Part IV—To Be Completed by the Partnership Required To Withhold Under Section 1446(f)(4)

Caution: File a separate Form 8288 for each distribution made to a transferee partner that is subject to the withholding requirements of section 1446(f)(4). Only attach the Form 8288-C applicable to the current distribution.

Line 16. Line 16 is used to report the cumulative number and amounts related to this distribution plus any prior distributions that you have made to a transferee that failed

Line 11b. Enter the amount subject to withholding multiplied by 15% (0.15).

Instructions for Form 8288 (Rev. 1-2026) 13

to properly withhold with respect to a transfer under section 1446(f)(1). These distributions are subject to withholding under section 1446(f)(4) and Regulations section 1.1446(f)-3.

Line 16a. Enter the total number of distributions, including this one, made to the transferee. This amount should equal the total number of Forms 8288-C that you filed, including this one, for the transferee with respect to the transfer.

Line 16b. Enter the total amount of distributions, including this one, made to the transferee. This amount should equal the total of the amounts in box 5 of the Form(s) 8288-C you have filed, including this one, for the transferee with respect to the transfer.

Line 16c. If any portion of a distribution, including this one, was subject to withholding under another provision of the Internal Revenue Code (such as section 1441 or 1442), enter the total amount of other withholding on these distributions. This amount should equal the total of the amount(s) in box 6 of the Form(s) 8288-C you have filed, including this one, for the transferee with respect to the transfer.

Line 17. If known, enter the total amount of the transferee’s liability under section 1446(f)(1), without regard to any withholding you performed under section 1446(f)(4). Generally, this amount will be 10% of the amount realized on the transfer.

Line 18. Enter the total amount of section 1446(f)(4) tax that you have withheld on the transferee with respect to this transfer. This should equal the total of the amounts in box 5 of the Form(s) 8288-C you have filed, including this one, for the transferee with respect to the transfer.

Example 3. On a transfer of an interest in Cherry Blossom Partnership, Brad (transferee) had a section 1446(f)(1) withholding obligation of $110, but failed to withhold any tax on the transfer or to provide a certification of withholding to the partnership. The partnership has actual knowledge of the transfer at the time that it occurred. For its first distribution following the date on which it is required to withhold under section 1446(f)(4), the partnership distributes $100 of income described in section 871(a) to Brad. The partnership is required to withhold $30 under section 1441 on the $100 distribution. The partnership must withhold the remaining $70 ($100 $30) from the distribution under section 1446(f)(4). Brad receives net $0 on the distribution. The partnership must file a Form 8288 and complete Part IV by entering “1” on line 16a; entering “$100” on line 16b; entering “$30” on line 16c; leaving line 17 blank since it has not received a certification of withholding from Brad; and entering “$70” on line 18. The partnership must also attach Copy A of Form 8288-C to its Form 8288 and send Copy B of Form 8288-C to Brad. The partnership should retain Copy C of Form 8288-C for its records.

The partnership must continue to withhold under section 1446(f)(4) on future distributions made to Brad until it can rely on a certification of withholding from Brad and it has withheld the required amount plus interest. For each distribution, it must file a Form 8288 and complete Part IV with the cumulative amounts related to all distributions the partnership has made to Brad. It must

also complete Form 8288-C with the amounts specific to this distribution.