8804-W Installment Payments of Section 1446 Tax for Partnership

Caution: DRAFT—NOT FOR FILING
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Form

8804-W

(WORKSHEET)

Department of the Treasury
Internal Revenue Service

Part I
1

Installment Payments of Section 1446 Tax for Partnerships
▶ Go

to www.irs.gov/Form8804W for instructions and the latest information.

For calendar year 2019, or tax year beginning

, 2019, ending

Determination of Installment Payments

Allocable share of effectively connected taxable income (ECTI)
expected for the tax year for all foreign partners (see instructions):

DRAFT AS OF
July 27, 2018
DO NOT FILE

9

10
11

12
13

2019

, 20

(Keep for the partnership’s records—Do not send to the Internal Revenue Service.)

a Total ECTI allocable to corporate partners . . . . . . . . . .
1a
b Reduction to line 1a for state and local taxes under Regulations section
)
1.1446-6(c)(1)(iii) . . . . . . . . . . . . . . . . . .
1b (
c Reduction to line 1a for certified foreign partner-level items submitted using Form 8804-C
)
1c (
d Combine lines 1a, 1b, and 1c . . . . . . . . . . . . . . . . . . . . . . .
e Total ECTI allocable to non-corporate partners other than on lines 1i, 1m, and 1q
1e
)
f Reduction to line 1e for state and local taxes under Regulations section 1.1446-6(c)(1)(iii)
1f (
)
g Reduction to line 1e for certified foreign partner-level items submitted using Form 8804-C 1g (
h Combine lines 1e, 1f, and 1g . . . . . . . . . . . . . . . . . . . . . . .
i 28% rate gain (non-corporate partners only) . . . . . . . . .
1i
1j (
)
j Reduction to line 1i for state and local taxes under Regulations section 1.1446-6(c)(1)(iii)
)
k Reduction to line 1i for certified foreign partner-level items submitted using Form 8804-C
1k (
l Combine lines 1i, 1j, and 1k . . . . . . . . . . . . . . . . . . . . . . . .
m Unrecaptured section 1250 gain (non-corporate partners only) . . .
1m
)
1n (
n Reduction to line 1m for state and local taxes under Regulations section 1.1446-6(c)(1)(iii)
)
o Reduction to line 1m for certified foreign partner-level items submitted using Form 8804-C
1o (
p Combine lines 1m, 1n, and 1o . . . . . . . . . . . . . . . . . . . . . . .
q Adjusted net capital gain (including qualified dividend income and net
1q
section 1231 gain) (non-corporate partners only) . . . . . . . .
r Reduction to line 1q for state and local taxes under Regulations section 1.1446-6(c)(1)(iii)
)
1r (
s Reduction to line 1q for certified foreign partner-level items submitted
)
1s (
using Form 8804-C
. . . . . . . . . . . . . . . . .
t Combine lines 1q, 1r, and 1s . . . . . . . . . . . . . . . . . . . . . . .
2
Multiply line 1d by 21% (0.21) . . . . . . . . . . . . . . . . . . . . . . .
3
Multiply line 1h by 37% (0.37) . . . . . . . . . . . . . . . . . . . . . . .
4
Multiply line 1l by 28% (0.28) . . . . . . . . . . . . . . . . . . . . . . .
5
Multiply line 1p by 25% (0.25) . . . . . . . . . . . . . . . . . . . . . . .
6
Multiply line 1t by 20% (0.20) . . . . . . . . . . . . . . . . . . . . . . .
Add lines 2 through 6 . . . . . . . . . . . . . . . . . . . . . . . . . .
7
Note: If the aggregate line 7 amount of all foreign partners is less than $500, the partnership is not
required to make estimated tax payments.
8

OMB No. 1545-0123

1d

1h

1l

1p

1t
2
3
4
5
6
7

Enter the total section 1446 tax that would have been due for 2018, without regard to
reductions for certified foreign partner-level items or state and local taxes under Regulations
section 1.1446-6(c)(1)(iii), on ECTI allocable to all foreign partners for 2018 . . . . . . . .

