Part I. Transfers Reportable Under Section

6038B Part I is used to report the transfer of property to a foreign partnership in accordance with Regulations section 1.6038B-2(c). The completion of Part l (related property transferred to the partnership) is required by Regulations section 1.6038B-2(c). Provide the information required in columns (a) through (g) for each contribution of property to the foreign partnership that must be reported. If you contributed property with an FMV greater than its tax basis (appreciated property), or intangible property, provide the information required in columns (a) through (g) separately for each item of property transferred (except to the extent you are allowed to aggregate the property under Regulations sections 1.704-3(e)(2), (3), and (4)).

Provide a general description of each item of property in the Supplemental Information Required To Be Reported section. For all other property contributed, aggregate by the categories listed in Part I.

Column (a). Enter the date of the transfer. If the transfer was composed of a series of transactions over multiple dates, enter the date the transfer was completed.

Column (b). Enter the description of the property transferred.

Column (c). Enter the FMV of the property contributed (measured as of the date of the transfer).

Column (d). Enter your adjusted basis in the property contributed on the date of the transfer. See sections 1011 through 1016 for more information on the determination of adjusted basis.

Column (f). If you contributed appreciated property, enter the method (traditional, traditional with curative allocations, or remedial) used by the partnership to make section 704(c) allocations for each item of property. See Regulations sections 1.704-3(b), (c), and (d) for more information on these allocation methods. If the gain deferral method is applied, the remedial method must generally be used. See Regulations section 1.721(c)-3(b) (1)(i). For an exception for certain property generating effectively connected income, see Regulations section 1.721(c)-3(b)(1)(ii).

• Copy of “Statement of Waiver of Treaty Benefits under Section 1.721(c)-6,” if applicable. See Regulations section 1.721(c)-6(c)(1).

Annual Reporting With Respect to the Gain Deferral Method

A U.S. transferor subject to the gain deferral method must annually attach Schedule G (Form 8865), containing the information required in Regulations sections 1.721(c)-6(b) (3)(i) through (vii) (and (b)(3)(ix), as applicable). See Regulations section 1.721(c)-6(b)(3) for further annual reporting requirements pursuant to the gain deferral method.