Department of the Treasury 1999 Internal Revenue Service Instructions for Forms 8804, 8805, and 8813 Section references are to the Internal Revenue Code unless otherwise noted.

Paperwork Reduction Act Notice. We ask for the information on these forms to carry partner in any tax year must file Forms out the Internal Revenue laws of the United States. You are required to give us the 8804 and 8805 whether or not information. We need it to ensure that you are complying with these laws and to allow distributions were made during the us to figure and collect the right amount of tax. partnership's tax year. The partnership You are not required to provide the information requested on a form that is subject may designate a person to file the forms. to the Paperwork Reduction Act unless the form displays a valid OMB control number. The partnership, or person it designates, Books or records relating to a form or its instructions must be retained as long as their must file these forms even if the contents may become material in the administration of any Internal Revenue law. partnership has no withholding tax liability Generally, tax returns and return information are confidential, as required by section under section 1446. 6103. Publicly traded partnerships must file The time needed to complete and file these forms will vary depending on individual these forms only if they have elected to circumstances. The estimated average times are: pay section 1446 withholding tax based on effectively connected taxable income Form 8804 8805 8813 allocable to its foreign partners. Those that do not make this election and instead Recordkeeping 59 min. 59 min. 26 min. withhold the tax on distributions to their Learning about the foreign partners should see Publicly law or the form 57 min. 54 min. 49 min. Traded Partnerships on page 4. Preparing the form 31 min. 17 min. 16 min. When To File Copying, assembling, and sending the form to the IRS 20 min. 17 min. 10 min. Forms 8804 and 8805 If you have comments concerning the accuracy of these time estimates or Generally, file on or before the 15th day suggestions for making these forms simpler, we would be happy to hear from you. You of the 4th month following the close of the can write to the Tax Forms Committee, Western Area Distribution Center, Rancho partnership's tax year. However, a Cordova, CA 95743-0001. DO NOT send the tax forms to this address. Instead, see partnership that consists entirely of Where To File below. nonresident alien partners must file on or before the 15th day of the 6th month following the close of the partnership's tax Photographs of Missing effectively connected taxable income and year. Children the total tax credit allowed to the foreign File Forms 8804 and 8805 separately partner for the partnership's tax year. from Form 1065, U.S. Partnership Return The Internal Revenue Service is a proud File a separate Form 8805 for each of Income, and Form 1065-B, U.S. Return partner with the National Center for foreign partner even if no section 1446 of Income for Electing Large Partnerships. Missing and Exploited Children. withholding tax was paid. Attach Copy A If you need more time, you may file Photographs of missing children selected of each Form 8805 to the Form 8804 filed Form 2758, Application for Extension of by the Center may appear in instructions with the IRS. Time To File Certain Excise, Income, on pages that would otherwise be blank. Foreign partners must attach Form Information, and Other Returns, to You can help bring these children home 8805 to their U.S. income tax returns to request an extension of time to file Form by looking at the photographs and calling claim a credit for their shares of the 8804. Generally, an extension will not be 1-800-THE-LOST (1-800-843-5678) if you section 1446 tax withheld by the granted for more than 90 days. If you recognize a child. partnership. A foreign partnership that need more time, file a second Form 2758 receives a Form 8805 should see Tiered for an additional 90-day extension. The General Instructions Partnerships on page 4. Any U.S. total extension may not be for more than person erroneously subjected to the 6 months except for taxpayers who are Purpose of Forms withholding tax would also receive Form abroad. 8805 from a partnership and should Use Forms 8804, 8805, and 8813 to pay attach it to his or her income tax return. Form 8813 and report section 1446 withholding tax Use Form 8813, Partnership File on or before the 15th day of the 4th, based on effectively connected taxable Withholding Tax Payment (Section 1446), 6th, 9th, and 12th months of the income allocable to foreign partners. to pay the withholding tax under section partnership's tax year for U.S. income tax Use Form 8804, Annual Return for 1446 to the United States Treasury. Form purposes. Partnership Withholding Tax (Section 8813 must accompany each payment of 1446), to report the total liability under section 1446 tax made during the Where To File section 1446 for the partnership's tax partnership's tax year. year. Form 8804 is also a transmittal form File Forms 8804, 8805, and 8813 with: for Form(s) 8805. Who Must File Internal Revenue Service Center, Use Form 8805, Foreign Partner's Philadelphia, PA 19255. Information Statement of Section 1446 All partnerships with effectively connected Withholding Tax, to show the amount of gross income allocable to a foreign

