Federal List of Foreign Partner Interests in Partnerships

List of Foreign Partner Interests in Partnerships
2023 Schedule P (Form 1120-F)
SCHEDULE P
(Form 1120-F)
Department of the Treasury
Internal Revenue Service

2023

Attach to Form 1120-F.
Go to www.irs.gov/Form1120F for instructions and the latest information.

Employer identification number (EIN)

Name of corporation (foreign partner)

Part I

OMB No. 1545-0123

List of Foreign Partner Interests in Partnerships

List of Foreign Partner’s Interests in Partnerships
(a) Name of partnership

(b) Address

(c) EIN

(d) For each partnership interest, is the
foreign corporation’s distributive share
ECI, or treated as ECI, in whole or in part,
with a U.S. trade or business determined
under section 875 (see instructions)?

A
B
C
D

Yes

No

Yes

No

Yes

No

Yes

No

Note: If the corporation has more than 4 partnership interests, continue on a separate page. See instructions.

Part II

Summary of Foreign Partner’s Income and Expenses From Schedule K-3 (Form 1065)
Schedules K-3
A

1

Total gross income. Enter the amount
from Schedule K-3, Part X, Section 1,
line 21, column (a) . . . . . . .

2

Gross ECI—Partnership determination.
Enter the sum of Schedule K-3, Part X,
Section 1, line 21, column (c) plus
column (d) . . . . . . . . .

3

Gross ECI—Partner determination.
Enter all applicable amounts from
Schedule K-3, Part X, Section 1,
column (b) (see instructions) . . .

4

Total deductions and losses. Enter
the amount from Schedule K-3, Part
X, Section 2, line 24, column (a) . .

5

Total
deductions
and
losses
deductible against gross ECI—
Partnership determination. Enter the
sum of Schedule K-3, Part X, Section
2, line 24, column (c) plus column (d)

6

Total
deductions
and
losses
deductible against gross ECI—Partner
determination. Enter all applicable
amounts from Schedule K-3, Part X,
Section 2, column (b) (see instructions)

7

Interest expense directly allocable
under Regulations section 1.882-5(a)
(1)(ii)(B). (Note: Include the line 7 total
on Schedule I, line 22.) . . . . .

8

Interest expense on U.S. booked
liabilities
as
described
under
Regulations section 1.882-5(d)(2)(vii).
Enter the amount from Schedule K-3,
Part X, Section 2, line 7, column (b).
Include the line 8 total on Schedule I,
line 9, column (b) . . . . . . .

B

For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.

C

Cat. No. 49677Z

D

Total

Schedule P (Form 1120-F) 2023

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Schedule P (Form 1120-F) 2023

Part III

Foreign Partner’s Average Outside Basis Under Regulations sections 1.882-5(b) and 1.884-1(d)(3)
Schedules K-3
A

9

Section 705 outside basis .

.

.

B

C

D

Total

.

10a Partner’s liabilities included in outside
basis under section 752 that give rise
to directly allocable interest expense
under Regulations section 1.882-5(a)
(1)(ii)(B) . . . . . . . . . .
b All other liabilities included in partner’s
outside basis under section 752 . .
c Add lines 10a and 10b .

.

.

.

.

d Subtract line 10c from line 9

.

.

.

11

Partner’s liabilities under Regulations
section 1.884-1(d)(3)(vi). (Note: Enter
the portion of the line 11 total on
Schedule I, line 8, column (b) that
represents U.S. booked liabilities
under Regulations section 1.882-5(d).)

12

Partner’s outside basis under
Regulations section 1.884-1(d)(3)
(vi). Add lines 10d and 11 . . . .

13

Partner’s outside basis allocable to
ECI under Regulations sections
1.884-1(d)(3)(i) and 1.882-5. (Note:
The line 13 total should generally be
entered on Schedule I, line 5, column
(b). However, see the instructions for
Schedule I, line 5, column (b) before
entering an amount on that line.) . .

14

Check either the “income” box or the
“asset” box to indicate the allocation
method used on line 13 (see
instructions) . . . . . . . .

Income

Income

Income

Income

Asset

Asset

Asset

Asset
Schedule P (Form 1120-F) 2023

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Schedule P (Form 1120-F) 2023

Employer identification number (EIN)

Name of corporation (foreign partner)

Part IV

Foreign Partner’s Interests in Partnerships Transferred During Tax Year
(a) Enter the letter of the row in Part I
that corresponds to the partnership
whose interest was transferred.
See instructions.

(b)(1) Percentage
interest transferred

(b)(2) Units transferred

(c) Date acquired
(Mo., Day, Yr.)

(d) Date transferred
(Mo., Day, Yr.)

(i)
(ii)
(iii)
(iv)
Note: If the corporation transferred more than four partnership interests, continue on a separate page. See instructions.

Part V

Foreign Partner’s Gain or Loss on Transfer of Partnership Interests
Partnership Interest Transferred (see instructions)
(i)

(ii)

(iii)

(iv)

1 Amount realized on transfer of partnership interest
2 Section 705 outside basis . . . . . . . .
3 Total outside gain (loss) on transfer of
partnership interest. Subtract line 2 from line 1

.
.

4 Total outside ordinary gain (loss) that would be
recognized on the deemed sale of section 751
property. Enter amount from Schedule K-3 (Form
1065), Part XIII, line 1 . . . . . . . . . .
5 Total outside capital gain (loss) related to the
transfer of the partnership interest. Subtract line
4 from line 3 . . . . . . . . . . . . .
6 Aggregate effectively connected ordinary gain
(loss) that would be recognized on the deemed
sale of section 751 property. Enter amount from
Schedule K-3 (Form 1065), Part XIII, line 2 . . .
7 Aggregate effectively connected capital gain
(loss) that would be recognized on the deemed
sale of non-section 751 property. Enter amount
from Schedule K-3 (Form 1065), Part XIII, line 3 .
8 Recognized effectively connected ordinary gain
(loss). Enter the smaller of line 4 or line 6. See
instructions . . . . . . . . . . . . .
9 Recognized effectively connected capital gain
(loss). Enter the smaller of line 5 or line 7. See
instructions . . . . . . . . . . . . .
10 Gain (loss) that would be recognized under
section 897(g) on the deemed sale of U.S. real
property interests. Enter amount from Schedule
K-3 (Form 1065), Part XIII, line 7. See instructions .
Schedule P (Form 1120-F) 2023