Instructions for IRS Form 8804 Schedule A "Penalty for Underpayment of Estimated Section 1446 Tax for Partnerships"

This document contains official instructions for IRS Form 8804 Schedule A, Penalty for Underpayment of Estimated Section 1446 Tax for Partnerships - a tax form released and collected by the Internal Revenue Service (IRS), a subdivision of the U.S. Department of the Treasury. An up-to-date fillable IRS Form 8804 Schedule A is available for download through this link.

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Download Instructions for IRS Form 8804 Schedule A "Penalty for Underpayment of Estimated Section 1446 Tax for Partnerships"

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2019
Department of the Treasury
Internal Revenue Service
Instructions for Schedule A
(Form 8804)
Penalty for Underpayment of Estimated Section 1446 Tax for Partnerships
on lines 4d, 4h, 4l, 4p, and 4t of its 2019
Complete Parts IV through VI as
Section references are to the Internal Revenue
Code unless otherwise noted.
Form 8804; and (2) the tax year was for
appropriate if the partnership uses the
a full 12 months. See the instructions for
adjusted seasonal installment method
Future Developments
line
2, later, for more details.
and/or the annualized income
installment method.
For the latest information about
In these instructions, “Form 8804”
developments related to Schedule A
generally refers to the partnership's
Specific Instructions
(Form 8804) and its instructions, such
original Form 8804. However, an
as legislation enacted after they were
amended Form 8804 is considered the
Part I. Reasons for Filing
published, go to IRS.gov/Form8804.
original Form 8804 if the amended Form
8804 is filed by the due date (including
General Instructions
Adjusted seasonal installment meth-
extensions) of the original Form 8804.
od and/or annualized income install-
Also, for purposes of determining a
ment method. If the partnership's
Purpose of Form
required installment, if an amended
income varied during the year because,
Form 8804 is filed for the prior tax year,
Partnerships that have effectively
for example, it operated its business on
then “prior tax year” includes the
connected taxable income (ECTI)
a seasonal basis, it may be able to
amended Form 8804, but only if the
allocable to foreign partners use
lower or eliminate the amount of one or
amended Form 8804 is filed before the
Schedule A (Form 8804) to determine:
more required installments by using the
applicable installment due date.
Whether they are subject to the
adjusted seasonal installment method
penalty for underpayment of estimated
The penalty is figured separately for
and/or the annualized income
tax and, if so,
each installment due date. Therefore,
installment method.
The amount of the underpayment
the partnership may owe a penalty for
Example. A ski shop, which
penalty.
an earlier due date even if it paid
receives most of its income during the
enough tax later to make up the
Who Must File
winter months, may benefit from using
underpayment. This is true even if the
one or both of these methods to figure
partnership is due a refund when its
Generally, the partnership doesn’t have
its required installments. The
return is filed. However, the partnership
to file this schedule because the IRS will
annualized income installment or
may be able to reduce or eliminate the
figure the amount of the penalty and
adjusted seasonal installment may be
penalty by using the annualized income
notify the partnership of any amount
less than the required installment under
installment method or the adjusted
due. However, even if the partnership
the current year safe harbor (increased
seasonal installment method. See the
doesn’t owe a penalty, complete and
by any reduction recaptured under
instructions for Parts IV and V for
attach this schedule to the partnership's
section 6655(e)(1)(B)) for one or more
details.
Form 8804 if the Part II, line 1, amount
due dates. Using one or both of these
on page 1 is $500 or more and any of
methods may reduce or eliminate the
Exception to the Penalty
the following apply.
penalty for those due dates.
A partnership won’t have to pay a
1. The adjusted seasonal
Use Parts IV through VI of
penalty if the tax shown on line 5f of its
installment method is used.
