Section 3. Other Information for Preparation of

Form 8993

Line 13. Interest deduction. The term “interest” refers to the gross amount of interest expense incurred by a partnership in a given year. Generally, interest expense includes any expense that is currently deductible under section 163 (including original issue discount), and interest equivalents. See Regulations section 1.861-9(b) for the definition of interest equivalents and Temporary Regulations section 1.861-9T(c) for sections that disallow, suspend, or require the capitalization of interest deductions. Include excess business interest expense determined under section 163(j)(4) on this line. Under Regulations section 1.250(b)-1(d)(2)(ii), deductions are determined without regard to section 163(j).

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

Lines 13A and 13B. Interest expense specifically allocable under Regulations section 1.861-10(e) and Temporary Reg- ulations section 1.861-10T. Apart from interest expense entered on line 13A, enter on line 13B interest expense that is directly allocable under Temporary Regulations section 1.861-10T to income from specific partnership property. Such interest expense is treated as directly allocable to income generated by such partnership property. See Temporary Regulations section 1.861-9T(e)(1).

Line 13C. Enter all interest deductions not otherwise included on lines 13A and 13B.

Line 14. Interest expense apportionment factors. Report information that a partner will use to allocate and apportion its interest expense for FDII purposes.

Interest deductions are apportioned to gross DEI and FDDEI based ordinarily on the tax book value of the taxpayer’s assets. See Temporary Regulations section 1.861-9T(g)(1)(i). A taxpayer can use either the tax book value or the alternative tax book value of its assets. See Regulations section 1.861-9(i). Under both methods, the partner whose interest in the partnership is 10% or more uses the partnership’s inside basis in its assets, including adjustments required under sections 734(b) and 743(b). See Regulations sections 1.861-9(e)(2) and -9(e) (3). When reporting the basis in an asset which is stock in nonaffiliated 10%-owned corporations, adjust such amount for E&P. See Regulations section 1.861-12(c)(2)(i)(A).

The total interest expense deductions for the members of the corporation’s affiliated group are allocated and apportioned to the statutory and residual groupings under proposed, final, and Temporary Regulations sections 1.861-8 through -14.

Note: The Total column isn’t a sum of DEI and FDDEI but rather refers to the partnership’s specific line totals (that is, that would also include non-DEI).

Line 14A. Enter the amount of the average of the beginning-of-year and end-of-year inside bases in the partnership’s total assets. See Regulations section 1.861-9(g)(2) (i)(A).

Line 14B. Enter the amount of the average of the beginning-of-year and end-of-year inside bases adjustments under sections 734(b) and 743(b).

Lines 14C and 14D. Enter the amount of the reductions in the partnership’s asset values to reflect the partnership’s directly allocable interest under Regulations section 1.861-10(e) and Temporary Regulations section 1.861-10T. See also Temporary Regulations section 1.861-9T(e)(1).

Line 14E. Enter the amount of the average value of assets excluded from the apportionment formula. See section 864(e) (3).

Lines 15 and 16. R&E expenses apportionment factors. These lines require information that a partner will use to allocate and apportion its R&E expense for FDII purposes. Lines 15 and 16 aren’t required to be completed unless either (a) the partnership incurs R&E expense; or (b) the partner is expected to license, sell, or transfer its intangible property to the partnership (as provided in Regulations section 1.861-17(f)(3)).

R&E expenses deducted, or amortized and deducted, under section 174 are definitely related to all gross intangible income reasonably connected with relevant broad product categories of the taxpayer and are allocable to all items of gross intangible income as a class related to such product categories. The product categories are generally determined by reference to the three-digit SIC code. R&E expenses are apportioned between the statutory and residual groupings based on an analysis of the taxpayer’s gross receipts from certain sales, leases, licenses,

and services. See Regulations section 1.861-17. The exclusive apportionment rule in Regulations section 1.861-17(c) doesn’t apply for purposes of apportioning R&E expenses to gross DEI and gross FDDEI.

R&E expenses are allocated and apportioned by the partner. This requires the reporting to the partners of the gross receipts related to certain income within the statutory and residual groupings within a SIC code and the partner’s distributive share of the partnership’s R&E deductions, if any, connected with the SIC codes.

