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Control of a foreign partnership is ownership of more than a fifty-percent interest in the partnership.
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.
The reason Form 8865 exists is to help the IRS track U.S. members of foreign partnerships, and its similar to Form 1065, which is the form youd file for a U.S. partnership. A partnership is considered a foreign partnership when it wasnt created or organized in the United States or under the law of the United States.
In general, a U.S. person who is a partner in a foreign partnership is required to file Form 8865 to report the income and financial position of the partnership and to report certain transactions between the partner and the partnership. The form is required to be filed with the partners tax return.
Form 8865 returns can be electronically filed only if filing Form 1040, 1041, 1120, 1120S, or 1065. Multiple Form 8865 electronic files can be attached to the filers return, as needed.
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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
In general, a U.S. person who is a partner in a foreign partnership is required to file Form 8865 to report the income and financial position of the partnership and to report certain transactions between the partner and the partnership. The form is required to be filed with the partners tax return.
The reason Form 8865 exists is to help the IRS track U.S. members of foreign partnerships, and its similar to Form 1065, which is the form youd file for a U.S. partnership. A partnership is considered a foreign partnership when it wasnt created or organized in the United States or under the law of the United States.
Form 8865 returns can be electronically filed only if filing Form 1040, 1041, 1120, 1120S, or 1065. Multiple Form 8865 electronic files can be attached to the filers return, as needed.
UltraTax CS will include Form 8865 in the filers electronic file.

form 8865 filing requirements