8858 Information Return of U.S. Persons With Respect To Forei

Form

8858

(Rev. December 2008)
Department of the Treasury
Internal Revenue Service

Information Return of U.S. Persons With
Respect To Foreign Disregarded Entities

OMB No. 1545-1910

© See separate instructions.
Information furnished for the foreign disregarded entity’s annual accounting period (see
instructions) beginning . . .
, 20
, and ending
, 20

Attachment
Sequence No.

Name of person filing this return

140

Filer’s identifying number

Number, street, and room or suite no. (or P.O. box number if mail is not delivered to street address)

City or town, state, and ZIP code

Filer’s tax year beginning

, 20

, and ending

, 20

Important: Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated
in U.S. dollars unless otherwise indicated.
1a Name and address of foreign disregarded entity

b

U.S. identifying number, if any

c Country(ies) under whose laws organized and entity type under local tax law

d

Date(s) of organization e

Effective date as foreign
disregarded entity

f

h

Principal business
activity

Functional currency

If benefits under a U.S. tax treaty were claimed with respect to
income of the foreign disregarded entity, enter the treaty and article
number

g Country in which principal
business activity is conducted

i

Provide the following information for the foreign disregarded entity’s accounting period stated above.

2

a Name, address, and identifying number of branch office or agent (if any) in
the United States

b

Name and address (including corporate department, if applicable) of
person(s) with custody of the books and records of the foreign disregarded
entity, and the location of such books and records, if different

For the tax owner of the foreign disregarded entity (if different from the filer) provide the following:

3

a Name and address

b

Annual accounting period covered by the
return (see instructions)

c

U.S. identifying number, if any

d

Country under whose laws organized

e

Functional currency

c

U.S. identifying number, if any

d

Functional currency

For the direct owner of the foreign disregarded entity (if different from the tax owner) provide the following:

4

a Name and address

5

b

Country under whose laws organized

Attach an organizational chart that identifies the name, placement, percentage of ownership, tax classification, and country of organization of all entities in
the chain of ownership between the tax owner and the foreign disregarded entity, and the chain of ownership between the foreign disregarded entity and
each entity in which the foreign disregarded entity has a 10% or more direct or indirect interest. See instructions.

Schedule C
Income Statement (see instructions)
Important: Report all information in functional currency in accordance with U.S. GAAP. Also, report each amount in
U.S. dollars translated from functional currency (using GAAP translation rules or the average exchange rate determined
under section 989(b)). If the functional currency is the U.S. dollar, complete only the U.S. Dollars column. See instructions
for special rules for foreign disregarded entities that use DASTM.
If you are using the average exchange rate (determined under section 989(b)), check the following box
Functional Currency

1
2
3
4
5
6
7
8

Gross receipts or sales (net of returns and allowances)
Cost of goods sold
Gross profit (subtract line 2 from line 1)
Other income
Total income (add lines 3 and 4)
Total deductions
Other adjustments
Net income (loss) per books

For Paperwork Reduction Act Notice, see the separate instructions.

U.S. Dollars

1
2
3
4
5
6
7
8
Cat. No. 21457L

Form

8858

(Rev. 12-2008)

Form 8858 (Rev. 12-2008)

Schedule C-1

Page

(a)
Amount stated in
functional currency of
foreign disregarded entity

1
2

Remittances from the foreign disregarded entity
Section 987 gain (loss) of recipient

(b)
Amount stated in
functional currency
of recipient

1
2
Yes

3
4

2

Section 987 Gain or Loss Information

No

Were all remittances from the foreign disregarded entity treated as made to the direct owner?
Did the tax owner change its method of accounting for section 987 gain or loss with respect to
remittances from the foreign disregarded entity during the tax year?

Schedule F
Balance Sheet
Important: Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in
accordance with U.S. GAAP. See instructions for an exception for foreign disregarded entities that use DASTM.
(a)
Beginning of annual
accounting period

Assets
1
2
3

Cash and other current assets
Other assets
Total assets

(b)
End of annual
accounting period

1
2
3

Liabilities and Owner’s Equity
4
5
6

Liabilities
Owner’s equity
Total liabilities and owner’s equity

Schedule G

4
5
6

Other Information
Yes

1
2

During the tax year, did the foreign disregarded entity own an interest in any trust?
During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly,
in any foreign partnership?

3

Answer the following question only if the foreign disregarded entity made its election to be treated as
disregarded from its owner during the tax year: Did the tax owner claim a loss with respect to stock or
debt of the foreign disregarded entity as a result of the election?

4

Answer the following question only if the foreign disregarded entity is owned directly or indirectly by a
domestic corporation and the foreign disregarded entity incurred a net operating loss for the tax year: Is the
foreign disregarded entity a separate unit as defined in Regulations section 1.1503(d)-1(b)(4)? (If “Yes,” see
the instructions)

5

Answer the following question only if the tax owner of the foreign disregarded entity is a controlled foreign
corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and
the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted
as a manufacturing, selling, or purchasing branch?

No

Schedule H
Current Earnings and Profits or Taxable Income (see instructions)
Important: Enter the amounts on lines 1 through 6 in functional currency.
1
2
3
4
5
6
7

Current year net income or (loss) per foreign books of account
Total net additions
Total net subtractions
Current earnings and profits (or taxable income—see instructions) (line 1 plus line 2 minus line 3)
DASTM gain or loss (if applicable)
Combine lines 4 and 5
Current earnings and profits (or taxable income) in U.S. dollars (line 6 translated at the average
exchange rate determined under section 989(b) and the related regulations (see instructions))
Enter exchange rate used for line 7 ©

1
2
3
4
5
6
7
Form

8858

(Rev. 12-2008)