Line 15. Gross receipts by SIC code. Enter the gross receipts that resulted in gross income for each category shown on the form, DEI, FDDEI, and then total gross receipts. Note that the Total column isn’t a sum of DEI and FDDEI but refers to all the partnership’s gross receipts. Such gross receipts include both the partnership’s sales and certain other parties’ sales. See Regulations section 1.861-17(d). Gross receipts from certain transactions of parties both controlled or uncontrolled by the partnership may be included on line 15. See, generally, Regulations section 1.861-17(d).

Line 16. Enter the amount of R&E expense by SIC code.

Schedules K-2 and K-3, Part V (Distributions From Foreign Corporations to Partnership)

Note: The following information, in combination with other information known to the partners, including Schedule P (Form 5471), is relevant for certain partners to exclude from gross income distributions to the extent that they are attributable to PTEP in their annual PTEP accounts and report foreign currency gain or loss for the PTEP on Forms 1040 and 1120. If eligible, partners use this information for purposes of a dividends received deduction under section 245A on Form 1120.

Use Part V of the Schedule K-2 to report the distributions made by foreign corporations to the partnership.

Use Part V of the Schedule K-3 to report the partner’s share of the amounts reported in Part V of the Schedule K-2.

Exception. Part V of the Schedule K-2 isn’t required to be completed for distributions by a foreign corporation if the U.S. person filing Form 8865 knows that (a) none of the distributions by the foreign corporation are attributable to PTEP in annual PTEP accounts of any direct or indirect partner, and (b) none of the partnership’s direct or indirect partners are eligible to claim a deduction under section 245A for any distribution by the foreign corporation. Nevertheless, the filer may be required to append Attachment 3 to the Schedule K-2 (discussed below).

Exception. Part V of the Schedule K-3 for a partner doesn’t need to be completed for distributions by a foreign corporation if the filer of Form 8865 knows that (a) none of the distributions by the foreign corporation are attributable to PTEP in annual PTEP accounts of the partner or any U.S. person that is treated as indirectly owning stock of the foreign corporation through the partner (“relevant indirect partners”), and (b) the partner and relevant indirect partners aren’t eligible to claim a deduction under section 245A for any distributions by the foreign corporation. Nevertheless, the filer may be required to append Attachment 4 to the Schedule K-3 for the partner (discussed below). If this exception is applicable for a foreign corporation, the sum of the amounts reported in Part V of the Schedules K-3 for the foreign corporation may not equal the amounts reported in Part V of the Schedule K-2 for the foreign corporation.

Rows A–O. Use rows A–O to report information for each distribution by a foreign corporation for its stock that the partnership (directly or through pass-through entities) owns (within the meaning of section 958) other than solely by reason

Inst. for Schedules K-2 and K-3 (Form 8865) (2025) 17

of applying section 318(a)(3) (providing for downward attribution) as provided in section 958(b).

Each row should relate to the partnership’s direct ownership of stock in the foreign corporation or direct ownership of the ownership interests in a pass-through entity that (directly or through other pass-through entities) owns (within the meaning of section 958) stock in the foreign corporation other than solely by reason of applying section 318(a)(3) (providing for downward attribution) as provided in section 958(b). For example, if a partnership (upper-tier partnership) directly owns 50% of the foreign corporation’s stock and owns 50% of the foreign corporation’s stock through another partnership (lower-tier partnership), then distributions by the foreign corporation to each of the upper-tier partnership and the lower-tier partnership are to be reported on separate rows on the upper-tier partnership’s Part V (Form 8865). If the partnership owns stock of a foreign corporation through another partnership (lower-tier partnership)

Attachment 3 (Schedule K-2)

from which it receives a Part V of Schedule K-3 (Form 1065 or 8865), the partnership must replicate each line of the Part V of Schedule K-3 (Form 1065 or 8865) on its Part V (Form 8865). Rows for distributions for a partnership’s direct ownership of foreign corporation stock should be listed before rows for distributions for a partnership’s ownership of foreign corporation stock through a pass-through entity.

If the partnership received a Schedule K-3 from another partnership with an attachment related to net investment income PTEP (NII PTEP), append Attachment 3 to Schedule K-2 and Attachment 4 to each Schedule K-3 in the following format, adding additional rows as necessary for each distribution by a foreign corporation. For more information about net investment income and net investment income tax relating to CFCs and qualified electing funds (QEFs), see Regulations section 1.1411-10.

