Section 1. General Information

Columns (a) through (c). Enter the name, U.S. EIN or reference ID number, and address of each PFIC held directly or indirectly by the partnership during its tax year. Don’t enter “FOREIGNUS” or “APPLIED FOR.”

For basic information about reference ID numbers (including the requirements as to the characters permitted), see the Instructions for Form 8621.

Columns (d) and (e). Enter the beginning and end of the PFIC’s tax year using the format YYYYMMDD.

Column (f). Enter each class of shares in the PFIC owned by the partnership using the following codes.

Codes for Classes of PFIC Shares

Code Class of PFIC Shares

COM Common or Ordinary Shares

PRE Preferred Shares

OTH Other Equity Interest

VAR Multiple Classes of Shares or Equity

Interests

Column (g). If the partnership acquired any PFIC shares during its tax year, provide the date(s) of acquisition of those shares using the format YYYYMMDD. If the partnership acquired no shares in a particular PFIC during its tax year, leave this column blank for that PFIC.

Reminder. If the partnership acquired shares in a PFIC on multiple dates during the tax year, append a completed Attachment 5 to Schedule K-2, Part VII, and its corresponding Schedules K-3, Part VII, providing those dates.

Column (h). Enter the total number of all classes of shares of the PFIC the partnership owned at the end of its tax year.

Column (i). Enter the total value of all shares in the PFIC held by the partnership at the end of the tax year. If the PFIC shares aren’t publicly traded, it is possible to rely upon periodic account statements provided at least annually to determine the value of a PFIC unless there is actual knowledge or reason to know based on readily accessible information that the statements don’t reflect a reasonable estimate of the PFIC’s value, and the information provides a more reasonable estimate of the PFIC’s value.

Note: A partner may need additional information not required to be reported on this Schedule K-2, Part VII (or the partner’s Schedule K-3, Part VII), from the partnership for the value of the PFIC shares as of a particular date to aid the partner in making certain elections under Regulations section 1.1291-10, 1.1297-3, or 1.1298-3.

Column (j). Check the box if the foreign corporation has indicated that it has documented eligibility to be treated as a QIC. See section 1297(f) and Regulations section 1.1297-4 for additional information on QICs.

Column (k). Check the box if the PFIC has indicated that its shares are "marketable stock" as defined in section 1296(e) and Regulations section 1.1296-2.

Column (l). Check the box if the PFIC also constitutes a CFC within the meaning of section 957 (PFIC/CFC).

Reminder. If the U.S. person filing the Form 8865 knows that all of the partnership’s direct and indirect partners that are U.S. persons (including itself) aren’t subject to the PFIC rules for a PFIC/CFC under section 1297(d) because they are subject to the subpart F rules for the corporation, it’s not required to complete Schedules K-2 and K-3, Part VII, for the PFIC/CFC.

Note: If the PFIC is a PFIC/CFC, a partner may need certain additional information for the PFIC/CFC’s E&P not required to be reported on this Schedule K-2, Part VII (or the partner’s Schedule K-3, Part VII), from the partnership to aid the partner in making certain elections under Regulations section 1.1291-9, 1.1297-3, or 1.1298-3.

Column (m). Complete column (m) in the following manner.

Attachment 5. Additional Information for Part VII, Section 1

Inst. for Schedules K-2 and K-3 (Form 8865) (2025) 21

Note: If the foreign corporation is a “former PFIC” within the meaning of Regulations section 1.1291-9(j)(2)(iv), a partner may need additional information not required to be reported on this Schedule K-2, Part VII (or the partner’s Schedule K-3, Part VII), from the partnership for the PFIC to aid the partner in making certain elections under Regulations section 1.1298-3.