Cat. No. 10393W Taxpayer Identifying Number withholding. If a partnership relies in good a properly executed power of attorney, faith on the certification, but it is later provided the power of attorney To insure proper crediting of the determined that the certification was false, accompanies the certification. withholding tax when reporting to the IRS, the partnership will not be held liable for How long to keep the certifications. A a partnership must provide a U.S. payment of the tax, any applicable partnership must keep a certification of taxpayer identifying number (TIN) for penalties, or interest. A certification that nonforeign status until the end of the 5th each foreign partner. The partnership satisfies the requirements of these tax year after the last tax year in which the should notify any of its foreign partners instructions will also satisfy the partnership relied on the certification. without such a number of the necessity requirements for a certificate of Special rule for widely held of obtaining a U.S. identifying number. nonforeign status under section 1445. partnership. In addition to relying on a An individual's identifying number is the Once a partnership learns that the certification of nonforeign status, a widely individual's social security number (SSN) certification is false, it will no longer be held partnership (a partnership that has or individual taxpayer identification entitled to rely on that certification. For more than 200 partners, including a number (ITIN). Any other partner's this purpose, the knowledge of any publicly traded partnership) may rely on identifying number is its U.S. employer general partner will be imputed to the the information provided to it by partners identification number (EIN). partnership to cause a withholding on a Form 1001, Ownership, Exemption, Certain aliens who cannot obtain SSNs liability. The knowledge of one of its or Reduced Rate Certificate; Form W-8, can now apply for ITINs on Form W-7, limited partners will not be imputed to a Certificate of Foreign Status; Form Application for IRS Individual Taxpayer partnership based solely on that partner's W-8BEN, Certificate of Foreign Status of Identification Number. status as a limited partner. For a limited Beneficial Owner for United States Tax liability company or other entity classified Withholding; or Form W-9, Request for Requirement To Make as a partnership for Federal income tax Taxpayer Identification Number and Withholding Tax Payments purposes, any member with authority to Certification. manage or bind the entity is treated as a Also, a widely held partnership may rely A foreign or domestic partnership that has general partner. on a certification under penalties of effectively connected taxable income Also, the partnership will be liable under perjury from a nominee about the allocable to a foreign partner must pay a section 1461 for any failure to pay the nonforeign status of partners owning withholding tax equal to the applicable withholding tax under section 1446 for the partnership interests through the percentage of the effectively connected tax year in which it learned that the nominee. No particular form is required for taxable income that is allocable to its certification is false. However, the this certification, but it should identify the foreign partners. However, this partnership will not be liable for penalties partner for whom the certification is made requirement does not apply to a for failure to make timely payments of and indicate the basis for the certification. partnership treated as a corporation under installments of section 1446 withholding When making a certification, a nominee the general rule of section 7704(a). tax that were due prior to the time it may also rely on a certification of Effectively connected taxable income is learned that the certification was false. nonforeign status or on information defined on page 3. Duration of certification. A partnership provided by Forms 1001, W-8, W-8BEN may rely on a partner's certification of or W-9. A nominee and a partnership may Withholding Agents nonforeign status until the earliest of the not rely on any of those forms after the General partners and limited liability following: date that the forms must be re-executed, company members are jointly and 1. The end of the 3rd year after the tax nor on a certification of nonforeign status severally liable as withholding agents for year of the partnership during which the based on an election under section 897(i). the partnership. For ease of reference, certification was obtained. A widely held partnership that relies in these instructions refer to various 2. The date the partnership receives good faith on a certification of nonforeign requirements applicable to withholding notice from the partner that it has become status or Forms 1001, W-8, W-8BEN or agents as requirements applicable to a foreign person. W-9 in determining nonforeign status will partnerships themselves. 