Section 1. Applicable Taxpayer

Lines 1a through 4a. Enter the partnership’s total gross receipts for the current year and each of the 3 preceding tax years. The determination of the partnership’s gross receipts is made in accordance with Temporary Regulations section 1.448-1T(f)(2)(iv).

Lines 1b through 4b. Complete lines 1b through 4b if the partnership has a foreign partner or there is reason to know it has a foreign partner through a partner that is a pass-through entity. Enter the partnership’s total gross receipts on income effectively connected with a U.S. trade or business (ECI) for the current year and each of the 3 preceding tax years which the foreign partner(s) would take into account as income that is ECI. If the foreign partner(s) is subject to tax on a net basis pursuant to an applicable income tax treaty of the United States, enter the gross receipts that would be attributable to transactions taken into account in determining its net taxable income.

Lines 1c through 4c. Complete lines 1c through 4c if the partnership has a foreign partner or has reason to know it has a foreign partner through a partner that is a pass-through entity. Enter the total non-ECI gross receipts as the difference between column (a) and column (b).

Schedule K-3. For purposes of section 59A, each partner in a partnership includes on its Schedule K-3, Part VIII, the share of partnership gross receipts in proportion to the partner’s distributive share (as determined under sections 704(b) and (c)) of items of gross income that were taken into account by the partnership under section 703 or 704(c) (such as remedial or curative items under Regulations section 1.704-3(c) or (d)).

Line 5. Amounts included in the denominator of the base erosion percentage as described in Regulations section 1.59A-2(e)(3). Enter the amount of deductions and other items allocated to the partners from the partnership that will be included in the denominator of the partners’ base erosion percentage. For a description of deductions that aren’t included in the denominator, see Regulations section 1.59-2(e)(3)(ii).