(a) Name of distributing foreign

corporation

(b) EIN or reference

ID number

(c) Date of

distribution

currency of distributing foreign

(d) Functional

corporation

(f) Spot rate (functional currency

to U.S. dollars)

(g) Amount of NII PTEP in U.S. dollars

(e) Amount of NII PTEP in functional

currency

Attachment 4 (Schedule K-3)

(a) Name of distributing foreign

corporation

(b) EIN or reference

ID number

(c) Date of

distribution

currency of distributing foreign

(d) Functional

corporation

(f) Spot rate (functional currency

to U.S. dollars)

(g) Partner’s share of

dollars

(e) Partner’s share of

NII PTEP in functional currency

NII PTEP in U.S.

Note: If additional rows are required, attach statements to Schedules K-2 and K-3 that look like the current version of Part V.

Column (b). Enter the EIN or reference ID number of the distributing foreign corporation. 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 1118.

Column (c). Enter the year, month, and day on which the distribution was made using the format YYYYMMDD.

Column (d). Enter the applicable three-character alphabet code for the foreign corporation’s functional currency using the ISO 4217 standard. These codes are available at iso.org/ iso-4217-currency-codes.html .

Note: Columns (e) and (f) are reported in functional currency.

Column (e). This represents the partnership’s share of the amount distributed in functional currency. See Schedule R (Form 5471), column (c).

Column (f). This represents the partnership’s share of the amount of E&P distributed in functional currency. See Schedule R (Form 5471), column (d). The total of the amounts reported in column (f) for a distributing foreign corporation should equal the partnership’s share of the total of the amounts reported on line 9, column (f), of Schedules J (Form 5471) on a separate category of income basis filed for the distributing foreign corporation, as reported on line 9, column (f), of the Schedule J (Form 5471) with code “TOTAL” entered on line a that is filed for the distributing foreign corporation. If a Schedule J

(Form 5471) with code “TOTAL” entered on line a isn’t filed for the distributing foreign corporation, then the total of the amounts reported in column (f) for a distributing foreign corporation should equal the partnership’s share of the amount reported on line 9, column (f), of the Schedule J (Form 5471) filed for the distributing foreign corporation.

Column (g). Enter the exchange rate on the date of distribution used to translate the amount of the distribution in functional currency to U.S. dollars. See section 989(b)(1). Report the exchange rate using the "divide-by convention" specified under Reporting exchange rates on Form 5471 in the Instructions for Form 5471.

Column (h). Enter the amount of the distribution in U.S. dollars. Translate column (e) using the spot rate reported in column (g).

Column (i). Enter the amount of E&P distributed in U.S. dollars. Translate column (f) using the spot rate reported in column (g).

Column (j). If the distributing foreign corporation is a qualified foreign corporation, determined without regard to section 1(h) (11)(C)(iii)(I), check the box. See section 1(h)(11)(C).

Schedules K-2 and K-3, Part VI (Information on Partners’ Section 951(a)(1) and Section 951A Inclusions)

Note: This information is relevant to partners completing Form 8992 and Forms 1040 and 1120 for income inclusions under section 951(a)(1)(A) (subpart F inclusions), section 951(a)(1)(B) inclusions, and section 951A inclusions.

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

Schedules K-2 and K-3, Part VI, must be completed for a CFC if the partnership owns (within the meaning of section 958) stock of the CFC, unless the partnership owns stock of the CFC solely by reason of applying section 318(a)(3) (providing for downward attribution) as provided in section 958(b).

Generally, a foreign corporation is a CFC if more than 50% of either the total combined voting power of all classes of stock entitled to vote or the total value of the stock of the corporation is owned (within the meaning of section 958(a)) or is considered as owned by applying the rules of section 958(b) by U.S. shareholders. For this purpose, a U.S. shareholder is a U.S. person (as defined in section 957(c)) who owns (within the meaning of section 958(a)), or is considered as owning by applying the rules of ownership of section 958(b), 10% or more of the total combined voting power of all classes of stock entitled to vote, or 10% or more of the total value of shares of all classes of stock of such foreign corporation.