3. The date the partnership learns that not be held liable for payment of the tax, the partner is, or has become, a foreign any applicable penalties, or interest. Determining If a Partner Is a person. However, if a partnership learns that any Foreign Person Form of certification. No particular form of these forms contain false information, nor any particular language is required for it may no longer rely on the form and will A partnership must determine if any certification of nonforeign status. be liable under section 1461 for any partner is a foreign person subject to However, the certification must: failure to pay the withholding tax under section 1446. Under section 1446, a section 1446 for the tax year in which it foreign person is a nonresident alien 1. State that the partner is not a obtained that knowledge. The partnership individual, foreign corporation, foreign foreign person. will not be liable for penalties for failure to partnership, or foreign trust or estate. A 2. State the partner's name, U.S. make timely payments of installments of partnership may determine a partner's taxpayer identifying number, and home the section 1446 withholding tax that were status by relying on a certification of address (for individuals) or office address due prior to the time it learned that the nonforeign status or by any other means. (for entities). information it properly relied on was false. 3. State that the partner will notify the For a widely held partnership, the Certification of Nonforeign Status partnership within 60 days of a change to documentation used to determine the In general, a partnership may determine foreign status. nonforeign status of a partner must be that a partner is not a foreign person by 4. Be signed by or for the partner kept until the end of the 5th tax year obtaining a certification of nonforeign under penalties of perjury. following the last tax year in which the status from the partner. A partnership that A certification of nonforeign status must partnership properly relied on the has obtained this certification may rely on be verified as true and signed under documentation. it to establish the nonforeign status of a penalties of perjury by a responsible partner. See below. corporate officer for a corporation that is Use of Means Other Than Effect of certification. Generally, a a partner, by a general partner for a Certification partnership that has obtained a partnership that is a partner, and by a A partnership is not required to obtain a certification of nonforeign status trustee, executor, or equivalent fiduciary certification of nonforeign status. It may according to the rules in these instructions for a trust or estate that is a partner. A rely on other means to learn the may rely on the certification to determine certification of nonforeign status may also nonforeign status of the partner. But if the that the partner is not subject to be signed by a person authorized under

Page 2 partnership relies on other means and 743 according to the partnership's under the requirements of sections 1441 erroneously determines that the partner election under section 754. Also, a and 1442 and their regulations. was not a foreign person, the partnership partnership's effectively connected will be held liable for payment of the tax, taxable income is not allocable to a Real Property Gains any applicable penalties, and interest. A foreign partner to the extent the amounts Domestic partnerships. Domestic partnership is not required to rely on other are exempt from U.S. tax for that partner partnerships subject to the withholding means to determine the nonforeign status by a treaty or reciprocal agreement, or a requirements of section 1446 are not also of a partner and may demand a provision of the Code. subject to the payment and reporting certification of nonforeign status. requirements of section 1445(e)(1) and its Amount of Withholding Tax regulations for income from the Effectively Connected disposition of a U.S. real property interest. Figuring the Tax Payments A domestic partnership's compliance with Taxable Income the requirement to pay a withholding tax Under section 1446, a partnership must under section 1446 satisfies the Definition make four installment payments of requirements under section 1445(e)(1) for “Effectively connected taxable income” is withholding tax during the tax year. dispositions of U.S. real property the excess of the gross income of the Amount of each installment payment interests. However, a domestic partnership that is effectively connected of withholding tax. In general, the partnership that would otherwise be under section 864(c), or treated as amount of a partnership's installment exempt from section 1445 withholding by effectively connected with the conduct of payment is equal to the sum of the operation of a nonrecognition provision a U.S. trade or business, over the installment payments for each of the must continue to comply with the allowable deductions that are connected partnership's foreign partners. For a requirement of Regulations section to such income. Pub. 519, U.S. Tax foreign partner, the amount of an 1.1445-5(b)(2). Guide for Aliens, has a lengthy discussion installment of the section 1446 Foreign partnerships. A foreign of effectively connected taxable income. withholding tax can be figured by applying partnership subject to withholding under Figure this income with the following the principles of section 6655(e)(2). To do section 1445(a) during a tax year will be adjustments: so, use the worksheet on page 6. allowed to credit the amount withheld 1. Paragraph (1) of section 703(a) Alternatively, each installment payment under section 1445(a) against its liability does not apply. during the tax year may be made in an to pay the section 1446 withholding tax for 2. The partnership is allowed a amount equal to 25% of the withholding that year. deduction for depletion of oil and gas tax that would be payable on the amount wells, determined without regard to of effectively connected taxable income Reporting to Partners sections 613 and 613A. allocable to foreign partners for the prior year if the following three conditions are When making a payment of withholding 3. The partnership may not take into met: tax to the IRS under section 1446, a account items of income, gain, loss, or partnership must notify all foreign partners deduction allocable to any partner that is 1. The prior tax year consisted of 12 months. of their allocable shares of any section not a foreign partner. 