Schedule A 

(Form 8804)

Department of the Treasury 

Internal Revenue Service

Penalty for Underpayment of Estimated 

Section 1446 Tax by Partnerships

▶ Attach to Form 8804.

▶ Go to www.irs.gov/Form8804 for instructions and the latest information.

OMB No. 1545-0123

2019

Name Employer identification number

Note: Generally, the partnership isn’t required to file this Schedule A (see Part I below for exceptions) because the IRS will figure any penalty 

owed and bill the partnership. However, the partnership may still use this Schedule A to figure the penalty. If so, enter the amount from line 65 

of this Schedule A on line 8 of Form 8804, but don’t attach this Schedule A.

Part I Reasons for Filing—Check the boxes below that apply. If any boxes are checked, the partnership must file 

Schedule A (Form 8804) even if it doesn’t owe a penalty. See instructions.

The partnership is using the adjusted seasonal installment method.

The partnership is using the annualized income installment method.

Part II Current Year and Prior Year Safe Harbors

1 Enter the total section 1446 tax shown on the partnership’s 2019 Form 8804, line 5f. If less than $500, 

don’t complete or file this form. The partnership doesn’t owe the penalty . . . . . . . . . . 1

2 Enter the total section 1446 tax that would have been due for 2018, without regard to reductions for 

certified foreign partner-level items, on the effectively connected taxable income (ECTI) allocable to 

foreign partners for 2018. 

Caution: This line 2 amount only applies if certain conditions are met. See instructions . . . . . . 2

3 Enter the smaller of line 1 or line 2. If the partnership is required to skip line 2, enter the amount from 

line 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Part III Figuring the Underpayment

(a) (b) (c) (d)

4 

 

Installment due dates. Enter in columns (a) through (d) 

the 15th day of the 4th, 6th, 9th, and 12th months of the

partnership’s tax year . . . . . . . . . . . 4

5 

 

 

 

Required installments. If the partnership uses the 

adjusted seasonal installment method and/or the 

annualized income installment method, enter the amounts 

from line 43. If neither of those methods is used, enter 

25% (0.25) of line 3 above in each column . . . . . 5

6 

 

Estimated section 1446 tax paid or credited for each 

period. See instructions. For column (a) only, enter the 

amount from line 6 on line 10 . . . . . . . . . 6

Complete lines 7 through 13 of one column before 

going to the next column.

7 Enter amount, if any, from line 13 of the preceding column 7

8 Add lines 6 and 7 . . . . . . . . . . . . 8

9 Add amounts on lines 11 and 12 of the preceding column 9

10 Subtract line 9 from line 8. If zero or less, enter -0- . . 10

11 If the amount on line 10 is zero, subtract line 8 from line 9. 

Otherwise, enter -0- . . . . . . . . . . . . 11

12 

 

Underpayment. If line 10 is less than or equal to line 5,

subtract line 10 from line 5. Then go to line 7 of the next

column. Otherwise, go to line 13 . . . . . . . . 12

13 Overpayment. If line 5 is less than line 10, subtract line 5 

from line 10. Then go to line 7 of the next column . . 13

Go to Part VII on page 5 to figure the penalty. Don’t go to Part VII if there are no entries on line 12—no penalty is owed.

For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 40853F Schedule A (Form 8804) 2019
Schedule A (Form 8804) 2019 Page 2

Part IV Adjusted Seasonal Installment Method (Caution: Use this method only if the base period percentage for 

any 6 consecutive months is at least 70%. See instructions.)

Check this box if the partnership has elected to attach a schedule 

that expands lines 15 and 22 through 25 to reflect Regulations 

section 1.1446-3(a)(2). See instructions . . . . . . . . ▶

(a) (b) (c) (d)

First 3 

months

First 5 

months

First 8 

months

First 11 

months

14 Enter ECTI allocable to all foreign partners for the following periods:

a Tax year beginning in 2016 14a

b Tax year beginning in 2017 14b

c Tax year beginning in 2018 14c

15 

 