Schedule A (Form 8804) to figure one or
2019 Form 8804 is less than $500.
2. The annualized income
more required installments. If Parts IV
installment method is used.
through VI are used for any payment
How To Use Schedule A
due date, those Parts must be used for
Who Must Pay the
Complete this schedule as follows.
all subsequent payment due dates. To
Underpayment Penalty
arrive at the amount of each required
Check one or both of the boxes in
Part I that apply. If the partnership
installment, Part VI uses the smallest of:
Generally, a partnership is subject to the
checks a box in Part I, attach
The adjusted seasonal installment (if
penalty if it didn’t timely pay in
applicable),
Schedule A (Form 8804) to Form 8804.
installments at least the smaller of:
Be sure to check the box on Form 8804,
The annualized income installment (if
1. The tax shown on line 5f of its
line 8.
applicable), or
2019 Form 8804; or
The current year safe harbor
If the total section 1446 tax, shown on
2. The total section 1446 tax that
Part II, line 1, is $500 or more, complete
(increased by any reduction recaptured
would have been due for 2018, without
the rest of page 1 to determine the
under section 6655(e)(1)(B)).
regard to reductions for certified foreign
underpayment for any of the installment
Follow the steps below to determine
partner-level items, on the ECTI
due dates.
which parts of the form have to be
allocable to foreign partners for 2018,
If there is an underpayment on line 12
completed.
provided that (1) this amount is at least
(column (a), (b), (c), or (d)), go to Part
50% of the sum of the amounts shown
VII to figure the penalty.
Jun 21, 2019
Cat. No. 36325U
2019
Department of the Treasury
Internal Revenue Service
Instructions for Schedule A
(Form 8804)
Penalty for Underpayment of Estimated Section 1446 Tax for Partnerships
on lines 4d, 4h, 4l, 4p, and 4t of its 2019
Complete Parts IV through VI as
Section references are to the Internal Revenue
Code unless otherwise noted.
Form 8804; and (2) the tax year was for
appropriate if the partnership uses the
a full 12 months. See the instructions for
adjusted seasonal installment method
Future Developments
line
2, later, for more details.
and/or the annualized income
installment method.
For the latest information about
In these instructions, “Form 8804”
developments related to Schedule A
generally refers to the partnership's
Specific Instructions
(Form 8804) and its instructions, such
original Form 8804. However, an
as legislation enacted after they were
amended Form 8804 is considered the
Part I. Reasons for Filing
published, go to IRS.gov/Form8804.
original Form 8804 if the amended Form
8804 is filed by the due date (including
General Instructions
Adjusted seasonal installment meth-
extensions) of the original Form 8804.
od and/or annualized income install-
Also, for purposes of determining a
ment method. If the partnership's
Purpose of Form
required installment, if an amended
income varied during the year because,
Form 8804 is filed for the prior tax year,
Partnerships that have effectively
for example, it operated its business on
then “prior tax year” includes the
connected taxable income (ECTI)
a seasonal basis, it may be able to
amended Form 8804, but only if the
allocable to foreign partners use
lower or eliminate the amount of one or
amended Form 8804 is filed before the
Schedule A (Form 8804) to determine:
more required installments by using the
applicable installment due date.
Whether they are subject to the
adjusted seasonal installment method
penalty for underpayment of estimated
The penalty is figured separately for
and/or the annualized income
tax and, if so,
each installment due date. Therefore,
installment method.
The amount of the underpayment
the partnership may owe a penalty for
Example. A ski shop, which
penalty.
an earlier due date even if it paid
receives most of its income during the
enough tax later to make up the
Who Must File
winter months, may benefit from using
underpayment. This is true even if the
one or both of these methods to figure
partnership is due a refund when its
Generally, the partnership doesn’t have
its required installments. The
return is filed. However, the partnership
to file this schedule because the IRS will
annualized income installment or
may be able to reduce or eliminate the
figure the amount of the penalty and
adjusted seasonal installment may be
penalty by using the annualized income
notify the partnership of any amount
less than the required installment under
installment method or the adjusted
due. However, even if the partnership
the current year safe harbor (increased
seasonal installment method. See the
doesn’t owe a penalty, complete and
by any reduction recaptured under
instructions for Parts IV and V for
attach this schedule to the partnership's
section 6655(e)(1)(B)) for one or more
details.
