SCHEDULE O
(Form 8865)
Transfer of Property to a Foreign Partnership
(Under Section 6038B)
Department of the Treasury
Internal Revenue Service
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Attach to Form 8865. See the Instructions for Form 8865.
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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)
1
a
Is the partnership a section 721(c) partnership (as defined in Temporary Regulations section
1.721(c)-1T(b)(14))? See instructions . . . . . . . . . . . . . . . . . . . . . . . . Yes No
b
If “Yes,” was the gain deferral method applied to avoid the recognition of gain upon the contribution of property?
Yes No
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)? . . . . . . .
Yes No
Part I
Transfers Reportable Under Section 6038B
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
Type of property
(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
(g)
Gain recognized
on transfer
Cash
Totals
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):
Part II
Dispositions Reportable Under Section 6038B
(a)
Type of
property
(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
(h)
Depreciation
recapture allocated
to partner
Part III
Is any transfer reported on this schedule subject to gain recognition under section 904(f)(3) or
section 904(f)(5)(F)? . . . . . . . . . . . . . . . . . . . . . . . . .
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Yes No
For Paperwork Reduction Act Notice, see the Instructions for Form 8865.
Cat. No. 25909U Schedule O (Form 8865) 12-2018
(Rev. December 2018)