Form 8804-C Certificate of Partner-Level Items to Reduce Section 144

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TLS, have you
transmitted all R
text files for this
cycle update?

Date

Form

I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 8920, PAGE 1 OF 2
MARGINS; TOP 13mm (1/2"), CENTER SIDES. PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
FLAT SIZE: 216mm (8-1/2") x 279mm (11")
PERFORATE: None
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

8804-C

Department of the Treasury
Internal Revenue Service

Part I

Action

Signature

O.K. to print
Revised proofs
requested

Certificate of Partner-Level Items to Reduce
Section 1446 Withholding

OMB No. 1545-XXXX

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Partnership’s tax year for which the certificate is submitted
beginning
, 2007, and ending
, 20
©

2007

See separate instructions.

General Information — If the partner is submitting an updated certificate, check here
Section A—Partner Information

Foreign partner’s name

Date

©

Taxpayer Identification Number

Date of Certification

Number, street, and room or suite no. If a P.O. box, see instructions.
City, state, and ZIP code. If a foreign address, see instructions.

Section B—Partnership Information
Partnership’s name

Employer Identification Number

Number, street, and room or suite no. If a P.O. box, see instructions.
City, state, and ZIP code. If a foreign address, see instructions.

The partner makes the following representations:
1 I am a foreign person that meets the requirements of Regulations section 1.1446-6(b).
2a I have timely filed, or will timely file, my U.S. federal income tax return for each of the preceding 4 tax years and the tax year
during which the certificate is considered and have timely paid (or will timely pay) all tax shown on such returns as required
under Regulations section 1.1446-6(b).
b As of the time of submission of this certificate, I had not filed the following U.S. federal income tax return:
Return Form ©
Tax Year Ended ©
Filing Due Date ©
c I will comply with the provisions of Regulations section 1.1446-6(c)(2)(i)(B)(1) for providing an updated certificate or status
update with respect to the filing of any such return. See instructions for additional information.
Parts II and III – Complete either Part II or Part III. Complete Part II to certify the deductions and losses for the tax year that you
reasonably expect to be available to reduce your U.S. income tax liability on your allocable share of effectively connected income or gain
from the partnership (see the Part II instructions for more details). Complete Part III to certify that your investment in the partnership is (and
will be) your only activity that will give rise to effectively connected items for the tax year (see the Part III instructions for more details).

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The foreign partner is completing (check one):

Part II

Part II

Part III

Certifications of Deductions and Losses under Regulations sections 1.1446-6(c)(1)(i) and (ii)

Whereas the partner has completed all of the applicable information requested in Part I of this form, which is incorporated into this
certification by reference, the partner makes the following representations:
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The deductions and losses set forth in this certificate are described in Regulations section 1.1446-6(c)(1).

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The amounts of deductions and losses as described in Regulations section 1.1446-6(c)(1) that I reasonably expect to be
available to reduce my U.S. income tax liability on my allocable share of effectively connected income or gain from the
partnership for the tax year in which such income or gain is includible in gross income are:
5a
a Net operating loss carryforward
b Other ordinary deductions and losses under Regulations section 1.1446-6(c)(1) that are subject
5b
to limitation
5c
c Capital losses (attach a statement that indicates type and amount)
d Other deductions and losses that warrant special consideration (attach a statement that
5d
indicates the type and amount)

6

The deductions and losses set forth above have been reflected on a timely filed U.S. income tax return.

7

The amounts of deductions and losses set forth in this certificate pursuant to Regulations section 1.1446-6(c)(1), have not been
set forth in a certificate provided to another partnership for the same tax year for the purpose of reducing withholding under
section 1446.

8

All of the deductions and losses described under Regulations section 1.1446-6(c)(1), and set forth in the certificate are (or will
be) reflected on my income tax return that is filed (or will be filed) with respect to a tax year that ends (or ended) prior to the
installment due date or Form 8804 filing due date (without regard to extensions) for the partnership tax year for which such
certificate will be considered.
The deductions and losses described under Regulations section 1.1446-6(c)(1) and set forth in this certificate have not been
disallowed by the IRS as part of a proposed adjustment described in Regulations section 601.103(b) or 601.105(b).

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For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 37731M

Form

8804-C

(2007)

5
I.R.S. SPECIFICATIONS
TO BE REMOVED BEFORE PRINTING
INSTRUCTIONS TO PRINTERS
FORM 8920, PAGE 2 OF 2
MARGINS; TOP 13mm (1/2"), CENTER SIDES. PRINTS: HEAD TO HEAD
PAPER: WHITE WRITING, SUB. 20.
INK: BLACK
FLAT SIZE: 216mm (8-1/2") x 279mm (11")
PERFORATE: None
DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

Form 8804-C (2007)

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Page

2

The amounts of deductions and losses set forth in this certificate pursuant to Regulations section 1.1446-6(c)(1), are not being
used by the partner to reduce the installment amounts of tax due on its income, other than its allocable share of income from
the partnership to which it provided the certificate, to avoid the estimated tax penalties under section 6654 or 6655 for the
same tax year.

Part III

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Certification under Regulations section 1.1446-6(c)(1)(iv)

Whereas the partner has completed all of the applicable information requested in Part I of this form, which is incorporated into this
certification by reference, the partner makes the following representations:
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Check here if the only activity that gives rise to effectively connected income, gain, deduction, or loss during my tax year is
(and will be) my investment in the partnership.

Part IV

Disclosure Consent and Signature

Consent is hereby given to disclosures of return and return information by the Internal Revenue Service pertaining to the validity
of this certificate to the partnership or other withholding agent to which this certificate is submitted for the purpose of administering
section 1446.
Under penalties of perjury, I declare that I have examined this certification, including accompanying schedules and statements, and
to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than taxpayer) is based on
all information of which preparer has any knowledge.

Sign
Here
Paid
Preparer’s
Use Only

©

Signature of partner

Preparer’s
signature

©

Firm’s name (or
yours if self-employed),
address, and ZIP code

Title

Date

Title

Date

Date

©

Check if
self-employed

Preparer’s SSN or PTIN

EIN
Phone no. (
Printed on Recycled Paper

)
Form

8804-C

(2007)