OMB No. 1545-1668 Return of U.S. Persons With Respect to

Certain Foreign Partnerships Form 8865

Department of the Treasury Information furnished for the foreign partnership’s tax year

Internal Revenue Service

Name of person filing this return Filer’s identifying number

Filer’s address (if you are not filing this form with your tax return) A Category of filer (see Categories of Filers in the instructions and check applicable box(es)):

1234

Filer’s tax year beginning , 20 , and ending , 20

Important: All information must be in English. All amounts must be in U.S. dollars unless otherwise indicated.

F1 Name and address of foreign partnership 2 EIN (if any)

3 Country under whose laws organized

Principal business activity 7 Principal business activity

code number

Date of organization 5 Principal place of business 6

1

G Provide the following information for the foreign partnership’s tax year:

Name, address, and identifying number of agent (if any) in the 2 Check if the foreign partnership must file:

United States

Name and address of person(s) with custody of the books and

records of the foreign partnership, and the location of such books

and records, if different

Name and address of foreign partnership’s agent in country of 4

organization, if any

3

For Paperwork Reduction Act Notice, see the separate instructions. Form 8865 (2001)

 Attach to your tax return. See separate instructions.

(4) Check applicable box(es) (1) Name (2) Address (3) Identifying number

Category 1 Category 2

E Information about certain other partners (see instructions)

Cat. No. 25852A

4

Service Center where Form 1065 or 1065-B is filed:

Functional currency and

exchange rate (see instr.)

8

D If filer is a member of a consolidated group but not the parent, enter the following information about the parent:

Name EIN

Form 1042 Form 1065 or 1065-B Form 8804

5 Were any special allocations made by the foreign partnership?  Yes No

6 Number of foreign disregarded entities owned by the partnership (attach list) 

Address

C Filer’s share of liabilities: Nonrecourse $ Qualified nonrecourse financing $ Other $

7 How is this partnership classified under the law of the country in which it is organized? 

Constructive owner

B

Sign Here

Only If You

Are Filing

This Form

Separately

and Not With

Your Tax

Return

Paid

Preparer’s

Use Only

Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my

knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than general partner or limited liability company member) is

based on all information of which preparer has any knowledge.

Signature of general partner or limited liability company member Date

Preparer’s

signature

Check if

self-employed 

Preparer’s SSN or PTIN

Firm’s name (or

yours if self-employed),

address, and ZIP code

EIN 

Phone no. ( )









Date

Attachment

Sequence No. 118

Did the partnership own any separate units within the meaning of Regulations section 1.1503-2(c)(3) or (4)? 

Does this partnership meet both of the following requirements?

● The partnership’s total receipts for the tax year were less than $250,000 and

● The value of the partnership’s total assets at the end of the tax year was less than $600,000.

If “Yes,” do not complete Schedules L, M-1, and M-2.

8

9

Yes No

Yes No  

2001

(see instructions) beginning , 2001, and ending , 20
Total income (loss). Combine lines 3 through 7

Bad debts

Form 8865 (2001) Page 2

Certain Partners of Foreign Partnership (see instructions)

Name Address Identifying number (if any)

Caution: Include only trade or business income and expenses on lines 1a through 22 below. See the instructions for more information.

1a

b

1a Gross receipts or sales

Less returns and allowances 1b 1c

2 Cost of goods sold 2

3 Gross profit. Subtract line 2 from line 1c 3

4 Ordinary income (loss) from other partnerships, estates, and trusts (attach schedule) 4

Income

5 5

7

Net farm profit (loss) (attach Schedule F (Form 1040))

7

8

Other income (loss) (attach schedule)

8

9 Salaries and wages (other than to partners) (less employment credits)

11

10 Guaranteed payments to partners

12

Rent 

12

13

Interest

14 Taxes and licenses 14

13

16a Depreciation (if required, attach Form 4562) 16a

b Less depreciation reported on Schedule A and elsewhere on return 16b

Depletion (Do not deduct oil and gas depletion.) 17

15

18

21

Other deductions (attach schedule)

Deductions (see page 8 of the instructions for limitations)

Total deductions. Add the amounts shown in the far right column for lines 9 through 20

20

Ordinary income (loss) from trade or business activities. Subtract line 21 from line 8

17

22

10

9

Affiliation Schedule. List all partnerships (foreign or domestic) in which the foreign partnership

owns a direct interest or indirectly owns a 10% interest.

EIN

(if any) Name Address

6 Net gain (loss) from Form 4797, Part II, line 18 6

11 Repairs and maintenance

Retirement plans, etc.

19 Employee benefit programs

20

21

22

15

18

19

Schedule A-2

Check if

foreign

person

Check if

foreign

partnership

Total ordinary

income or loss

Does the partnership have any other foreign person as a direct partner? Yes No

Constructive Ownership of Partnership Interest. Check the boxes that apply to the filer. If you

check box b, enter the name, address, and U.S. taxpayer identifying number (if any) of the

person(s) whose interest you constructively own. See instructions.