8
Caution: This line 8 amount only applies if certain conditions are met. See instructions.
Enter the smaller of line 7 or line 8 (however, see Caution below). If the line 8 amount does not
apply, enter the amount from line 7 on line 9 . . . . . . . . . . . . . . . . . .
9
Caution: If, for any installment payment, line 7 is smaller than line 8 and you enter that smaller line 7 amount, you will not
qualify for the prior year safe harbor when determining any penalty due on Schedule A (Form 8804). See instructions.
(a)
(b)
(c)
(d)
Installment due dates. See
instructions . . . . . . .
10
Enter 25% (0.25) of line 9 in
columns (a) through (d). If the
partnership uses the annualized
income installment method or the
adjusted seasonal installment
method, then enter the amount
from line 43 . . . . . . .
Enter certain amounts paid or credited
for each period. See instructions . .
Balance due. Subtract line 12
from line 11 . . . . . . .

11
12
13

For Paperwork Reduction Act Notice, see instructions.

Cat. No. 40849X

Form 8804-W (2019)

Page 2

Form 8804-W (WORKSHEET) 2019

Part II

Adjusted Seasonal Installment Method (see instructions)
(Use this method only if the base period percentage for any 6 consecutive months is at least 70%.)

Enter ECTI allocable to all foreign partners for the following
periods.
a Tax year beginning in 2016
b Tax year beginning in 2017
c Tax year beginning in 2018
15
Enter ECTI allocable to all foreign partners for each period for
the tax year beginning in 2019. See instructions for the
treatment of extraordinary items.

14

(a)

(b)

(c)

(d)

First 3
months

First 5
months

First 8
months

First 11
months

DRAFT AS OF
July 27, 2018
DO NOT FILE
14a
14b
14c

15

First 4
months

16

Enter ECTI allocable to all foreign partners for the following
periods.

a
b
c
17

Tax year beginning in 2016
Tax year beginning in 2017
Tax year beginning in 2018
Divide the amount in each column on line 14a by the amount
in column (d) on line 16a.
Divide the amount in each column on line 14b by the amount
in column (d) on line 16b.
Divide the amount in each column on line 14c by the amount
in column (d) on line 16c.

18
19
20
21
22a
b
c
23

24
25a

Add lines 17 through 19.
Divide line 20 by 3.0.
Divide line 15 by line 21.
Extraordinary items (see instructions).
Combine lines 22a and 22b.
Reduction to line 22c amount for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii) and for certified foreign partnerlevel items submitted using Form 8804-C. See instructions.

Subtract line 23 from line 22c. If zero or less, enter -0-.
Multiply the ECTI on line 24 allocable to non-corporate
partners by 37% (0.37).
b Multiply the ECTI on line 24 allocable to corporate partners by
21% (0.21).
c Combine lines 25a and 25b.
26a Divide the amount in columns (a) through (c) on line 16a by the
amount in column (d) on line 16a.
b Divide the amount in columns (a) through (c) on line 16b by the
amount in column (d) on line 16b.
c Divide the amount in columns (a) through (c) on line 16c by the
amount in column (d) on line 16c.
27
Add lines 26a through 26c.
28
Divide line 27 by 3.0.
29
Multiply the amount in columns (a) through (c) of line 25c by the
amount in the corresponding column of line 28. In column (d), enter
the amount from line 25c, column (d). See line 37 for instructions.

First 6
months

First 9
months

Entire year

16a
16b
16c
17
18
19
20
21
22a
22b
22c

23
24
25a
25b
25c
26a
26b
26c
27
28

29
Form 8804-W (2019)

Page 3

Form 8804-W (WORKSHEET) 2019

Part III
30
31

Annualized Income Installment Method (see instructions)

Annualization periods (see instructions).
Enter ECTI allocable to all foreign partners for each annualization period.
See instructions for the treatment of extraordinary items.