Form 8804 if the Part II, line 1, amount
due dates. Using one or both of these
on page 1 is $500 or more and any of
methods may reduce or eliminate the
Exception to the Penalty
the following apply.
penalty for those due dates.
A partnership won’t have to pay a
1. The adjusted seasonal
Use Parts IV through VI of
penalty if the tax shown on line 5f of its
installment method is used.
Schedule A (Form 8804) to figure one or
2019 Form 8804 is less than $500.
2. The annualized income
more required installments. If Parts IV
installment method is used.
through VI are used for any payment
How To Use Schedule A
due date, those Parts must be used for
Who Must Pay the
Complete this schedule as follows.
all subsequent payment due dates. To
Underpayment Penalty
arrive at the amount of each required
Check one or both of the boxes in
Part I that apply. If the partnership
installment, Part VI uses the smallest of:
Generally, a partnership is subject to the
checks a box in Part I, attach
The adjusted seasonal installment (if
penalty if it didn’t timely pay in
applicable),
Schedule A (Form 8804) to Form 8804.
installments at least the smaller of:
Be sure to check the box on Form 8804,
The annualized income installment (if
1. The tax shown on line 5f of its
line 8.
applicable), or
2019 Form 8804; or
The current year safe harbor
If the total section 1446 tax, shown on
2. The total section 1446 tax that
Part II, line 1, is $500 or more, complete
(increased by any reduction recaptured
would have been due for 2018, without
the rest of page 1 to determine the
under section 6655(e)(1)(B)).
regard to reductions for certified foreign
underpayment for any of the installment
Follow the steps below to determine
partner-level items, on the ECTI
due dates.
which parts of the form have to be
allocable to foreign partners for 2018,
If there is an underpayment on line 12
completed.
provided that (1) this amount is at least
(column (a), (b), (c), or (d)), go to Part
50% of the sum of the amounts shown
VII to figure the penalty.
Jun 21, 2019
Cat. No. 36325U
If the partnership is using only the
and the standard option annualization
under the adjusted seasonal installment
adjusted seasonal installment method,
method. Attach a statement that
method. An extraordinary item includes:
check the applicable box in Part I and
explains the computation.
Any item identified in Regulations
complete Parts IV and VI of Schedule A
section 1.1502-76(b)(2)(ii)(C)(1), (2),
Part III. Figuring the
(Form 8804).
(3), (4), (7), and (8);
If the partnership is using only the
Underpayment
A section 481(a) adjustment; and
annualized income installment method,
Net gain or loss from the disposition
Line 6. Enter the estimated tax
check the applicable box in Part I and
of 25% or more of the fair market value
payments made by the partnership for
complete Parts V and VI of Schedule A
of the partnership's business assets
its tax year as indicated below. Include
(Form 8804).
during the tax year.
any overpayment from line 13 of the
If the partnership is using both
These extraordinary items must be
partnership's 2018 Form 8804 that was
methods, check both of the boxes in
accounted for in the appropriate
credited to the partnership's first
Part I and complete all three parts (Parts
annualization period. However, a
installment period on its 2019 Form
IV through VI) of Schedule A (Form
section 481(a) adjustment (unless the
8804. If an installment is due on a
8804).
partnership makes the alternative
Saturday, Sunday, or legal holiday,
choice under Regulations section
Part II. Current Year and
payments made on the next day that
1.6655-2(f)(3)(ii)(C)) is treated as an
isn’t a Saturday, Sunday, or legal
Prior Year Safe Harbors
extraordinary item occurring on the first
holiday are considered made on the due
day of the tax year in which the item is
Line 2 (prior year safe harbor). Enter
date to the extent the payment is
taken into account in determining ECTI.
the total section 1446 tax that would
applied against that required
For more information regarding
have been due for 2018, without regard
installment.
extraordinary items, see Regulations
to reductions for certified foreign
Also include on line 6 any of the
section 1.6655-2(f)(3)(ii) and the
partner-level items on the ECTI
following.
examples in Regulations section
allocable to foreign partners for 2018.
