Part IX – Other — Publication 5346

Under applicable regulations, a partnership may request a modification not otherwise described in other parts of the Form 8980 and instructions, and the IRS will consider such request and determine whether such modification is accurate and appropriate. For each partner listed in this section:

Attach a statement that describes, in detail, the requested modification.
Include in columns 3 through 6, the partner’s adjustment allocations that are relevant to the modification requested.
If this section is being completed for a source partnership’s closing agreement:
- Enter the source partnership’s name and TIN in columns 1 and 2; and
- Enter all relevant adjustment allocations in columns 3 through 6 that were included in the partnership’s closing agreement.

Make sure the relevant modifcation type is checked in Item B, otherwise the felds in this part will not be unlocked for completion. Once the relevant box in Item B is checked, you will be able to complete this part.

A. Total number of relevant partners included under this modification request . Enter the total number of relevant partners included under this modification request. This is a required feld when this type of modification is requested . When the number of partners is entered, the form will populate with the appropriate number of lines needed for completion.

Columns (1) and (2): Name of Partner & TIN of Partner . Both column 1 and column 2 are required fields for each relevant partner . List the name and Taxpayer Identification Number (TIN) of each direct or indirect partner for which the partnership is requesting modification under this section. Both Columns 1 and 2 are required felds .

Columns (3) through (6) : At least one entry in columns 3 through 6 must be entered for each partner listed.

Column (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only) . Enter in the appropriate subcolumn of column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive share of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. Do not include adjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information provided on Form 8980, Item C for such adjustments. Allocations of net negative adjustments resulting after subgroupings within the Reallocation and Residual grouping should be included in column 6.

Column (4): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only) . Enter in the appropriate subcolumn of column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive share of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. This includes decreases to creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs)) that were included in the subgroupings within the Creditable Expenditures grouping. Any amounts entered in column 4 should be consistent with the allocation information provided on Form 8980, Item C for such adjustments. Allocations of any net negative adjustments resulting after subgroupings (representing net increases to creditable expenditures) should be included in column 6.

Column (5): Total Share of Credit Grouping Adjustments (positive and negative adjustments) . Enter in the appropriate subcolumn of column 5 (General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of all credit adjustments (positive and negative) that were included in the Credit Grouping per the NOPPA. Any amounts entered in column 5 should be consistent with the allocation information provided on Form 8980, Item C for such adjustments.

Column (6): Total Share of Negative Adjustments . Include in column 6, the following amounts:

The total of all allocations for each relevant partner which are net negative adjustments (resulting after subgrouping per the NOPPA) in the

Reallocation and Residual grouping; and

The total of any net negative adjustments (resulting after subgrouping per the NOPPA) in the Creditable Expenditures grouping. A net negative

adjustment in the Creditable Expenditures grouping is a net increase to Creditable Expenditures after subgrouping.

Any amounts entered in column 6 should be consistent with the allocation information provided on Form 8980, Item C, for such adjustments.

Column (7): Amount of Tax Paid . Include in column 7 the amount of tax paid by the partner or on behalf of the partner relative to the requested modification. Note: See “ BBA Partner Payments Related to Requested Modifications ” under the General Instructions for information on how partner payments must be identified at the time payments are made.

Column (8): Amount of Penalty Paid . Include in column 8 the amount of any penalty paid by the partner or on behalf of the partner relative to the requested modification.

Column (9): Date Paid . Use the drop-down calendar to select the date of payment for the amount of tax included in column 7.

Item F – Signature of Partnership Representative (PR) This form must be signed by the partnership representative who has the sole authority to act on behalf of the partnership.

If the form is being filed electronically:

Signature of individual partnership representative or designated individual : The form is e-signed by entering the 5-digit PIN in the

signature block. A POA for the PR may sign Form 8980 with PIN signature . Refer to the PIN Signature section under Important Tips for Electronic Submission at the beginning of this Publication. This is a required feld .

Name of person signing form : The name, exactly as it appears in the Transmitter Control Code (TCC) application, must be entered in the

“Name of person signing the form” block (e.g., if your name is “John T. Smith” in the TCC application, enter the name “John T. Smith” in the name block, not “John Smith,” or “JT Smith,”). This is a required feld .

Title & Date : Enter your title and the date the form is being signed. These are both required felds .
Telephone number : Enter a daytime telephone number.
Name of entity partnership representative (if applicable) : If the partnership representative is an entity, enter the entity name.

If the form is being attached to the filing of an AAR, the form can be signed manually:

If you are an individual partnership representative:
- Signature of individual partnership representative or designated individual: Sign within this block.
- Name of person signing form: Enter the name of the person signing.
- Title, Date, and Telephone number: Enter the signor’s title, date signed, and daytime telephone number.
If you are a designated individual : In addition to completing the five fields mentioned above, also complete the field “Name of entity

partnership representative”.