1446 tax paid to the IRS by the 4. The partnership may not deduct 2. The partnership filed Form 1065 for the prior year. partnership. The partners use this any net operating loss carryovers or information to adjust the amount of charitable contributions. 3. The amount of effectively estimated tax that they must otherwise A partnership's effectively connected connected taxable income for the prior pay to the IRS. year was not less than 50% of the taxable income includes partnership A partnership must annually provide income subject to a partner's election effectively connected taxable income on the current year's Form 8804. foreign partners with a copy of Form 8805 under section 871(d) or 882(d) (election even if no section 1446 withholding tax is to treat real property income as income Applicable percentage. For partners paid. Send Form 8805 to the foreign connected with a U.S. business). It also taxed as corporations, the section 1446 partner by the due date of the partnership includes any partnership income treated applicable percentage is 35%. For return (including extensions). as effectively connected with the conduct partners not taxable as corporations (e.g., of a U.S. trade or business under section partnerships, individuals, estates), the Interest and Penalties 897 (disposition of investment in U.S. real applicable percentage is 39.6%. property), and other items of partnership When to make the payment. Make Interest and penalties are described income treated as effectively connected payments of the withholding tax under below. If the partnership files Form 8804 under other provisions of the Internal section 1446 with Form 8813 by its due or Forms 8805 late, fails to furnish correct Revenue Code, regardless of whether date during the tax year of the partnership Forms 8805, or fails to pay the tax when those amounts are taxable to the partner. in which the income is earned. due, it may be liable for penalties and Generally, pay any additional amounts interest unless it can show that failure to Amount Allocable to Foreign due when filing Form 8804. However, if file or pay was due to reasonable cause Partners the partnership files Form 2758 to request and not willful neglect. The amount of a partnership's effectively an extension of time to file Form 8804, Interest connected taxable income for the pay the balance of section 1446 partnership's tax year allocable to a withholding tax estimated to be due with Interest is charged on taxes not paid by foreign partner under section 704 equals Form 2758. the due date, even if an extension of time (a) the foreign partner's distributive share to file is granted. Interest is also charged of effectively connected gross income of Coordination With Other on penalties imposed for failure to file, the partnership for the partnership's tax Withholding Rules negligence, fraud, and substantial year that is properly allocable to the understatements of tax from the due date partner under section 704, minus (b) the Interest, Dividends, etc. (including extensions) to the date of foreign partner's distributive share of Fixed or determinable, annual or payment. The interest charge is figured deductions of the partnership for that year periodical income subject to tax under at a rate determined under section 6621. that are connected with that income under section 871(a) or 881 is not included in section 873 or section 882(c)(1). This the partnership's effectively connected Late Filing of Form 8804 income is figured to take into account any taxable income under section 1446. A partnership that fails to file Form 8804 adjustments to the basis of the However, these amounts are when due (including extensions of time to partnership property described in section independently subject to withholding file) generally may be subject to a penalty

Page 3 of 5% of the unpaid tax for each month under section 1446, but who fails to do this, the partnership must comply with the or part of a month the return is late, up to so, may be subject to a civil penalty under payment and reporting requirements of a maximum of 25% of the unpaid tax. The section 6672. The civil penalty is equal these instructions by the date on which penalty will not apply if the partnership to the amount that should have been Form 8804 is due for the partnership's can show reasonable cause for filing late. withheld and paid over. first tax year. Also, the partnership must If the failure to timely file is due to attach a statement to its first Form 8804 reasonable cause, attach an explanation Other Penalties indicating that it is a publicly traded to Form 8804. Penalties can also be imposed for partnership that is electing not to withhold negligence, substantial understatement on distributions. Once