Section 1446 tax paid or withheld by
1.6655-2(f)(3)(vii). Also see Regulations
The partnership can generally use
another partnership in which the
section 1.6655-3(d)(3).
the prior year safe harbor only if it paid
partnership filing this Schedule A (Form
the required amount using that method
8804) was a partner during the tax year.
De minimis rule. Extraordinary
for each of its installment payments of
See the instructions for Form 8804, lines
items identified above resulting from a
section 1446 tax during the tax year.
6b and 6c, in the Instructions for Forms
particular transaction that totals less
However, see Regulations section
8804, 8805, and 8813.
than $1 million (other than a section
1.1446-3(b)(3)(ii) for an exception. Also,
Section 1445(a) or 1445(e) tax
481(a) adjustment) can be annualized
see the
Note
below. In addition, the
withheld from or paid by the partnership
using the general rules of Regulations
partnership can only use the prior year
filing this Schedule A (Form 8804)
section 1.6655-2(f), or, if the partnership
safe harbor if all of the following apply.
during the tax year for a disposition of a
chooses, can be taken into account
Each installment payment that was
U.S. real property interest. See the
after annualizing the ECTI for the
made during the tax year, when
instructions for Form 8804, lines 6d and
annualization period.
averaged with all prior installment
6e, in the Instructions for Forms 8804,
payments, must have been 25% of the
8805, and 8813.
Part IV. Adjusted Seasonal
partnership's total section 1446 tax
Installment Method
Column (a). Enter payments made by
liability under the prior year safe harbor.
the date on line 4, column (a).
The prior tax year consisted of 12
Note. Part IV doesn't reflect the lower
Columns (b), (c), and (d). Enter
months.
preferential rates permitted under
payments made on or before the date
The partnership timely files (including
Regulations section 1.1446-3(a)(2).
on line 4 for that column and after the
extensions) a U.S. return of partnership
These were omitted because, for most
date on line 4 of the preceding column.
income (for example, Form 1065) for the
taxpayers, the income reported in Part
prior tax year.
IV will be predominantly (or exclusively)
Note. A payment of estimated tax is
The amount of ECTI for the prior tax
ordinary income. If the partnership
applied against unpaid installments in
year isn’t less than 50% of the ECTI
wishes to consider lower preferential
the order in which installments are
shown on the current year Form 8804
rates for Part IV (and if the requirements
required to be paid, regardless of the
that is (or will be) timely filed.
outlined in the third paragraph of the
installment to which the payment
line 31 instructions are met), it must
If the partnership isn’t permitted to
pertains. See the
Example
under
Part
attach a statement which appropriately
use the prior year safe harbor method
VII. Figuring the
Penalty, later.
expands lines 15 and 22 through 25 to
because any of the necessary
Line 12. If any of the columns in line 12
show the applicable special types of
conditions described above isn’t met,
shows an underpayment, complete Part
income or gain and the applicable
skip line 2 and enter on line 3 the
VII to figure the penalty.
percentages (see, for example, lines 33
amount from line 1.
and 34 of this schedule). Also, Part IV,
Note. If the partnership qualifies for and
Parts IV Through VI
lines 15 and 22 through 25, don’t
uses the exception under Regulations
provide the separate entries for
section 1.1446-3(b)(3)(ii) to switch to
Extraordinary items. Generally, under
corporate and non-corporate partners
the standard option annualization
the annualized income installment
necessary to apply the rates on lines
method during the tax year, the
method, extraordinary items must be
25a and 25b. A partnership with
partnership should include on line 2 the
taken into account after annualizing the
corporate and non-corporate partners
total of all installment payments that
ECTI for the annualization period.
completing Part IV must attach a
were made during the tax year under
Similar rules apply in determining ECTI
statement which appropriately expands
both the prior year safe harbor method
-2-
Instructions for Schedule A (Form 8804) (2019)
lines 15 and 22 through 25 to show the
Instructions for Forms 8804, 8805, and
Line 32. Annualization amounts.
amounts allocable to both types of
8813, for additional information.
