Part V. Additional Information

Part V provides questions relating to whether certain events have occurred in the current tax year for one or more reportable section 721(c) properties and information relating to treaty benefits. Such events include:

• Acceleration events (see Regulations section 1.721(c)-4),

• Partial acceleration events (see Regulations section 1.721(c)-5(d)),

• Termination events (see Regulations section 1.721(c)-5(b)),

• Successor events involving a successor partnership or U.S. transferor (see Regulations section 1.721(c)-5(c)),

• Taxable disposition of a portion of an interest in a partnership (see Regulations section 1.721(c)-5(f)), and

• Direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (see Regulations section 1.721(c)-5(e)).

Lines 1 through 6b. If the answer is “Yes” to any of the questions on lines 1 through 6b of Part V, also complete and attach Schedule H (Form 8865). See the separate instructions later for Schedule H. In addition, the corresponding checkboxes in Part I, columns 7(a) through 7(e), should be marked, as applicable.

Line 7a. If the answer is “Yes,” attach to Form 8865 a copy of the waiver of treaty benefits for the reportable section 721(c) property. See Regulations sections 1.721(c)-6(b)(2)(iii) and 1.721(c)-6(c).