Exception. Part VI of Schedule K-2 doesn’t need to be completed for a CFC if the partnership doesn’t have a direct or indirect partner (through pass-through entities only) that is a U.S. shareholder of the CFC required to include in gross income a subpart F income inclusion and/or section 951(a)(1)(B) inclusion for the CFC, or calculate section 951A inclusions by taking into account GILTI items (defined below) of the CFC.

Exception. Part VI of Schedule K-3 for a partner doesn’t need to be completed for a CFC if the filer of Form 8865 knows that (a) the partner isn’t a U.S. shareholder of the CFC required to include in gross income a subpart F income inclusion and/or a section 951(a)(1)(B) inclusion for the CFC, or figure section 951A inclusions by taking into account GILTI items (defined below) of the CFC; and (b) no U.S. person that indirectly owns (through pass-through entities only) an interest in the CFC through the partner is a U.S. shareholder of the CFC required to include in gross income a subpart F income inclusion and/or a section 951(a)(1)(B) inclusion for the CFC, or figure section 951A inclusions by taking into account GILTI items (defined below) of the CFC. If the filer doesn’t complete Part VI of Schedule K-3 for a partner for a CFC, the sum of each partner’s share of the CFC’s subpart F income, section 951(a)(1)(B) inclusion for the CFC, and share of the CFC’s GILTI items (defined below) reported on all Schedules K-3 may not equal the aggregate share of subpart F income of the CFC, the aggregate section 951(a)(1)(B) inclusion for the CFC, and the aggregate share of the CFC’s GILTI items (defined below), respectively, reported on the Schedule K-2.

Use Schedule K-2, Part VI, to report the information on the partnership’s share of the amounts its partners will need to figure their subpart F income inclusions, section 951(a)(1)(B) inclusions, and section 951A inclusions, for CFCs owned (within the meaning of section 958) by the partnership. Use Schedule K-3, Part VI, to report the partner’s share of the amounts needed to determine its subpart F income inclusions, section 951(a)(1)(B) inclusions, and section 951A inclusion, for CFCs owned (within the meaning of section 958) by the partnership.

The U.S. person completing Form 8865 must complete Part VI of Schedules K-2 and K-3 by assuming that each partner in the partnership is a U.S. shareholder of the CFC and is required to include in gross income its share of the CFC’s subpart F income, its section 951(a)(1)(B) inclusion, and its GILTI.

A partner’s GILTI is calculated based upon its share of the following amounts for each CFC for which it is a U.S. shareholder: tested income, tested loss, QBAI, tested loss QBAI amount, tested interest income, and tested interest expense (collectively, GILTI items) (a CFC’s subpart F income and GILTI items, CFC items).

A partner’s share of a CFC’s subpart F income, amounts used to determine its section 956 amount for a CFC, and a CFC’s

GILTI items may not be limited to the partner’s share of such income, amounts, or items through its ownership in the partnership. However, for purposes of completing Part VI of Schedules K-2 and K-3, use only the partner’s share of a CFC’s subpart F income, amounts used to determine its section 956 amount for a CFC, and a CFC’s GILTI items through the partner’s ownership in the partnership.

A partner’s share through its ownership in the partnership of subpart F income and GILTI items is generally anticipated to be calculated by multiplying the percentage in column (d) by the amount of subpart F income or GILTI item, respectively. For example, in general, a partner’s share through its ownership interest in the partnership of tested income in column (i) is anticipated to be calculated by multiplying the percentage in column (d) by the amount of tested income in column (g). If the partner’s share through its ownership in the partnership of subpart F income or GILTI items isn’t calculated by multiplying the percentage in column (d) by the amount of subpart F income or GILTI items, respectively (for example, because of special allocations), then, instead of entering a percentage in column (d) for that CFC, attach a statement to the Schedules K-2 and K-3 explaining the partner’s share through its ownership in the partnership of the CFC’s subpart F and GILTI items.

Line a. Complete a separate Part VI for each applicable separate category of income. However, all GILTI items must be reported on only one Part VI. If GILTI items include passive category income, report all GILTI items on the Part VI completed for passive category income; otherwise, report all GILTI items on the Part VI completed for general category income. Enter the appropriate code on line a.

Note: The other reporting requirements for reporting income by separate category don’t change by reason of reporting GILTI items that include general category income on a Part VI completed for passive category income.

