IRS Form 8865 Schedule G "Statement of Application of the Gain Deferral Method Under Section 721(C)"

What Is IRS Form 8865 Schedule G?

This is a tax form that was released by the Internal Revenue Service (IRS) - a subdivision of the U.S. Department of the Treasury on November 1, 2018. As of today, no separate filing guidelines for the form are provided by the IRS.

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SCHEDULE G
Statement of Application of the Gain Deferral Method
(Form 8865)
Under Section 721(c)
OMB No. 1545-1668
(November 2018)
Attach to Form 8865. See the Instructions for Form 8865.
Department of the Treasury
Go to www.irs.gov/Form8865 for instructions and the latest information.
Internal Revenue Service
Name of person filing Form 8865
Filer’s identification number
Name of partnership
EIN (if any)
Reference ID number (see instructions)
Successor
partnership
Name of U.S. transferor (see instructions)
Filing year: (see instructions)
Successor
U.S. transferor
Tax year of gain deferral contribution
Annual reporting
Part I
Section 721(c) Property (see instructions)
1.
2.
3.
4.
5.
6. On the date of contribution
7. Events
Tax year of
Description of property
Recovery
Section
Effectively
(a)
(b)
(c)
(a)
(b)
(c)
(d)
(e)
contribution
period
197(f)(9)
connected
Fair market
Basis
Built-in gain
Acceleration
Termination
Successor
Tax
Section
property
income
value
(including
disposition of
367 transfer
property
partial
a portion of
acceleration
partnership
event)
interest
1
2
3
4
From Part I additional
statement(s), if any
4a
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)
(a)
(b)
(c)
(d)
(e)
Part I,
Remaining built‐in gain at
Remaining built‐in gain at
Remedial income allocated
Gain recognized
Gain recognized
line
beginning of tax year
end of tax year
to U.S. transferor
due to acceleration event
due to section 367 transfer
number
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)
SCHEDULE G
Statement of Application of the Gain Deferral Method
(Form 8865)
Under Section 721(c)
OMB No. 1545-1668
(November 2018)
Attach to Form 8865. See the Instructions for Form 8865.
Department of the Treasury
Go to www.irs.gov/Form8865 for instructions and the latest information.
Internal Revenue Service
Name of person filing Form 8865
Filer’s identification number
Name of partnership
EIN (if any)
Reference ID number (see instructions)
Successor
partnership
Name of U.S. transferor (see instructions)
Filing year: (see instructions)
Successor
U.S. transferor
Tax year of gain deferral contribution
Annual reporting
Part I
Section 721(c) Property (see instructions)
1.
2.
3.
4.
5.
6. On the date of contribution
7. Events
Tax year of
Description of property
Recovery
Section
Effectively
(a)
(b)
(c)
(a)
(b)
(c)
(d)
(e)
contribution
period
197(f)(9)
connected
Fair market
Basis
Built-in gain
Acceleration
Termination
Successor
Tax
Section
property
income
value
(including
disposition of
367 transfer
property
partial
a portion of
acceleration
partnership
event)
interest
1
2
3
4
From Part I additional
statement(s), if any
4a
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)
(a)
(b)
(c)
(d)
(e)
Part I,
Remaining built‐in gain at
Remaining built‐in gain at
Remedial income allocated
Gain recognized
Gain recognized
line
beginning of tax year
end of tax year
to U.S. transferor
due to acceleration event
due to section 367 transfer
number
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)
2
Schedule G (Form 8865) (11-2018)
Page
Part III
Allocation Percentages of Partnership Items With Respect to Section 721(c) Property (see instructions)
1. Income
2. Gain
3. Deduction
4. Loss
(a)
(b)
(c)
(a)
(b)
(c)
(a)
(b)
(c)
(a)
(b)
(c)
Part I,
U.S.
Related domestic
Related foreign
U.S.
Related domestic
Related foreign
U.S.
Related domestic
Related foreign
U.S.
Related domestic
Related foreign
line
transferor
partners
partners
transferor
partners
partners
transferor
partners
partners
transferor
partners
partners
number
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,
(a)
(b)
(a)
(b)
(a)
(b)
(a)
(b)
line
Book
Tax
Book
Tax
Book
Tax
Book
Tax
number
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? .
.
.
.
.
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.
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.
.
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.
.
.
.
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
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?
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
5
Temporary Regulations section 1.721(c)‐5T(e))?
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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 .
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6a
b Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed?
6b
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.
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 .
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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)
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7b
Part VI
Supplemental Information (see instructions)
Schedule G (Form 8865) (11-2018)
Page of 2