Schedule A. Constructive Ownership of Partnership Interest

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

All filers must complete Schedule A. Check box a if the person filing the return owns a direct interest in the foreign partnership. Check box b if the person filing the return constructively owns an interest in the foreign partnership. See Constructive ownership, earlier.

Category 1 and 2 filers. Category 1 and 2 filers must list the persons (U.S. and foreign) whose interests in the foreign partnership they constructively owned during the partnership’s tax year.

Category 3 filers. Category 3 filers must list the persons (U.S. and foreign) whose interests in the foreign partnership they constructively owned during the filer’s tax year that the reportable transfer occurred. See Schedule A-2, later.

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▸Contents — Instruction 8865 — Instructions for Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships

Instruction 8865 — Instructions for Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships

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