Codes for Categories of Income

Code Category of Income

PAS Passive Category Income

901j Section 901(j) Income

GEN General Category Income

Line b. If any portion of a CFC item is U.S. source, complete a separate Part VI for U.S.-source CFC items, and check the box on line b on such separate Part VI.

Line 1. Use lines A through K to report information for CFCs owned (within the meaning of section 958) by the partnership, and for which Part VI of Schedules K-2 and K-3 must be completed. If the partnership owns a CFC through another partnership (lower-tier partnership) from which it receives a Schedule K-3 (Form 1065 or 8865), Part VI, replicate each line of the Schedule K-3 (Form 1065 or 8865), Part VI, that is related to the CFC on Schedule K-2 (Form 8865), Part VI. For example, if a partnership directly owns 50% of the CFC’s stock and owns 50% of the CFC’s stock through a lower-tier partnership, the CFC should be listed on two lines with one line related to the partnership’s direct ownership and the other line related to the partnership’s ownership through the lower-tier partnership. Lines related to a partnership’s direct ownership of CFCs should be listed before lines related to a partnership’s non-direct ownership of CFCs. If additional lines are required, attach to the Schedules K-2 and K-3 a schedule that looks like the current version of Part VI.

Column (a). Enter the name of each CFC for which Part VI must be completed.

Inst. for Schedules K-2 and K-3 (Form 8865) (2025) 19

Column (b). Enter the EIN or reference ID number of the CFC. 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 1118.

Column (c). Enter the end of the CFC’s tax year using the format YYYYMMDD.

Column (d). Enter the partners’ shares of CFC items through the partners’ ownership in the partnership (aggregate share). See Regulations sections 1.951-1(b), 1.951-1(e), and 1.951A-1(d)(1) for rules on determining the partners’ shares.

Column (e). Enter the aggregate share of the amount of the CFC’s subpart F income, if any. Note that an amount determined under section 956(a) isn’t considered subpart F income. For guidance on computing a CFC’s subpart F income and the partners’ shares of a CFC’s subpart F income, see Worksheet A in the Instructions for Form 5471.

Column (f). Enter the amount determined under section 956 for the partners that relates to those partners’ ownership in the partnership, as described in these instructions for column (f) (aggregate section 951(a)(1)(B) inclusion). In determining the section 956 amount, use only the partners’ share through their ownership in the partnership of:

• The average of the amounts of U.S. property held (directly or indirectly) by the CFC as of the close of each quarter of the CFC’s tax year, and

• The applicable earnings of the CFC. Don’t reduce the amount reported in column (f) for any reduction to the partners’ section 956 amount under Regulations section 1.956-1(a)(2). For guidance on computing the partners’ share of a CFC’s earnings invested in U.S. property, see Worksheet B in the Instructions for Form 5471.

Column (g). Enter the CFC’s tested income, if any, from line 6 of Schedule I-1 (Form 5471) for each CFC.

Column (h). Enter the CFC’s tested loss, if any, from line 6 of Schedule I-1 (Form 5471) for each CFC.

Column (i). Enter the aggregate share of the tested income listed in column (g) for each CFC with tested income.

Column (j). Enter the aggregate share of the tested loss listed in column (h) for each CFC with tested loss.

Column (k). If the CFC has a tested loss in column (h), enter zero. If the CFC has tested income in column (g), enter the aggregate share of QBAI. A CFC’s QBAI is reported on Schedule I-1 (Form 5471), line 8.

Column (l). If the CFC has tested income in column (g), enter zero. If the CFC has a tested loss in column (h), enter the aggregate share of the CFC’s tested loss QBAI amount. See Regulations section 1.951A-4(b)(1)(iv). A CFC’s tested loss QBAI amount is reported on Schedule I-1 (Form 5471), line 9c, which must be translated to U.S. dollars.

Column (m). Enter the aggregate share of the CFC’s tested interest income. A CFC’s tested interest income is reported on Schedule I-1 (Form 5471), line 10c.

Column (n). Enter the aggregate share of the CFC’s tested interest expense. A CFC’s tested interest expense is reported on Schedule I-1 (Form 5471), line 9d.

Schedules K-2 and K-3, Part VII (Information Regarding Passive Foreign Investment Companies (PFICs))

Note: This information is relevant to partners completing Form 8621 and/or that determine income inclusions for the PFICs reported on Schedule K-2, Part VII; and Schedule K-3, Part VII.

