SCHEDULE M 

(Form 8858) 

(Rev. September 2021)

Transactions Between Foreign Disregarded Entity (FDE) or 

Foreign Branch (FB) and the Filer or Other Related Entities

Department of the Treasury 

Internal Revenue Service 

▶ Attach to Form 8858. 

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

OMB No. 1545-1910

Name of person filing Form 8858 Identifying number

Name of FDE or FB U.S. identifying number, if any Reference ID number (see instructions)

Name of tax owner 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.

Controlled Foreign Partnership 

(a) Transactions of 

 FDE or FB

(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) 

Controlled Foreign Corporation 

(a) Transactions of 

FDE or FB

(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 

(f) 10% or more U.S. 

shareholder, or other 

owner, of any entity 

controlling the tax 

owner 

U.S. Tax Owner

(a) Transactions of 

 FDE or FB

(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)

(d) Any foreign 

corporation (including

its branches or 

disregarded entities) 

controlling or controlled 

by the filer

(e) Any foreign 

partnership (including its 

branches or FDEs) 

controlling or controlled 

by the filer 

1 Sales of inventory . . . . .

2 Sales of property rights . . .

3 Compensation received for certain 

services . . . . . . . .

4 Commissions received . . .

5 Rents, royalties, and license fees 

received . . . . . . .

6 Dividends/Distributions received 

7 Interest received . . . . .

8 Loan guarantee fees received .

9 Other . . . . . . . .

10 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 Interest paid . . . . . .

18 Loan guarantee fees paid . .

19 Add lines 11 through 18 . . .

20 Amounts borrowed 

(see instructions) . . . . .

21 Amounts loaned 

(see instructions) . . . . .

For Paperwork Reduction Act Notice, see the Instructions for Form 8858. Cat. No. 37387C Schedule M (Form 8858) (Rev. 9-2021)