2025›Instructions for Form 8865
Schedule A-2. Foreign Partners of Section 721(c) Partnership
Instruction 8865 — Instructions for Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships · 2026-10-03 edition · updated 2026-10-04 · United States
Schedule A-2 must be completed if (1) item H6 is answered “Yes” (that the partnership is a section 721(c) partnership); and (2) during the current tax year, a gain deferral contribution occurred, or (3) a gain deferral contribution occurred in a prior tax year (including before 2021) and, during the current tax year, the gain deferral method is applied to section 721(c) property contributed in the prior gain deferral contribution. See Section 721(c) partnership , Gain deferral contribution , and Gain deferral method , earlier.
Country of organization. Enter the 2-letter country code for the country of organization for any foreign partner, other than an individual. See country codes on IRS.gov/ CountryCodes .
Check if related to U.S. transferor. Check the box if the partner is directly or indirectly related to the U.S. transferor (within the meaning of section 267(b) or 707(b)(1)) and isn’t a U.S. person.
Percentage interest. Include the foreign partner’s percentage of interest in the partnership’s capital and profits immediately after the gain deferral contribution. If multiple gain deferral contributions occurred during the tax year, enter the percentages immediately after the last gain deferral contribution. See Gain deferral contribution , earlier.
10 Instructions for Form 8865 (2025)
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