Except as otherwise provided, Schedules K-2 and K-3, Part VII, must be filed for every partnership that owns PFIC stock directly or indirectly. However, the following exceptions apply.

• The U.S. person filing the Form 8865 isn’t required to complete Schedules K-2 and K-3, Part VII, for a foreign corporation if the U.S. person knows that all of the foreign partnership’s direct and indirect partners that are U.S. persons (including itself) are either (a) not subject to the PFIC rules for the foreign corporation under section 1297(d) because they are subject to the subpart F rules for the foreign corporation, (b) tax-exempt entities that aren’t subject to the PFIC rules for the corporation under Regulations section 1.1291-1(e), or (c) pass-through entities with no direct or indirect U.S. taxable partners.

• The U.S. person filing the Form 8865 isn’t required to complete Schedules K-2 and K-3, Part VII, for a foreign corporation (i) if the U.S. person knows that the foreign corporation is treated as a qualifying insurance corporation (QIC) (as defined in section 1297(f)(1)) that isn’t treated as a PFIC by reason of section 1298(b)(1), or (ii) the U.S. person filing the Form 8865 satisfies the deemed election requirements of Regulations section 1.1297-4(d)(5)(iv) with respect to a foreign corporation eligible to be treated as a QIC (and that isn’t treated as a PFIC by reason of section 1298(b)(1)).

• The U.S. person filing the Form 8865 isn’t required to complete Schedules K-2 and K-3, Part VII, for a PFIC the stock of which has been marked to market as described in Regulations section 1.1291-1(c)(4). Instead, the U.S. person filing the Form 8865 should report the partnership’s mark-to-market (MTM) gain or loss on Schedule K (if required), and report the partners’ shares of those amounts in Part III of Schedule K-1 (if required). Note, however, there may be instances in which the U.S. person filing the Form 8865 will need additional information for the PFIC the stock of which has been marked to market as described in Regulations section 1.1291-1(c)(4) to meet its tax obligations, such as when the section 1291 rules apply to the U.S. person filing the Form 8865 because the stock wasn’t marked to market in the first year of its holding period. In such instances, the U.S. person filing the Form 8865 may use Part VII to report the needed information.

Use Schedule K-2, Part VII, to report certain information for any PFIC owned, directly or indirectly, by the partnership for which reporting is required, including PFICs for which no QEF or section 1296 MTM election has been made and unpedigreed QEFs (section 1291 funds), and PFICs for which pedigreed QEF, section 1296 MTM, or other elections have been, or may be, made.

The U.S. person filing the Form 8865 must also use Schedule K-2, Part VII, to report information for any PFIC for which the U.S. person is making an MTM election under section 1296 in the current tax year if the current tax year isn’t the first year of the U.S. person’s holding period in the stock (“non-initial section 1296 MTM election”). See section 1296(j)(1)(A) and Regulations section 1.1296-1(i) for more information.

Use Schedule K-3, Part VII, to report the partner’s share, through its ownership in the partnership, of the amounts reported on Schedule K-2, Part VII.

Complete only one line on both Sections 1 and 2 for each PFIC for which reporting on Schedules K-2 and K-3, Part VII, is

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

required. Each line completed for a PFIC in Section 1 should correspond to the same line on Section 2. If there is no information to report for a PFIC in Section 2, columns (c) through (o), only complete the name and EIN of the PFIC in Section 2, columns (a) and (b), and leave columns (c) through (o) blank for that PFIC. For additional information on determining indirect ownership of PFICs, see Regulations section 1.1291-1(b)(8).

The partnership may have additional required information for a PFIC for certain columns (for example, scenarios where the partnership may have multiple different events for the PFIC in the same tax year, such as multiple dates of acquisitions of, or distributions for, the PFIC stock). In that case, complete Schedules K-2, and K-3, Part VII, with the first of those entries for a PFIC and attach a statement including the remaining entries for each of those PFICs to Schedule K-2, Part VII, and its corresponding Schedules K-3, Part VII, with Attachments 5 and/or 6 completed.

If the partnership has additional PFICs for which to report information that don’t fit on single Schedules K-2 and K-3, Part VII, attach additional Parts VII of Schedules K-2 and K-3 as needed.