Part I. Section — Instruction 8865 — Instructions for Form

Provide the requested information for each reportable section 721(c) property. See General Instructions under Schedule G, earlier, for the order in which properties must be listed and when an attached statement can and must be used. If there are more than four reportable section 721(c) properties, enter on line 4a the following information for the reportable section 721(c) properties listed on the attached statement.

In columns 6(a) through 6(c), provide the aggregate FMV, basis, and built-in gain, respectively, of the properties.
Check the boxes in columns 4, 5, and 7(a)–(e) if applicable to any of the properties.

Caution: Don’t complete line 4a if there are four or fewer reportable section 721(c) properties.

Note: Schedule O, Transfer of Property to a Foreign Partnership, may need to be completed if, during the tax year, the U.S. transferor contributed property (including section 721(c) property) to the partnership. See the Schedule O instructions, later.

Column 4. Section 197(f)(9) property. Check the box for the reportable section 721(c) property if the property is an intangible described in section 197(f)(9).

Column 5. Effectively connected income property. Check the box for the reportable section 721(c) property if (a) all distributive shares of income and gain with respect to the property for all direct and indirect partners that are related foreign persons for the U.S. transferor will be subject to taxation as income effectively connected with a trade or business within the United States (under section 871 or 882), and (b) neither the section 721(c) partnership nor a related foreign person that is a direct or indirect partner in the partnership claims benefits under an income tax convention that would exempt the income or gain from tax or reduce the rate of taxation to which the income or gain is subject. See Regulations sections 1.721(c)-3(b)(1) (ii) and 1.721(c)-6(c)(1).

Column 6(a). Fair market value. Enter the FMV of the reportable section 721(c) property, measured as of the date of contribution.

Column 6(b). Basis. Enter the adjusted tax basis of the reportable section 721(c) property on the date of the contribution. See sections 1011 through 1016 for more information for the determination of adjusted tax basis.

Column 7. Events. Check the box for each of columns 7(a) through 7(e) which describes an event that occurred during the tax year for the reportable section 721(c) property. If a box is checked for any reportable section 721(c) property listed, check “Yes” on the corresponding

line in Part V of Schedule G and complete Schedule H. See the Part V instructions below.