Transfer of Property to a Foreign Partnership
(Under Section 6038B)
Department of the Treasury
Internal Revenue Service
Attach to Form 8865. See the Instructions for Form 8865.
Go to www.irs.gov/Form8865 for instructions and the latest information.
OMB No. 1545-1668
Name of transferor Filer’s identifying number
Name of foreign partnership EIN (if any) Reference ID number (see instructions)
Is the partnership a section 721(c) partnership (as defined in Temporary Regulations section
1.721(c)-1T(b)(14))? See instructions . . . . . . . . . . . . . . . . . . . . . . . . Yes No
If “Yes,” was the gain deferral method applied to avoid the recognition of gain upon the contribution of property?
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
payable, and other
used in trade
other than intangible
in section 197(f)(9)
Type of property
Fair market value
on date of transfer
Cost or other
3 Enter the transferor’s percentage interest in the partnership: (a) Before the transfer
(b) After the transfer
Supplemental Information Required To Be Reported (see instructions):
Dispositions Reportable Under Section 6038B
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 Schedule O (Form 8865) 12-2018
(Rev. December 2018)