Part III. Allocation Percentages of 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
Items With Respect to Section 721(c) Property For each reportable section 721(c) property, enter the percentage of income, gain, deduction, and loss allocated to the U.S. transferor, related domestic partners, and related foreign partners. See General Instructions under Schedule G, earlier, for the order in which properties must be listed and when an attached statement can and must
12 Instructions for Form 8865 (2025)
be used. See section 267(b) or 707(b)(1) for rules on determining related partners, and see Regulations section 1.721(c)-3(c) for a rule requiring that the partnership apply the consistent allocation method when the gain deferral method applies.
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