Enter ECTI allocable to all foreign partners for each period for the 

tax year beginning in 2019 (see instructions for the treatment of 

extraordinary items). 15

First 4 

months

First 6 

months

First 9 

months Entire year

16 Enter ECTI allocable to all foreign partners for the following periods:

a Tax year beginning in 2016 16a

b Tax year beginning in 2017 16b

c Tax year beginning in 2018 16c

17 Divide the amount in each column on line 14a by the amount in 

column (d) on line 16a. 17

18 Divide the amount in each column on line 14b by the amount in 

column (d) on line 16b. 18

19 Divide the amount in each column on line 14c by the amount in 

column (d) on line 16c. 19

20 Add lines 17 through 19. 20

21 Divide line 20 by 3.0. 21

22a Divide line 15 by line 21. 22a

b Extraordinary items. See instructions. 22b

c Combine lines 22a and 22b. 22c

23 Reduction to line 22c amount for state and local taxes under 

Regulations section 1.1446-6(c)(1)(iii) and for certified foreign 

partner-level items submitted using Form 8804-C. See instructions. 23

24 Subtract line 23 from line 22c. If zero or less, enter -0-. 24

25a Multiply the ECTI on line 24 allocable to non-corporate partners by 

37% (0.37). 25a

b Multiply the ECTI on line 24 allocable to corporate partners by 

21% (0.21). 25b

c Combine lines 25a and 25b. 25c

26a Divide the amount in columns (a) through (c) on line 16a by the 

amount in column (d) on line 16a. 26a

b Divide the amount in columns (a) through (c) on line 16b by the 

amount in column (d) on line 16b. 26b

c Divide the amount in columns (a) through (c) on line 16c by the 

amount in column (d) on line 16c. 26c

27 Add lines 26a through 26c. 27

28 Divide line 27 by 3.0. 28

29 Multiply the amount in columns (a) through (c) of line 25c by 

columns (a) through (c) of line 28. In column (d), enter the amount 

from line 25c, column (d). 29

Schedule A (Form 8804) 2019
Schedule A (Form 8804) 2019 Page 3

Part V Annualized Income Installment Method

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

( ) ( ) ( ) ( ) 

(a) (b) (c) (d)

30 Annualization periods. See instructions. 30

First 

months

First

months

First

months

First

months

31 Enter ECTI allocable to all foreign partners for each annualization 

period (see instructions for the treatment of extraordinary items):

a Total ECTI allocable to corporate partners. 31a

b Total ECTI allocable to non-corporate partners other than on lines 

31c, 31d, and 31e. 31b

c 28% rate gain (non-corporate partners only). 31c

d Unrecaptured section 1250 gain (non-corporate partners only). 31d

e Adjusted net capital gain (including qualified dividend income and 

net section 1231 gains) (non-corporate partners only). 31e

32 Annualization amounts. See instructions. 32

33 Annualized ECTI allocable to all foreign partners (see instructions 

for the treatment of extraordinary items):

a Total ECTI allocable to corporate partners (multiply line 31a by line 

32). 33a

b Reduction to line 33a for state and local taxes under Regulations 

section 1.1446-6(c)(1)(iii). See instructions. 33b

c Reduction to line 33a for certified foreign partner-level items 

submitted using Form 8804-C. See instructions. 33c

d Combine lines 33a, 33b, and 33c. 33d

e Total ECTI allocable to non-corporate partners other than on lines 

33i, 33m, and 33q (multiply line 31b by line 32). 33e

f Reduction to line 33e for state and local taxes under Regulations 

section 1.1446-6(c)(1)(iii). See instructions. 33f

g Reduction to line 33e for certified foreign partner-level items 

submitted using Form 8804-C. See instructions. 33g

h Combine lines 33e, 33f, and 33g. 33h

i 28% rate gain allocable to non-corporate partners (multiply line 

31c by line 32). 33i

j Reduction to line 33i for state and local taxes under Regulations 

section 1.1446-6(c)(1)(iii). See instructions. 33j

k Reduction to line 33i for certified foreign partner-level items 

submitted using Form 8804-C. See instructions. 33k

l Combine lines 33i, 33j, and 33k. 33l

m Unrecaptured section 1250 gain allocable to non-corporate partners 

(multiply line 31d by line 32). 33m

n Reduction to line 33m for state and local taxes under Regulations 

section 1.1446-6(c)(1)(iii). See instructions. 33n

o Reduction to line 33m for certified foreign partner-level items 

submitted using Form 8804-C. See instructions. 33o

p Combine lines 33m, 33n, and 33o. 33p

q 

 

