2a. At the end of the tax year, did any foreign or domestic corporation, partnership (including any entity treated as a partnership), trust, or tax-exempt organization, or any foreign government own, directly or indirectly, an interest of 50% or more in the profit, loss, or capital of the partnership?
2b. At the end of the tax year, did any individual or estate own, directly or indirectly, an interest of 50% or more in the profit, loss, or capital of the partnership?
3a. At the end of the tax year, did the partnership own, directly or indirectly, 50% or more of the total voting power of all classes of stock entitled to vote of any foreign or domestic corporation?
(i) Name of Corporation *
(ii) Employer Identification Number (if any)
(iii) Country of Incorporation *
(iv) Percentage Owned in Voting Stock *
3b. At the end of the tax year, did the partnership own, directly or indirectly, an interest of 50% or more in the profit, loss, or capital in any foreign or domestic partnership (including an entity treated as a partnership) or in the beneficial interest of a trust?
5. Is this partnership a publicly traded partnership as defined in section 469(k)(2)?
6. During the tax year, did the partnership have any debt that was cancelled, was forgiven, or had the terms modified so as to reduce the principal amount of the debt?
7. Has this partnership filed, or is it required to file, Form 8918, Material Advisor Disclosure Statement, to provide information on any reportable transaction?
8. At any time during calendar year 2022, did the partnership have an interest in or a signature or other authority over a financial account in a foreign country (such as a bank account, securities account, or other financial account)? See instructions for exceptions and filing requirements for FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).
9. At any time during the tax year, did the partnership receive a distribution from, or was it the grantor of, or transferor to, a foreign trust?
10a. Is the partnership making, or had it previously made (and not revoked), a section 754 election?
Effective Date of the Election
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10b. Did the partnership make for this tax year an optional basis adjustment under section 743(b) or 734(b)?
10c. Is the partnership required to adjust the basis of partnership assets under section 743(b) or 734(b) because of a substantial built-in loss (as defined under section 743(d)) or substantial basis reduction (as defined under section 734(d))?
10d. Is the partnership required to adjust the basis of partnership property under section 743(b) or 734(b) because of a substantial built-in loss (as defined under section 743(d)) or substantial basis reduction (as defined under section 734(d))?
11. Check the box if, during the current or prior tax year, the partnership distributed any property received in a like-kind exchange or contributed such property to another entity (other than disregarded entities wholly owned by the partnership throughout the tax year)
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12. At any time during the tax year, did the partnership distribute to any partner a tenancy-in-common or other undivided interest in partnership property?
13. If the partnership is required to file Form 8858, Information Return of U.S. Persons With Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs)
Enter the number of 8858 forms attached
14. Does the partnership have any foreign partners?
Enter the number of Forms 8805, Foreign Partner’s Information Statement of Section 1446 Withholding Tax, filed for this partnership
15. Enter the number of Forms 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships, attached to this return
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16a. Did you make any payments in 2022 that would require you to file Form(s) 1099?
16a. Did you or will you file required Form(s) 1099?
17. Enter the number of Forms 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations, attached to this return
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18. Enter the number of partners that are foreign governments under section 892
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19. During the partnership’s tax year, did the partnership make any payments that would require it to file Forms 1042 and 1042-S under chapter 3 (sections 1441 through 1464) or chapter 4 (sections 1471 through 1474)?
20. Was the partnership a specified domestic entity required to file Form 8938 for the tax year?
21. Is the partnership a section 721(c) partnership, as defined in Regulations section 1.721(c)-1(b)(14)?
22. During the tax year, did the partnership pay or accrue any interest or royalty for which one or more partners are not allowed a deduction under section 267A?
Enter the total amount of the disallowed deductions
23. Did the partnership have an election under section 163(j) for any real property trade or business or any farming business in effect during the tax year?
24. Does the partnership satisfy one or more of the following?
a. The partnership owns a pass-through entity with current, or prior year carryover, excess business interest expense.
25. Is the partnership attaching Form 8990 to certify as a Qualified Opportunity Fund?
Enter the amount from Form 8996, line 15
26. Enter the number of foreign partners subject to section 864(c)(8) as a result of transferring all or a portion of an interest in the partnership or of receiving a distribution from the partnership
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27. At any time during the tax year, were there any transfers between the partnership and its partners subject to the disclosure requirements of Regulations section 1.707-8?
28. Since December 22, 2017, did a foreign corporation directly or indirectly acquire substantially all of the properties constituting a trade or business of your partnership, and was the ownership percentage (by vote or value) for purposes of section 7874 greater than 50% (for example, the partners held more than 50% of the stock of the foreign corporation)?
29a. Is the partnership required to file Form 7208, Excise Tax on Repurchase of Corporate Stock, under the applicable foreign corporation rules? (See instructions)
29b. Is the partnership required to file Form 7208, Excise Tax on Repurchase of Corporate Stock, under the covered surrogate foreign corporation rules? (See instructions)
30. At any time during this tax year, did the partnership (a) receive (as a reward, award, or payment for property or services); or (b) sell, exchange, or otherwise dispose of a digital asset (or financial interest in a digital asset)?
33. Is the partnership electing out of the centralized partnership audit regime under section 6221(b)?
Enter the total from Schedule B-2, Part III, line 3
Designation of Partnership Representative
Name of PR
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U.S. phone number of PR
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U.S. Address of Designated Individual
U.S. phone number of designated individual
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1. Net income (loss) per books
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2. Income included on Schedule K, lines 1, 2, 3c, 5, 6a, 7, 8, 9a, 10, and 11, not recorded on books this year (itemize):
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Describe the income included on line 2 above
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3. Guaranteed payments (other than health insurance)
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4a. Depreciation - Expenses recorded on books this year not included on Schedule K, lines 1 through 13d, and 21
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Describe the expenses indicated in line 4a
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4b. Travel and Entertainment - Expenses recorded on books this year not included on Schedule K, lines 1 through 13d, and 21
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Describe the expenses indicated in line 4b
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6. Amount of Tax-Exempt Interest - Income recorded on books this year not included on Schedule K, lines 1 through 11
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Description of Tax-Exempt Interest on Line 6
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7. Amount of Tax Depreciation Deductions on Schedule K, lines 1 through 13d, and 21, not charged against book income this year (itemize):
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Description of Tax Depreciation on Line 7
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