Schedule A-1. Certain Partners of Foreign Partnership

All Category 1 and certain Category 3 filers must complete Schedule A-1. Any person already listed on Schedule A isn’t required to be listed again on Schedule A-1.

Category 1 filers. Category 1 filers must list all U.S. persons who owned at least a 10% direct interest in the foreign partnership during the partnership’s tax year listed at the top of page 1 of Form 8865.

Category 3 filers. Category 3 filers must list:

• Each U.S. person that owned a 10% or greater direct interest in the foreign partnership during the Category 3 filer’s tax year, and

• Any other person related to the Category 3 filer that was a direct partner in the foreign partnership during that tax year.

See Regulations section 1.6038B-2(i)(4) for the definition of a “related person.”

Exception. Category 3 filers who only transferred cash and didn’t own a 10% or greater interest in the transferee partnership after the transfer aren’t required to complete Schedule A-1.