Adjusted net capital gain (including qualified dividend income and 

net section 1231 gains) allocable to non-corporate partners 

(multiply line 31e by line 32). 33q

r Reduction to line 33q for state and local taxes under Regulations 

section 1.1446-6(c)(1)(iii). See instructions. 33r

s Reduction to line 33q for certified foreign partner-level items 

submitted using Form 8804-C. See instructions. 33s

t Combine lines 33q, 33r, and 33s. 33t

34 Figure the tax on line 33 amounts as follows:

a Multiply line 33d by 21% (0.21). 34a

b Multiply line 33h by 37% (0.37). 34b

c Multiply line 33l by 28% (0.28). 34c

d Multiply line 33p by 25% (0.25). 34d

e Multiply line 33t by 20% (0.20). 34e

f Add lines 34a through 34e. 34f

Schedule A (Form 8804) 2019
Schedule A (Form 8804) 2019 Page 4

Part V Annualized Income Installment Method (continued)

(a) (b) (c) (d)

35 Applicable percentage. 35 25% (0.25) 50% (0.50) 75% (0.75) 100% (1.00)

36 Multiply line 34f by line 35. 36

Part VI Required Installments

Note: Complete lines 37 through 43 of one column before completing 

the next column.

1st 

installment

2nd 

installment

3rd 

installment

4th 

installment

37 If only Part IV or Part V is completed, enter the amount in each 

column from line 29 or line 36. If both parts are completed, enter 

the smaller of the amounts in each column from line 29 or line 36. 37

38 Add the amounts in all preceding columns of line 43. See instructions. 38

39 Adjusted seasonal or annualized income installments. Subtract 

line 38 from line 37. If zero or less, enter -0-. 39

40 Enter 25% (0.25) of line 1 in each column. 40

41 Subtract line 43 of the preceding column from line 42 of the preceding 

column. 41

42 Add lines 40 and 41. 42

43 Required installments. Enter the smaller of line 39 or line 42 here 

and on line 5. See instructions. 43

Schedule A (Form 8804) 2019
Schedule A (Form 8804) 2019 Page 5

Part VII Figuring the Penalty

(a) (b) (c) (d)

 44 Enter the date of payment or the 15th day of the 3rd month after 

the close of the tax year, whichever is earlier. See instructions. 

Partnerships that keep their records and books of account 

outside the United States and Puerto Rico: Use 6th month 

instead of 3rd month. 44

45 Number of days from due date of installment on line 4 to the 

date shown on line 44 . . . . . . . . . . . . 45

46 Number of days on line 45 after 4/15/2019 and before 7/1/2019 46

47 Underpayment on line 12 × Number of days on line 46

365 × 6% (0.06) 47 $ $ $ $

48 Number of days on line 45 after 6/30/2019 and before 10/1/2019 48

49 Underpayment on line 12 × Number of days on line 48

365 × 5% (0.05) 49 $ $ $ $

50 Number of days on line 45 after 9/30/2019 and before 1/1/2020 50

51 Underpayment on line 12 × Number of days on line 50

365 × 5% (0.05) 51 $ $ $ $

52 Number of days on line 45 after 12/31/2019 and before 4/1/2020 52

53 Underpayment on line 12 × Number of days on line 52

366

× *% 53 $ $ $ $

54 Number of days on line 45 after 3/31/2020 and before 7/1/2020 54

55 Underpayment on line 12 × Number of days on line 54

366

× *% 55 $ $ $ $

56 Number of days on line 45 after 6/30/2020 and before 10/1/2020 56

57 Underpayment on line 12 × Number of days on line 56

366

× *% 57 $ $ $ $

58 Number of days on line 45 after 9/30/2020 and before 1/1/2021 58

59 Underpayment on line 12 × Number of days on line 58

366

× *% 59 $ $ $ $

60 Number of days on line 45 after 12/31/2020 and before 4/1/2021 60

61 Underpayment on line 12 × Number of days on line 60

365

× *% 61 $ $ $ $

62 Number of days on line 45 after 3/31/2021 and before 5/16/2021 62

63 Underpayment on line 12 × Number of days on line 62

365

× *% 63 $ $ $ $

64 Add lines 47, 49, 51, 53, 55, 57, 59, 61, and 63 . . . . . 64 $ $ $ $

65 Penalty. Add columns (a) through (d) of line 64. Enter the total here and on Form 8804, line 8 . . 65 $

* Use the penalty interest rate for each calendar quarter, which the IRS will determine during the first month in the preceding quarter. These rates are 

published quarterly in an IRS News Release and in a revenue ruling in the Internal Revenue Bulletin (IRB). Go to www.irs.gov/irb for the IRBs. You can 

subscribe to IRS Newswire to receive news releases of the quarterly interest rates, and IRS GuideWire to receive emails with a link to the revenue 

rulings in which the quarterly interest rates are published by going to www.irs.gov/uac/e-news-subscriptions-2.

Schedule A (Form 8804) 2019