a Total ECTI allocable to corporate partners.
b Total ECTI allocable to non-corporate partners other than on
lines 31c, 31d, and 31e.
c 28% rate gain (non-corporate partners only).
d Unrecaptured section 1250 gain (non-corporate partners only).
e Adjusted net capital gain (including qualified dividend income
and net section 1231 gain) (non-corporate partners only).
Annualization amounts (see instructions).
32
Annualized allocable share of ECTI for all foreign partners. See instructions
33

30

(a)
First
months

(b)
First
months

(c)
First
months

(d)
First
months

31a

DRAFT AS OF
July 27, 2018
DO NOT FILE
31b
31c
31d
31e
32

for the treatment of extraordinary items, and for rules regarding the
reductions for state and local taxes and certified foreign partner-level items: 33

Total ECTI allocable to corporate partners (multiply line 31a by
line 32).
b Reduction to line 33a for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii).
c Reduction to line 33a for certified foreign partner-level items
submitted using Form 8804-C.
d Combine lines 33a, 33b, and 33c.
e Total ECTI allocable to non-corporate partners other than on
lines 31i, 31m, and 31q (multiply line 31b by line 32).
a

Reduction to line 33e for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii).
g Reduction to line 33e for certified foreign partner-level items submitted using Form 8804-C.
h Combine lines 33e, 33f, and 33g.
i 28% rate gain allocable to non-corporate partners (multiply line 31c by line 32).
j Reduction to line 33i for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii).
k Reduction to line 33i for certified foreign partner-level items
submitted using Form 8804-C.
l Combine lines 33i, 33j, and 33k.
m Unrecaptured section 1250 gain allocable to non-corporate
partners (multiply line 31d by line 32).
n Reduction to line 33m for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii).
o Reduction to line 33m for certified foreign partner-level items
submitted using Form 8804-C.
p Combine lines 33m, 33n, and 33o.
q Adjusted net capital gain (including qualified dividend income
and net section 1231 gain) allocable to non-corporate partners
(multiply line 31e by line 32).
r Reduction to line 33q for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii).
s Reduction to line 33q for certified foreign partner-level items
submitted using Form 8804-C.
t Combine lines 33q, 33r, and 33s.
34
Figure the tax on line 33 amounts as follows.
a Multiply line 33d by 21% (0.21).
b Multiply line 33h by 37% (0.37).
c Multiply line 33l by 28% (0.28).
d Multiply line 33p by 25% (0.25).
e Multiply line 33t by 20% (0.20).
f Add lines 34a through 34e.
35
Applicable percentage.
36
Multiply line 34f by line 35. See line 37 for instructions.

33a

33b (

)(

)(

)(

)

33c (
33d

)(

)(

)(

)

33f (
33g (
33h
33i

)(
)(

)(
)(

)(
)(

)
)

33j (

)(

)(

)(

)

33k (
33l

)(

)(

)(

)

33n (

)(

)(

)(

)

33o (
33p

)(

)(

)(

)

33r (

)(

)(

)(

)

33s (
33t
34
34a
34b
34c
34d
34e
34f
35
36

)(

)(

)(

)

33e

f

33m

33q

25%

50%

75%

100%
Form 8804-W (2019)

Page 4

Form 8804-W (WORKSHEET) 2019

Part IV

Required Installments Under Part II and/or Part III
(a)
1st
installment

Note: Complete lines 37 through 43 of one column before
completing the next column.
37

38
39

If only Part II or Part III is completed, enter the amount in each
column from line 29 or line 36. If both parts are completed, enter
the smaller of the amounts in each column from line 29 or line 36.
Add the amounts in all preceding columns of line 43. See instructions.
Adjusted seasonal or annualized income installments.
Subtract line 38 from line 37. If zero or less, enter -0-.

(b)
2nd
installment

(c)
3rd
installment

DRAFT AS OF
July 27, 2018
DO NOT FILE

40
41

Enter 25% (0.25) of line 7 in each column.
Subtract line 43 of the preceding column from line 42 of the
preceding column.

42
43

Add lines 40 and 41.
Required installments. Enter the smaller of line 39 or line 42
here and on line 11.

(d)
4th
installment

37
38
39
40
41
42

43

Form 8804-W (2019)