U.S. Income Tax Compliance
U.S. Income Tax Compliance
U.S. Income Tax Compliance
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Form 8865<br />
• Who must file?<br />
– Category 1 - A U.S. person who controlled foreign<br />
partnership at any time during the partnership’s tax<br />
year. Control of a partnership is ownership of more<br />
than a 50% interest in the partnership.<br />
– Category 2 - A U.S. person who at any time during<br />
the partnership’s tax year owned 10% or more in the<br />
partnership while the partnership was controlled by<br />
U.S. persons, each owning at least 10% interests.<br />
• If the foreign partnership had a Category 1 filer at any time<br />
during that tax year, no person will be considered a Category<br />
2 filer.
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