made, the election Late Filing of Correct Form 8805 of tax, and fraud. See sections 6662 and may be revoked only with IRS consent. A penalty may be imposed for failure to 6663. file each Form 8805 when due (including Tiered Partnerships extensions). The penalty may also be Treatment of Partners imposed for failure to include all required The term “tiered partnership” describes information on Form 8805 or for furnishing A partnership's payment of section 1446 the situation in which a partnership owns incorrect information. The penalty is withholding tax on effectively connected an interest in another partnership. The based on when a correct Form 8805 is taxable income allocable to a foreign latter is a “subsidiary partnership.” A filed. The penalty is: partner relates to the partner's U.S. partnership that directly or indirectly owns income tax liability for the partner's tax a partnership interest in a subsidiary ● $15 per Form 8805 if the partnership year in which the partner is subject to U.S. partnership is allowed a credit against its correctly files within 30 days; maximum tax on that income. own section 1446 liability for any section penalty of $75,000 per year ($25,000 for Amounts paid by the partnership under 1446 tax paid by the subsidiary a small business). A “small business” has partnership for that partnership interest. average annual gross receipts of $5 section 1446 on effectively connected million or less for the most recent 3 tax taxable income allocable to a partner may A partnership that is a direct or indirect years (or for the period of time the be claimed as a credit under section 33. partner in a subsidiary partnership and business has existed, if shorter) ending The partner may not claim an early refund that has had section 1446 tax payments before the calendar year in which the of withholding tax paid under section made on its behalf will receive a copy of Forms 8805 were due. 1446. Form 1042-S or Form 8805. The partnership that is the direct or indirect ● $50 per Form 8805 if the partnership Amounts paid by a partnership under section 1446 for a partner are to be partner must in turn file these forms with files more than 30 days after the due date its Form 8804 and treat the amount or does not file a correct Form 8805; treated as distributions made to that partner on the earliest of the following: withheld by the subsidiary partnership as maximum penalty of $250,000 per year a credit against its own liability to withhold ($100,000 for a small business). 1. The day on which this tax was paid by the partnership. under section 1446. The partnership that If the partnership intentionally is a direct or indirect partner must also disregards the requirement to report 2. The last day of the partnership's tax provide a copy of the forms it receives to correct information, the penalty per Form year for which the amount was paid. its partners, along with the information 8805 is increased to $100 or, if greater, 3. The last day on which the partner described in Reporting to Partners on 10% of the aggregate amount of items owned an interest in the partnership page 3. These statements and forms will required to be reported, with no maximum during that year. enable those partners to obtain penalty. For more information, see A partner that wishes to claim a credit appropriate credit for tax withheld under sections 6721 and 6724. against its U.S. income tax liability for section 1446. amounts withheld and paid over under Failure To Furnish Correct Forms section 1446 must attach Copy C of Form 8805 to Recipient 8805 to its U.S. income tax return for the A penalty of $50 may be imposed for each tax year in which it claims the credit. Specific Instructions failure to furnish Form 8805 to the recipient when due. The penalty may also Publicly Traded Partnerships Address be imposed for each failure to give the Include the suite, room, or other unit recipient all required information on each A “publicly traded partnership” is any partnership whose interests are regularly number after the street address. If the Form 8805 or for furnishing incorrect Post Office does not deliver mail to the information. The maximum penalty is traded on an established securities market (regardless of the number of its street address and the partnership (or $100,000 for all failures to furnish correct withholding agent) has a P.O. box, show Forms 8805 during a calendar year. partners). However, it does not include a publicly traded partnership treated as a the box number instead of the street If the partnership intentionally corporation under the general rule of address. disregards the requirement to report section 7704(a). If the partnership has a foreign address, correct information, the penalty is enter the number and street, city, province increased to $100 or, if greater, 10% of A publicly traded partnership that has effectively connected income, gain, or or state, and the name of the country. the aggregate amount of items required Follow the foreign country's practice in to be reported and the $100,000 loss, generally must withhold tax at a rate of 39.6% on distributions made to foreign placing the postal code in the address. maximum penalty does not apply. For Do not abbreviate the country name. more information, see sections 6722 and partners. In this situation, the partnership 6724. uses Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Form 8804 Late