Name Address Identifying number (if any)

Schedule A

Check if

direct

partner

Schedule A-1

a Owns a direct interest b Owns a constructive interest

Check if

foreign

person

Schedule B Income Statement—Trade or Business Income

Form 8865 (2001)

16c
Form 8865 (2001) Page 3

Short-Term Capital Gains and Losses—Assets Held One Year or Less

(c) Date sold

(month, day, year)

(b) Date acquired

(month, day, year)

(d) Sales price

(see instructions)

(e) Cost or other basis

(see instructions)

(a) Description of property

(e.g., 100 shares

of “Z” Co.)

1

2 Short-term capital gain from installment sales from Form 6252, line 26 or 37

4 Partnership’s share of net short-term capital gain (loss), including specially allocated

short-term capital gains (losses), from other partnerships, estates, and trusts

5

Long-Term Capital Gains and Losses—Assets Held More Than One Year

6

7 Long-term capital gain from installment sales from Form 6252, line 26 or 37

Partnership’s share of net long-term capital gain (loss), including specially allocated

long-term capital gains (losses), from other partnerships, estates, and trusts

9

10 Capital gain distributions

Combine lines 6 through 10 in column (g). Enter here and on Schedule K,

line 4e(2) or 7

11

Part I

Part II

3

4

5

8

9

10

11

2

3 Short-term capital gain (loss) from like-kind exchanges from Form 8824

8 Long-term capital gain (loss) from like-kind exchanges from Form 8824

7

(c) Date sold

(month, day, year)

(b) Date acquired

(month, day, year)

(d) Sales price

(see instructions)

(g) 28% rate gain

or (loss)

*(see instr. below)

(e) Cost or other basis

(see instructions)

(a) Description of property

(e.g., 100 shares

of “Z” Co.)

(f) Gain or (loss)

((d) minus (e))

(f) Gain or (loss)

((d) minus (e))

Net short-term capital gain or (loss). Combine lines 1 through 4 in column (f).

Enter here and on Form 8865, Schedule K, line 4d or 7

Net long-term capital gain or (loss). Combine lines 6 through 10 in column (f).

Enter here and on Form 8865, Schedule K, line 4e(1) or 7

12

12

*28% rate gain or (loss) includes all “collectibles gains and losses” (as defined in the instructions).

Schedule D Capital Gains and Losses

Form 8865 (2001)
Form 8865 (2001) Page 4

Partners’ Shares of Income, Credits, Deductions, etc.

(a) Distributive share items

1 Ordinary income (loss) from trade or business activities (enter from Schedule B, line 22)

2 Net income (loss) from rental real estate activities (attach Form 8825) 

Net income (loss) from other rental activities. Subtract line 3b from line 3a

4 Portfolio income (loss):

b Ordinary dividends 4b

c Royalty income 4c

Income (Loss)

d Net short-term capital gain (loss) 4d

e Net long-term capital gain (loss)

Other portfolio income (loss) 4f f (attach schedule)

5 Guaranteed payments to partners 5

6 Net section 1231 gain (loss) (other than due to casualty or theft) (attach Form 4797) 6

7 Other income (loss) (attach schedule) 7

8 Charitable contributions (attach schedule) 8

9 Section 179 expense deduction 9

10 Deductions related to portfolio income (itemize) 10

Deductions

11 Other deductions (attach schedule) 11

14a Interest expense on investment debts 14a

14b(1) b (1) Investment income included on lines 4a, 4b, 4c, and 4f above

InvestmentInterest

(2) Investment expenses included on line 10 above 14b(2)

12a Low-income housing credit:

Credits

13 Other credits 13

16a 16a

b 16b

16c

Depreciation adjustment on property placed in service after 1986

c

d

Depletion (other than oil and gas)

Gross income from oil, gas, and geothermal properties 16d(1) (1)

e

(2) Deductions allocable to oil, gas, and geothermal properties 16d(2)

Adjustments and

Tax Preference

Items

Other adjustments and tax preference items (attach schedule)

Adjusted gain or loss

16e

a Interest income

(2) 28% rate gain (loss)  (3) Qualified 5-year gain 

1

2

3c

4a

4e(1)

Schedule K

(1) From partnerships to which section 42(j)(5) applies

(2) Other than on line 12a(1)

b Qualified rehabilitation expenditures related to rental real estate activities (attach Form

3468) 

c Credits (other than credits shown on lines 12a and 12b) related to rental real estate

activities 

d Credits related to other rental activities

15a 15a

b 15b

15c

Net earnings (loss) from self-employment

c Gross nonfarm income

Gross farming or fishing income

12a(1)

12a(2)

12b

12c

12d

SelfEmployment

3a

3b

3a

b

c

Gross income from other rental activities

Expenses from other rental activities (attach schedule)

(b) Total amount

Form 8865 (2001)

(1)
Form 8865 (2001) Page 5

Balance Sheets per Books (Not required if Question G9, page 1, is answered “Yes.”)

