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US ownership of a foreign partnership: Form 8865
A US person with an interest in a foreign partnership may have Form 8865 reporting because of ownership, control, a contribution, a transfer or an acquisition. The filing category must be determined from the complete ownership and transaction history.
Who it may apply to
US persons who own, acquire, transfer an interest in, contribute property to, control or have significant reporting relationships with a non-US partnership.
Records to collect
Partnership agreement, ownership ledger, contribution and transfer documents, financial statements, capital accounts, related-party activity, foreign returns and previous Form 8865 filings.
Filing and decision points
Review the filer category, attribution, acquisition and transfer events, required schedules, book-to-tax data and whether a foreign corporation or branch form may instead apply.
Common mistakes
Treating an LLC label as conclusive, omitting a capital contribution, using net income only instead of balance-sheet data, or overlooking family ownership attribution.
Official sources
Reviewed by Gurleen Kaur, CPA (Washington State). Reviewed September 7, 2026.