Enter on line 32, columns (a) through
partners.
(d), respectively, the annualization
Part V. Annualized Income
The partnership can use the adjusted
amounts shown in the table below for
Installment Method
seasonal installment method only if the
the option used for line 30. For example,
partnership's base period percentage
if the partnership elected Option 1, enter
Line 30. Annualization periods. Enter
for any 6 consecutive months of the tax
on line 32 the annualization amounts 6,
on line 30, columns (a) through (d),
year is 70% or more. The base period
3, 1.71429, and 1.2, in columns (a)
respectively, the annualization periods
percentage for any period of 6
through (d), respectively.
for the option listed below. For example,
consecutive months is the average of
if the partnership elected Option 1, enter
the three percentages figured by
1st
2nd
3rd
4th
on line 30 the annualization periods 2, 4,
dividing the ECTI for the corresponding
Install-
Install-
Install-
Install-
7, and 10, in columns (a) through (d),
6-consecutive-month period in each of
ment
ment
ment
ment
respectively.
the 3 preceding tax years by the ECTI
Standard
for each of their respective tax years.
Option
4
4
2
1.33333
Use Option 1 or Option 2 only if
Figure the base period percentage
Option 1
6
3
1.71429
1.2
the partnership elected to do so
!
using the 6-month period in which the
by filing Form 8842, Election To
Option 2
4
2.4
1.5
1.09091
CAUTION
partnership normally receives the
Use Different Annualization Periods for
largest part of its ECTI.
Corporate Estimated Tax, by the due
Lines 33a, 33e, 33i, 33m, and 33q. If
date of the first required installment
Example. An amusement park with
the partnership has extraordinary items
payment. Once made, the election is
a 2019 calendar tax year receives the
that total $1 million or more from a
irrevocable for the particular tax year.
largest part of its taxable income during
particular transaction, or a section
a 6-month period, May through October.
481(a) adjustment, special rules apply.
To figure its base period percentage for
Include these amounts on line 33a, 33e,
1st
2nd
3rd
4th
this 6-month period, the amusement
Install-
Install-
Install-
Install-
33i, 33m, or 33q, depending on the type
park figures its ECTI for each May–
ment
ment
ment
ment
of income against which the item
October period in 2016, 2017, and
Standard
applies, for the appropriate period. Also
2018. It then divides the ECTI for each
Option
3
3
6
9
include on line 33a, 33e, 33i, 33m, or
May–October period by the total ECTI
Option 1
2
4
7
10
33q the de minimis extraordinary items
for that particular tax year. The resulting
Option 2
3
5
8
11
that the partnership chooses to exclude
percentages are 69% (0.69) for May–
from line 31a, 31b, 31c, 31d, or 31e,
October 2016, 74% (0.74) for May–
respectively. See
Extraordinary
items,
Line 31. Enter on lines 31a through
October 2017, and 67% (0.67) for May–
earlier.
31e the ECTI allocable to all foreign
October 2018. Because the average of
If the partnership has included on
partners for the months entered for each
69% (0.69), 74% (0.74), and 67% (0.67)
line 33a, 33e, 33i, 33m, or 33q any of
annualization period in columns (a)
is 70% (0.70), the base period
the items referred to in the previous
through (d) on line 30.
percentage for May–October 2019 is
paragraph, write “EI” and the dollar
70% (0.70). Therefore, the amusement
If the partnership has certain
amount of the item next to the affected
park qualifies for the adjusted seasonal
extraordinary items, special rules apply.
line. Attach a statement which shows
installment method.
Don’t include on line 31a, 31b, 31c, 31d,
the income for that line before the
or 31e the de minimis extraordinary
Line 15. If the partnership has certain
extraordinary item, the amount of the
items that the partnership chooses to
extraordinary items, special rules apply.
extraordinary item, and the net amount.
include on line 33a, 33e, 33i, 33m, or
Don’t include on line 15 the de minimis
Also include an explanation of the item,
33q, respectively. See
Extraordinary
extraordinary items that the partnership
including the authority under which it is
items, earlier.
chooses to include on line 22b. See
being claimed.
