SCHEDULE G 

(Form 8865)

(November 2018) 

Department of the Treasury 

Internal Revenue Service 

Statement of Application of the Gain Deferral Method 

Under Section 721(c)

▶ 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 person filing Form 8865 Filer’s identification number

Name of partnership EIN (if any) Reference ID number (see instructions)

Name of U.S. transferor (see instructions) Filing year: (see instructions)

Tax year of gain deferral contribution Annual reporting

Part I Section 721(c) Property (see instructions)

1. 

Tax year of 

contribution

2. 

Description of property

3. 

Recovery 

period

4.

Section 

197(f)(9) 

property

5. 

Effectively 

connected 

income 

property

6. On the date of contribution

(a)

Fair market 

value

(b)

Basis 

(c)

Built-in gain 

7. Events

(a) 

Acceleration 

(including 

partial 

acceleration 

event)

(b) 

Termination

(c) 

Successor

(d) 

Tax 

disposition of 

a portion of 

partnership 

interest

(e) 

Section 

367 transfer

 

1

2

3

4

4a

From Part I additional 

statement(s), if any

Do the tiered partnership rules of Temporary Regulations section 1.721(c)‐3T(d) apply to this partnership? See instructions . . . . . . . . . . . Yes No 

Part II Remaining Built-in Gain, Remedial Income, and Gain Recognition (see instructions)

Part I, 

line 

number

(a)

Remaining built‐in gain at 

beginning of tax year

(b) 

Remaining built‐in gain at 

end of tax year 

(c) 

Remedial income allocated 

to U.S. transferor 

(d) 

Gain recognized 

due to acceleration event 

(e) 

Gain recognized 

due to section 367 transfer

1

2

3

4

Total*

* Total must include any amounts included on an attached statement. See instructions.

For Paperwork Reduction Act Notice, see the Instructions for Form 8865. Cat. No. 71017D Schedule G (Form 8865) (11-2018)

Successor 

partnership

Successor 

U.S. transferor
Schedule G (Form 8865) (11-2018) Page 2 

Part III Allocation Percentages of Partnership Items With Respect to Section 721(c) Property (see instructions) 

Part I, 

line 

number

1. Income

(a) 

U.S. 

transferor

(b) 

Related domestic 

partners

(c)

Related foreign 

partners

2. Gain

(a) 

U.S. 

transferor

(b)

Related domestic 

partners

(c) 

Related foreign 

partners

3. Deduction

(a) 

U.S. 

transferor

(b)

Related domestic 

partners

(c) 

Related foreign 

partners

4. Loss

(a) 

U.S. 

transferor

(b)

Related domestic 

partners

(c) 

Related foreign 

partners 

1 % % % % % % % % % % % %

2 % % % % % % % % % % % %

3 % % % % % % % % % % % %

4 % % % % % % % % % % % %

Part IV Allocation of Items to U.S. Transferor With Respect to Section 721(c) Property (see instructions) 

1. Income 2. Gain 3. Deduction 4. Loss

Part I, 

line 

number

(a) 

Book 

(b) 

Tax

(a) 

Book 

(b) 

Tax

(a) 

Book 

(b) 

Tax

(a) 

Book 

(b) 

Tax

1

2

3

4

Part V Additional Information (see instructions). If “Yes” to any question 1 through 6b below, complete Schedule H. Yes No

1 During the tax year, did an acceleration event or partial acceleration event (as described in Temporary Regulations section 1.721(c)‐4T or Temporary 

Regulations section 1.721(c)‐5T(d)) occur with respect to one or more section 721(c) properties? . . . . . . . . . . . . . . . . . . . 1

2 During the tax year, did a termination event (as described in Temporary Regulations section 1.721(c)‐5T(b)) occur with respect to one or more section 721(c) properties? 2

3 During the tax year, did a successor event (as described in Temporary Regulations section 1.721(c)‐5T(c)) occur with respect to one or more section 721(c) properties? 3

4 During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Temporary Regulations section 1.721(c)‐5T(f))? 4

5 During the tax year, was there a direct or indirect transfer of section 721(c) property to a foreign corporation subject to section 367 (as described in 

Temporary Regulations section 1.721(c)‐5T(e))? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

6 a Was any additional section 721(c) property contributed to the section 721(c) partnership during the tax year? If “Yes,” complete Schedule O, include each 

contributed property in Part I above and information with respect to the property in Parts II–IV above, and complete line 6b . . . . . . . . . . 6a

b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed? . . . . . . . . . . . 6b

7 a Was a copy of the waiver of treaty benefits (as described in Temporary Regulations section 1.721(c)‐6T(b)(2)(iii)) filed with respect to each section 721(c) 

property contribution to the section 721(c) partnership? If “Yes,” complete line 7b . . . . . . . . . . . . . . . . . . . . . . . . 7a

b With respect to each section 721(c) property for which a waiver of treaty benefits was filed, after exercising reasonable diligence, has the U.S. transferor 

determined that to the best of its knowledge and belief, all income from section 721(c) property allocated to the partners during the tax year remained 

subject to taxation as income effectively connected with the conduct of a trade or business within the United States (under either section 871 or 882) for 

all direct or indirect partners that are related foreign persons with respect to the U.S. transferor (regardless of whether any such partner was a partner at 

the time of the gain deferral contribution), and that neither the section 721(c) partnership nor any such partner has made any claim under an income tax 

convention to an exemption from U.S. income tax or a reduced rate of U.S. income taxation on income derived from the use of section 721(c) property? 

See Temporary Regulations section 1.721‐6T(b)(3)(vi) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7b

Part VI Supplemental Information (see instructions) 

Schedule G (Form 8865) (11-2018)