Beginning of tax year End of tax year Assets

1 Cash

2a Trade notes and accounts receivable

b Less allowance for bad debts

3 Inventories

4

5

6 Other current assets (attach schedule)

Tax-exempt securities

7 Mortgage and real estate loans

8 Other investments (attach schedule)

9a Buildings and other depreciable assets

10a

Less accumulated depreciation

11

Depletable assets

b

Less accumulated depletion

12a

Land (net of any amortization)

13

Intangible assets (amortizable only)

Less accumulated amortization

Other assets (attach schedule)

b

14 Total assets

15

Liabilities and Capital

Accounts payable

Other current liabilities (attach schedule)

Other liabilities (attach schedule)

Partners’ capital accounts

Total liabilities and capital

16

17

18

20

All nonrecourse loans

19

Schedule L

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

U.S. government obligations

b

Mortgages, notes, bonds payable in less than 1 year

Mortgages, notes, bonds payable in 1 year or more

21

22

Schedule K (continued)

18b

24

Section 59(e)(2) expenditures: a Type  b Amount 

Other

23

Other items and amounts required to be reported separately to partners (attach

schedule)

18

19

20

Tax-exempt interest income

Other tax-exempt income

Nondeductible expenses

19

20

21

Distributions of money (cash and marketable securities)

Distributions of property other than money

22

23

21

22

e

f

Name of foreign country or U.S. possession 

Gross income sourced at partner level

Foreign gross income sourced at partnership level:

Deductions allocated and apportioned at partner level:

Deductions allocated and apportioned at partnership level to foreign source income:

Total foreign taxes (check one):  Paid Accrued

17a

Foreign Taxes

c

d

g

(1)

(2) Listed categories (attach schedule)

Passive 

(3) General limitation

(1) Interest expense

(2) Other 

(1)

(2) Listed categories (attach schedule)

Passive 

(3) General limitation

17c

17d(1)

17d(2)

17d(3)

17f(1)

17f(2)

17f(3)

17e(1)

17e(2)

h Reduction in taxes available for credit (attach schedule)

17g

Form 8865 (2001)

(a) Distributive share items (b) Total amount

17h

b Gross income from all sources 17b
Form 8865 (2001) Page 6

Analysis of Partners’ Capital Accounts (Not required if Question G9, page 1, is answered “Yes.”)

1 Balance at beginning of year 6 Distributions: a Cash

Net income (loss) per books

2

Other increases (itemize):

3

b Property

7 Other decreases (itemize):

8 Add lines 6 and 7

5

9

Add lines 1 through 4

Balance at end of year. Subtract

line 8 from line 5

4

Capital contributed during year

Balance Sheets for Interest Allocation

1 Total U.S. assets

2 Total foreign assets:

Listed categories (attach schedule) 

Passive income category

General limitation income category

(a)

Beginning of

tax year

(b)

End of

tax year

Reconciliation of Income (Loss) per Books With Income (Loss) per Return (Not required if

Question G9, page 1, is answered “Yes.”)

a

Net income (loss) per books

Income included on Schedule K,

lines 1 through 4, 6, and 7, not

recorded on books this year

(itemize): 

b

Schedule M-1

2

1

c

Guaranteed payments (other

than health insurance)

Expenses recorded on books

this year not included on

Schedule K, lines 1 through 11,

14a, 17g, and 18b (itemize):

Depreciation $

Travel and entertainment $

Add lines 1 through 4

3

4

a

b

5

Income recorded on books this

year not included on Schedule K,

lines 1 through 7 (itemize):

6

a Tax-exempt interest $

Deductions included on Schedule

K, lines 1 through 11, 14a, 17g,

and 18b, not charged against

book income this year (itemize):

a Depreciation $

Add lines 6 and 7

Income (loss). Subtract line 8

from line 5

7

8

9

Schedule M-2

Schedule M

Form 8865 (2001)
Important: Complete a separate Form 8865 and Schedule N for each controlled foreign partnership. Enter the totals for each type of

transaction that occurred between the foreign partnership and the persons listed in columns (a) through (d).

(b) Any domestic

corporation or partnership

controlling or controlled

by the U.S. person filing

this return

Transactions

of

foreign partnership

(a) U.S. person

filing this return

(d) Any U.S. person with a

10% or more direct interest

in the controlled foreign

partnership (other than the

U.S. person filing this return)

(c) Any other foreign

corporation or partnership

controlling or controlled

by the U.S. person filing

this return

1 Sales of inventory

2 Sales of property rights

(patents, trademarks, etc.)

Compensation received for

technical, managerial, engineering,

construction, or like services

3

4 Commissions received

5 Rents, royalties, and license

fees received

6 Distributions received

7 Interest received

8

Purchases of inventory

Purchases of tangible property

other than inventory

10

11

Purchases of property rights

(patents, trademarks, etc.)

Compensation paid for

technical, managerial, engineering,

construction, or like services

12

13

14 Commissions paid

Rents, royalties, and license

fees paid

Distributions paid

15

16

Interest paid

18

9

17

19 Add lines 10 through 18

Add lines 1 through 8

Amounts loaned (enter the

maximum loan balance

during the year) — see

instructions

Amounts borrowed (enter

the maximum loan balance

during the year) — see

instructions

Other

Other

20

21

Form 8865 (2001) Page 7

Schedule N Transactions Between Controlled Foreign Partnership and Partners or Other Related Entities

Form 8865 (2001)