Form 8886 Reportable Transaction Disclosure Statement

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Form

8886

Reportable Transaction Disclosure Statement

OMB No. 1545-1800

▶ Attach

to your tax return.
(Rev. December 2019)
Attachment
▶ See separate instructions.
Department of the Treasury
Sequence No. 137
▶
Go to www.irs.gov/Form8886 for instructions and the latest information.
Internal Revenue Service
Name(s) shown on return (individuals enter last name, first name, middle initial)
Identifying number
Number, street, and room or suite no.

City or town

State

ZIP code

DRAFT AS OF
December 10, 2019
DO NOT FILE
A

If you are filing more than one Form 8886 with your tax return, sequentially number
each Form 8886 and enter the statement number for this Form 8886 . . . . .

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B

Enter the form number of the tax return to which this form is attached or related

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Protective disclosure

1a

Enter the year of the tax return identified above . . . . . . . . .
Is this Form 8886 being filed with an amended tax return? . . . . . .
Check the box(es) that apply. See instructions.
Initial year filer
Name of reportable transaction

1b

Initial year participated in transaction

2

Identify the type of reportable transaction. Check all boxes that apply. See instructions.
Listed
Contractual protection
Transaction of interest
c
e

C

a

b

3

d

Confidential

1c

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of

Statement number
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Yes

No

Reportable transaction or tax shelter registration number. See instructions.

Loss

If you checked box 2a or 2e, enter the published guidance number for the listed transaction or transaction

of interest . . . . . . . . . . . . . . . . . . . . . . . . . . ▶
Enter the number of “same as or substantially similar” transactions reported on this form . . . . . . . . ▶
If you participated in this reportable transaction through a partnership, S corporation, trust, and foreign entity, check the applicable boxes and
provide the information below for the entity(ies). See instructions. (Attach additional sheets, if necessary.)

4
5
a

Type of entity .

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b

Name

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c

Employer identification number (EIN), if known

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d

Date Schedule K-1 received from entity (enter
“none” if Schedule K-1 not received) . . .

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6

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Partnership
S corporation

Trust
Foreign

Partnership
S corporation

Trust
Foreign

a

Enter below the name and address of each individual or entity to whom you paid a fee with regard to the transaction if that individual or entity
promoted, solicited, or recommended your participation in the transaction, or provided tax advice related to the transaction. (Attach additional
sheets, if necessary.)
Name
Identifying number (if known)
Fees paid
$
Number, street, and room or suite no.
City or town
State ZIP code

b

Name
Number, street, and room or suite no.

Identifying number (if known)
City or town

For Paperwork Reduction Act Notice, see separate instructions.

Fees paid
$
State

Cat. No. 34654G

ZIP code

Form 8886 (Rev. 12-2019)

Form 8886 (Rev. 12-2019)

7
a

Page

2

Facts
Identify the type of tax benefit generated by the transaction. Check all the boxes that apply. See instructions.
Deductions
Capital loss

Exclusions from gross income
Nonrecognition of gain

Absence of adjustments to basis
Deferral

Tax credits

b
c

Ordinary loss
Adjustments to basis
Other
Enter the total dollar amount of your tax benefits identified in 7a. See instructions . . . . . . . . .
Enter the anticipated number of years the transaction provides the tax benefits stated in 7b. See instructions .

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$

d

Enter your total investment or basis in the transaction. See instructions .

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$

e

Further describe the amount and nature of the expected tax treatment and expected tax benefits generated by the transaction for all affected
years. Include facts of each step of the transaction that relate to the expected tax benefits including the amount and nature of your investment.
Include in your description your participation in the transaction and all related transactions regardless of the year in which they were entered
into. Also, include a description of any tax result protection with respect to the transaction.

DRAFT AS OF
December 10, 2019
DO NOT FILE
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8

Identify all individuals and entities involved in the transaction that are tax-exempt, foreign, or related. Check the appropriate box(es). See
instructions. Include their name(s), identifying number(s), address(es), and a brief description of their involvement. For each foreign entity,
identify its country of incorporation or existence. For each individual or related entity, explain how the individual or entity is related. Attach
additional sheets, if necessary.
Tax-exempt
Foreign
Related
a Type of individual or entity:
Identifying number
Name
Address
Description

b Type of individual or entity:
Name

Tax-exempt

Foreign

Related
Identifying number

Address
Description

Form 8886 (Rev. 12-2019)