8858 Schedule M Transactions Between Disregarded Entity of a Foreign Tax

SCHEDULE M
(Form 8858)

Transactions Between Foreign Disregarded Entity (FDE) or
Foreign Branch (FB) and the Filer or Other Related Entities

(Rev. September 2021)
Department of the Treasury
Internal Revenue Service
Name of person filing Form 8858

OMB No. 1545-1910

Attach to Form 8858.
▶ Go to www.irs.gov/Form8858 for instructions and the latest information.
▶

Identifying number

Name of FDE or FB

U.S. identifying number, if any

Name of tax owner

Reference ID number (see instructions)
U.S. identifying number, if any

Important: Complete a separate Schedule M for each FDE or FB. Enter the totals for each type of transaction that occurred during
the annual accounting period between the FDE or FB and the persons listed in the applicable columns (b) through (f). All amounts must
be stated in U.S. dollars translated from functional currency at the appropriate exchange rate for the FDE’s or FB’s tax year. See
instructions.
Enter the relevant functional currency and the exchange rate used throughout this schedule ▶
Column headings. This schedule contains three sets of column headings. Check the box that identifies the status of the tax owner
and complete lines 1 through 21 with respect to the applicable set of column headings.

(b) U.S. person filing
this return

(c) Any domestic
corporation or
partnership
controlling or
controlled by the filer

(d) Any foreign
corporation or
partnership
controlling or
controlled by the
filer (other than the
tax owner)

(e) Any U.S. person
with a 10% or more
direct interest in the
controlled foreign
partnership (other
than the filer)

(b) U.S. person filing
this return

(c) Any domestic
corporation or
partnership controlled
by the filer

(d) Any foreign
corporation or
partnership controlled
by the filer (other
than tax owner)

(e) 10% or more U.S.
shareholder of any
corporation
controlling the tax
owner

(b) U.S. person filing
this return
(other than the
tax owner of the
FDE or FB)

(c) Any domestic
corporation or
partnership controlled
by the filer (other than
the tax owner of the
FDE or FB)

Controlled Foreign Partnership
(a) Transactions of
FDE or FB

Controlled Foreign Corporation
(a) Transactions of
FDE or FB
U.S. Tax Owner
(a) Transactions of
FDE or FB

1
2

Sales of inventory . . .
Sales of property rights .

3

Compensation received for certain
services . . . . . . . .

4

Commissions received

5

Rents, royalties, and license fees
received
. . . . . . .

6
7
8
9
10

Dividends/Distributions received
Interest received . . . . .
Loan guarantee fees received .
Other . . . . . . . .
Add lines 1 through 9 . . . .

11

Purchases of inventory

12

Purchases of tangible property
other than inventory . . . .

13

Purchases of property rights

14

Compensation paid for certain
services
. . . . . . .

15

Commissions paid

16

Rents, royalties, and license fees
paid . . . . . . . . .

17
18
19

Interest paid . . . .
Loan guarantee fees paid
Add lines 11 through 18 .

.
.
.

.
.
.

20

Amounts borrowed
(see instructions) .

.

.

.

.

21

Amounts loaned
(see instructions) .

.

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.

.

.

.

.

.

.
.

.

.

(f) 10% or more U.S.
shareholder, or other
owner, of any entity
controlling the tax
owner

(d) Any foreign
(e) Any foreign
corporation (including
partnership (including its
its branches or
branches or FDEs)
disregarded entities)
controlling or controlled
controlling or controlled
by the filer
by the filer

.
.

.

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For Paperwork Reduction Act Notice, see the Instructions for Form 8858.

Cat. No. 37387C

Schedule M (Form 8858) (Rev. 9-2021)