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A foreign partnership is any partnership (including an entity classified as a partnership) that is not organized under the laws of any state of the United States or the District of Columbia or any partnership that is treated as foreign under the income tax regulations.
Purpose of Form Use Form 8865 to report the information required under section 6038 (reporting with respect to controlled foreign partnerships), section 6038B (reporting of transfers to foreign partnerships), or section 6046A (reporting of acquisitions, dispositions, and changes in foreign partnership interests).
A U.S. person files Form 8865 to report the information required under: Section 6038 (reporting with respect to controlled foreign partnerships). Section 6038B (reporting of transfers to foreign partnerships). Section 6046A (reporting of acquisitions, dispositions, and changes in foreign partnership interests).
Form 8865 is filed for the foreign partnership by another Category 1 filer under the multiple Category 1 filers exception. To qualify for the constructive ownership filing exception, the indirect partner must file with its income tax return a statement entitled Controlled Foreign Partnership Reporting.
Form 8865 can be electronically filed only if the form is attached to the filers electronic file. The form cannot be electronically filed separately. You must have a separate UltraTax CS 1065 client with Foreign Ptnrshp (8865) selected in File Client Properties.
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U.S. citizens and U.S. residents who are officers, directors, or shareholders in certain foreign corporations are responsible for filing Form 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations.
File Form 1116, Foreign Tax Credit, to claim the foreign tax credit if you are an individual, estate or trust, and you paid or accrued certain foreign taxes to a foreign country or U.S. possession.
If you dont have to file an income tax return, you must file Form 8865 separately with the IRS at the time and place you would be required to file an income tax return (or, if applicable, a partnership or exempt organization return). See below for penalties that may apply if you dont file Form 8865 on time.
A U.S. transferor that is required to provide information with respect to a partnership under Regulations sections 1.721(c)-6(b)(2)(iv) and 1.721(c)-6(b)(3)(xi) must file a separate Form 8865 (along with all necessary schedules and attachments) for each partnership treated as a U.S. transferor under Regulations
A U.S. transferor that is required to provide information with respect to a partnership under Regulations sections 1.721(c)-6(b)(2)(iv) and 1.721(c)-6(b)(3)(xi) must file a separate Form 8865 (along with all necessary schedules and attachments) for each partnership treated as a U.S. transferor under Regulations

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