8865 Sch O Transfer of Property to a Foreign Partnership (draft 201

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Transfer of Property to a Foreign Partnership

SCHEDULE O
(Form 8865)

(Under Section 6038B)

(Rev. December 2018)
Department of the Treasury
Internal Revenue Service
Name of transferor

OMB No. 1545-1668

Attach to Form 8865. See the Instructions for Form 8865.
▶ Go to www.irs.gov/Form8865 for instructions and the latest information.
▶

Filer’s identifying number
EIN (if any)

Reference ID number (see instructions)

DRAFT AS OF
July 11, 2018
DO NOT FILE

Name of foreign partnership

1a

Is the partnership a section 721(c) partnership (as defined in Temporary Regulations section
1.721(c)-1T(b)(14))? See instructions . . . . . . . . . . . . . . . . . . . . . . . .
b If “Yes,” was the gain deferral method applied to avoid the recognition of gain upon the contribution of property?
2
Was any intangible property transferred considered or anticipated to be, at the time of the transfer or at any
time thereafter, a platform contribution as defined in Regulations section 1.482-7(c)(1)? . . . . . . .
Transfers Reportable Under Section 6038B
Part I
Type of property

Cash

(a)
Date of
transfer

(b)
Description of
property

(c)
Fair market value
on date of transfer

(d)
Cost or other
basis

(e)
Recovery period

(f)
Section 704(c)
allocation method

Yes
Yes

No
No

Yes

No

(g)
Gain recognized
on transfer

Stock, notes receivable
and payable, and other
securities

Inventory

Tangible
property
used in trade
or business
Intangible
property
described in
section 197(f)(9)
Intangible property,
other than intangible
property described in
section 197(f)(9)
Other
property
Totals

3
Enter the transferor’s percentage interest in the partnership: (a) Before the transfer
Supplemental Information Required To Be Reported (see instructions):

Part II

(b) After the transfer

%

Dispositions Reportable Under Section 6038B

(a)
Type of
property

Part III

%

(b)
Date of
original transfer

(c)
Date of
disposition

(d)
Manner of
disposition

(e)
Gain recognized
by partnership

(f)
Depreciation
recapture
recognized
by partnership

(g)
Gain allocated
to partner

Is any transfer reported on this schedule subject to gain recognition under section 904(f)(3) or
▶
section 904(f)(5)(F)? . . . . . . . . . . . . . . . . . . . . . . . . .

For Paperwork Reduction Act Notice, see the Instructions for Form 8865.

Cat. No. 25909U

(h)
Depreciation
recapture allocated
to partner

Yes

No

Schedule O (Form 8865) 12-2018