Regulations section 1.1294-1T for additional information.

Note: If you have made a section 1294 election with respect to a QEF owned by the partnership, a distribution of earnings by the QEF will terminate the section 1294 election to the extent the election is attributable to the earnings distributed. In such a case, enter the amount of the distribution on Form 8621, Part VI, line 22. See Temporary Regulations section 1.1294-1T(e) and the Form 8621, Part VI, instructions for additional information.

Column (i). Dates of distribution. This information is to help you assess any information related to the date of a distribution from a PFIC. You don’t need to enter these dates on Form 8621 or on your U.S. federal income tax return.

Column (j). Total creditable foreign taxes attributable to distribution by PFIC. This information is to help you assess any available foreign tax credit attributable to an excess distribution from a section 1291 fund or PFIC with respect to which the partnership is making a non-initial section 1296 MTM election in which you’re a shareholder through your ownership in the partnership. If you’re required to file Form 8621 with respect to one of these types of PFICs owned by the partnership, use this amount to determine your foreign tax credit to include on Form 8621, Part V, line 16d. See section 1291(g) for additional information on creditable foreign taxes.

Note: Your share of foreign taxes in column (j) of Schedule K-3, Part VII, Section 2, includes only foreign taxes within the

meaning of section 1291(g) and doesn’t include taxes attributable to QEF inclusions under section 1293. If you’re a corporate shareholder of a QEF that meets the ownership requirements of section 1293(f)(3), use Part VIII to determine your deemed paid foreign tax credit under section 960, including with respect to inclusions under section 1293(f).

Column (k). Total distributions from PFIC in preceding 3 tax years. This information is to help you assess your excess distribution and resulting other income, additional tax, and interest charge with respect to each section 1291 fund in which you’re a shareholder through your ownership in the partnership or with respect to a PFIC for which the partnership is making a non-initial section 1296 MTM election. If you’re required to file Form 8621 with respect to one of these types of PFICs owned by the partnership, use this amount to determine the amount to include on Form 8621, Part V, line 15b, and use the rest of Form 8621, Part V, lines 15 and 16, to determine the amount of any excess distribution and resulting other income, additional tax, and interest charge to include on your U.S. federal income tax return with respect to the section 1291 fund.

Note: The information in column (k) of Schedule K-3, Part VII, Section 2, is only relevant with respect to section 1291 funds and PFICs with respect to which the partnership is making a non-initial section 1296 MTM election and isn’t relevant for any PFIC with respect to which a pedigreed QEF election or other section 1296 MTM election has been, or may be, made.

Column (l). Dates PFIC shares disposed of during tax year. This information is provided to help you assess the treatment to you on any disposition by the partnership of stock in a PFIC in combination with column (g). These dates don’t need to be entered on Form 8621.

Note: Your holding period of the PFIC stock may have begun on a different date than the partnership’s holding period.

Columns (m) through (o). This information is to assist you in figuring any gain or loss on the partnership’s disposition of PFIC stock.

For each section 1291 fund in which you’re a shareholder through your ownership in the partnership or with respect to any PFIC for which the partnership is making a non-initial section 1296 MTM election for which you’re required to file Form 8621, enter the amount from column (o) of Schedule K-3, Part VII, Section 2, on Form 8621, Part V, line 15f, and use the rest of Form 8621, Part V, line 16, to determine the amount of any resulting other income, additional tax, and interest charge to include on your U.S. federal income tax return with respect to the PFIC. Your adjusted tax basis in the PFIC shares as reported by the partnership should reflect any adjustments in the partnership’s shares in the PFIC that are specific to you; you may also need to make corresponding adjustments to your basis in your partnership interest.

For each MTM PFIC (including a PFIC with respect to which a domestic partnership is making a non-initial section 1296 MTM election) in which you’re a shareholder through your ownership in the partnership, and with respect to which you’re required to file Form 8621, enter the amounts from columns (m) and (n) of Schedule K-3, Part VII, Section 2, on Form 8621, Part IV, lines 13a and 13b, respectively. Complete the rest of Form 8621, Part IV, lines 13 and 14, to determine your MTM gain or loss to include on your U.S. federal income tax return. Your basis in the MTM PFIC shares as reported by the partnership should reflect adjustments made by the partnership with respect to the MTM PFIC, as well as any other partner-specific adjustments such as section 743(b) adjustments; you may also need to make corresponding adjustments to your basis in your partnership interest. See section 1296(b)(2) for additional information on adjustments to basis in MTM PFIC shares held by foreign

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partnerships with respect to section 1296 income inclusions and deductions.

For each QEF in which you’re a shareholder through your ownership in the partnership with respect to which you have previously made a section 1294 election, and for which you’re required to file Form 8621, if amounts are reported in columns (m) through (o) of Schedule K-3, Part VII, Section 2, with respect to the QEF, the disposition may have partially or completely terminated your election, and you may need to complete Form 8621, Part VI, lines 21 through 24. See Temporary Regulations section 1.1294-1T and the Form 8621 instructions for additional information.

Note: If you have made a QEF election with respect to a PFIC which you own indirectly through the partnership, you may be required to adjust your share of the tax basis in the PFIC shares as reported by the partnership, and thus your gain or loss reported in column (o), by cumulative QEF inclusions and distributions made by the QEF; your basis in your partnership interest may need to be similarly adjusted. See section 1293(d) for more information on basis adjustments with respect to QEFs.