Extraordinary
items, earlier.
With respect to lines 31b through
Lines 33b, 33f, 33j, 33n, and 33r.
31e, enter the specified types of income
Line 22b. If the partnership has certain
Enter the reduction amounts for state
allocable to non-corporate partners if (a)
extraordinary items of $1 million or more
and local taxes under Regulations
the partners would be entitled to use a
from a transaction, or a section 481(a)
section 1.1446-6(c)(1)(iii). The netting
preferential rate on such income or gain
adjustment, special rules apply. Include
rules under section 1(h) and Notice
(see Regulations section 1.1446-3(a)
these amounts on line 22b for the
97-59 must be considered in
(2)), and (b) the partnership has
appropriate period. Also include on
determining the category of income the
sufficient documentation to meet the
line 22b the de minimis extraordinary
reduction amounts offset.
requirements of Regulations section
items that the partnership chooses to
1.1446-3(a)(2)(ii).
Lines 33c, 33g, 33k, 33o, and 33s.
exclude from line 15. See
Extraordinary
Enter the reduction amounts resulting
items, earlier.
If the partnership has net ordinary
from certified partner-level items
loss, net short-term capital loss, or net
Line 23. Enter the amount by which
received from foreign partners using
28% rate loss, each net loss should be
line 22c is being reduced for state and
Form 8804-C. See Certification of
netted against the appropriate
local taxes under Regulations section
Deductions and Losses in the
categories of income and gain to
1.1446-6(c)(1)(iii) and for certified
Instructions for Forms 8804, 8805, and
determine the amounts of income and
foreign partner-level items submitted
8813, for additional information. The
gain to be entered on lines 31b, 31c,
using Form 8804-C. See Reductions for
netting rules of section 1(h) and Notice
31d, and 31e, respectively. See section
State and Local Taxes and Certification
97-59 must be considered in
1(h) and Notice 97-59, 1997-45 I.R.B. 7,
of Deductions and Losses in the
for rules for netting gains and losses.
Instructions for Schedule A (Form 8804) (2019)
-3-
determining the category of income the
figured for the period of underpayment
installment to which the payment
reduction amounts offset.
using the underpayment rate
pertains.
determined under section 6621(a)(2).
Example. A partnership underpaid
Part VI. Required
The period of underpayment runs from
the April 15 installment by $1,000. The
Installments
the installment due date to the earlier of
June 15 installment requires a payment
the date the underpayment is actually
of $2,500. On June 11, the partnership
Line 38. Before completing line 38 in
paid or the 15th day of the 3rd month
pays $2,500 for its June 15 installment.
columns (b) through (d), complete lines
after the close of the 2019 tax year (the
However, $1,000 of this payment is
39 through 43 in each of the preceding
15th day of the 6th month if the
applied against the April 15 installment.
columns. For example, complete lines
partnership keeps its books and records
The penalty for the April 15 installment
39 through 43 in column (a) before
outside the United States and Puerto
is figured to June 11 (57 days). The
completing line 38 in column (b).
Rico). For information on obtaining the
remaining $1,500 is applied to the June
interest rate on underpayments denoted
Line 43. For each installment, enter the
15 installment as if it were made on
by an asterisk, see the footnote on
smaller of line 39 or line 42 on line 43.
June 15.
page 5 of the schedule.
Also enter the result on line 5.
If the partnership has made more
A payment of estimated tax is applied
Part VII. Figuring the
than one payment for a required
against unpaid required installments in
installment, attach a separate
Penalty
the order in which installments are
computation for each payment.
required to be paid, regardless of the
Complete Part VII to determine the
amount of the penalty. The penalty is
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would be happy to hear from you. See the instructions for the tax return with which this form is filed.
-4-
Instructions for Schedule A (Form 8804) (2019)
Page of 4