8865 Schedule G Statement of Application of the Gain Deferral Method Und

SCHEDULE G
(Form 8865)

Statement of Application of the Gain Deferral Method
Under Section 721(c)

(November 2018)
Department of the Treasury
Internal Revenue Service
Name of person filing Form 8865

▶ Go

to Form 8865. See the Instructions for Form 8865.
to www.irs.gov/Form8865 for instructions and the latest information.
Filer’s identification number

Name of partnership

1.
Tax year of
contribution

EIN (if any)

Successor
partnership

Name of U.S. transferor (see instructions)

Part I

OMB No. 1545-1668

▶ Attach

Successor
U.S. transferor

Reference ID number (see instructions)

Filing year: (see instructions)
Tax year of gain deferral contribution

Annual reporting

Section 721(c) Property (see instructions)
2.
Description of property

3.
Recovery
period

4.
Section
197(f)(9)
property

5.
Effectively
connected
income
property

6. On the date of contribution
(a)
Fair market
value

(b)
Basis

7. Events
(c)
Built-in gain

(a)
Acceleration
(including
partial
acceleration
event)

(b)
Termination

(c)
Successor

(d)
(e)
Tax
Section
disposition of 367 transfer
a portion of
partnership
interest

1
2
3
4
From Part I additional
statement(s), if any

4a
Do the tiered partnership rules of Temporary Regulations section 1.721(c)‐3T(d) apply to this partnership? See instructions

Part II
Part I,
line
number

.

.

.

.

.

.

.

.

.

.

.

Yes

No

Remaining Built-in Gain, Remedial Income, and Gain Recognition (see instructions)
(a)
Remaining built‐in gain at
beginning of tax year

(b)
Remaining built‐in gain at
end of tax year

(c)
Remedial income allocated
to U.S. transferor

(d)
Gain recognized
due to acceleration event

(e)
Gain recognized
due to section 367 transfer

1
2
3
4
Total*
* Total must include any amounts included on an attached statement. See instructions.
For Paperwork Reduction Act Notice, see the Instructions for Form 8865.

Cat. No. 71017D

Schedule G (Form 8865) (11-2018)

Page 2

Schedule G (Form 8865) (11-2018)

Part III

Allocation Percentages of Partnership Items With Respect to Section 721(c) Property (see instructions)
1. Income
(a)
U.S.
transferor

Part I,
line
number

1
2
3
4

(b)
(c)
Related domestic Related foreign
partners
partners

%
%
%
%

Part IV

%
%
%
%

%
%
%
%

(a)
U.S.
transferor

(b)
(c)
Related domestic Related foreign
partners
partners

%
%
%
%

%
%
%
%

%
%
%
%

(a)
U.S.
transferor

4. Loss

(b)
(c)
Related domestic Related foreign
partners
partners

%
%
%
%

%
%
%
%

%
%
%
%

(a)
U.S.
transferor

(b)
(c)
Related domestic Related foreign
partners
partners

%
%
%
%

%
%
%
%

%
%
%
%

Allocation of Items to U.S. Transferor With Respect to Section 721(c) Property (see instructions)
1. Income

Part I,
line
number

3. Deduction

2. Gain

(a)
Book

3. Deduction

2. Gain
(b)
Tax

(a)
Book

(b)
Tax

(a)
Book

4. Loss
(b)
Tax

(a)
Book

(b)
Tax

1
2
3
4

Part V
1
2
3
4
5
6a
b
7a
b

Additional Information (see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H.

Yes

During the tax year, did an acceleration event or partial acceleration event (as described in Temporary Regulations section 1.721(c)‐4T or Temporary
Regulations section 1.721(c)‐5T(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . .
During the tax year, did a termination event (as described in Temporary Regulations section 1.721(c)‐5T(b)) occur with respect to one or more section 721(c) properties?
During the tax year, did a successor event (as described in Temporary Regulations section 1.721(c)‐5T(c)) occur with respect to one or more section 721(c) properties?
During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Temporary Regulations section 1.721(c)‐5T(f))?
During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in
Temporary Regulations section 1.721(c)‐5T(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Was any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each
contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . .
Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . .
Was a copy of the waiver of treaty benefits (as described in Temporary Regulations section 1.721(c)‐6T(b)(2)(iii)) filed with respect to each section 721(c)
property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . .
With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor
determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained
subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for
all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at
the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax
convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property?
See Temporary Regulations section 1.721‐6T(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part VI

No

1
2
3
4
5
6a
6b
7a

7b

Supplemental Information (see instructions)

Schedule G (Form 8865) (11-2018)