Payment of Tax Persons, and Form 1042-S, Foreign Person's U.S. Source Income Subject to The penalty for not paying tax when due Lines 4a and 5a 1 Withholding, to report withholding from 2 Figure the partnership's effectively is usually / of 1% of the unpaid tax for distributions instead of following these connected taxable income based on the each month or part of a month the tax is instructions. It also must comply with the definition on page 3. Enter the effectively unpaid. The penalty cannot exceed 25% regulations under section 1461 and connected taxable income allocable to of the unpaid tax. Regulations section 1.6302-2. noncorporate foreign partners in the Failure To Withhold and Pay Over However, such a partnership may elect designated space on line 4a. Enter the Tax instead to pay a withholding tax based on effectively connected taxable income effectively connected taxable income allocable to corporate foreign partners in Any person required to withhold, account allocable to its foreign partners. To do for, and pay over the withholding tax the designated space on line 5a. Page 4 Partnership effectively connected Statement of Withholding on Dispositions Line 8b taxable income on which a foreign partner by Foreign Persons of U.S. Real Property Check the box on this line if any of the is exempt from U.S. tax by a treaty or Interests, for the tax year in which the partnership's effectively connected other reciprocal agreement is not partnership disposed of the U.S. real taxable income is treated as not allocable allocable to that partner and is exempt property tax interest. Also enter the to the foreign partner identified on line 1 from withholding under section 1446. amount of section 1445(e)(1) tax shown and therefore exempt from section 1446 However, this exemption from section under Income Code 25 or 26 on Form withholding because the income is 1446 withholding must be reported on 1042-S for the tax year in which the trust exempt from U.S. tax for that foreign Form 8805. made the distribution to the partnership partner by a treaty, reciprocal exemption, from which tax was withheld because of or a provision of the Internal Revenue Line 7b the disposition of a U.S. real property Code. A foreign partnership must enter the interest. Do not enter more than the amount of section 1446 tax withheld amount allocable to foreign partners (as shown on Form 8805 or under Income defined in section 1446(e)). Enter Form 8813 Code 27 on Form 1042-S received from amounts allocable to U.S. partners on line another partnership in which it owns an 13 of Schedules K and K-1 (Form 1065). Line 2 interest during its tax year. The For Form 1065-B, enter amounts on line A partnership without a U.S. EIN must partnership may credit this amount 16 of Schedule K and in box 9 of obtain one and must pay any section against its section 1446 liability for that tax Schedule K-1. 1446 withholding tax due. If the year. partnership has not received an EIN by Form 8805 the time it files Form 8813, indicate on line Line 7c 2 of Form 8813 the date the partnership Line 7c applies only to partnerships Line 2a applied for its EIN. On receipt of its EIN, the partnership must immediately send treated as foreign persons and subject to A partnership must pay the withholding that number to the IRS using the address withholding under section 1445(a) or tax for a foreign partner even if it does not as shown in Where To File on page 1 of 1445(e)(1) upon the disposition of a U.S. have a TIN for that partner. See these instructions. real property interest. Enter on line 7c the Taxpayer Identifying Number on page amount of tax withheld under section 2 for details on obtaining a TIN. 1445(a) and shown on Form 8288-A,

Page 5 WORKSHEET TO FIGURE 2000 INSTALLMENT PAYMENTS OF SECTION 1446 TAX FOR A FOREIGN PARTNER (Keep for your records—Do not send to the Internal Revenue Service) Caution: Complete lines 1 through 10 of one column before going (a) 1st (b) 2nd (c) 3rd (d) 4th Installment Installment Installment Installment to the next column. Period First ____ First ____ First ____ First ____ 1 Annualization periods (see instructions) 1 months months months months 2 Enter the partnership’s effectively connected taxable income for each period 2 3 Annualization amounts (see instructions) 3 4 Annualized effectively connected taxable income. Multiply line 2 by line 3 4 5 Foreign partner’s annualized effectively connected taxable income. Enter the foreign partner’s share of line 4 5 6 Multiply line 5 by 39.6% for a noncorporate partner (35% for a corporate partner) 6 7 Applicable percentage 7 25% 50% 75% 100% 8 Multiply line 6 by line 7 8 9 Add the amounts in all preceding columns of line 10 9 10 Installment payments of section 1446 tax due for foreign partner. Subtract line 9 from line 8. If less than zero, enter -0- 10

Worksheet Instructions Line 1—Annualization Periods For purposes of annualizing a foreign partner’s effectively connected taxable income during the tax year, partnerships must choose one of the following three sets of annualization periods, which are designated Standard Option, Option 1, and Option 2.

1st Installment 2nd Installment 3rd Installment 4th Installment Standard Option First 3 months First 3 months First 6 months First 9 months Option 1 First 2 months First 4 months First 7 months First 10 months Option 2 First 3 months First 5 months First 8 months First 11 months

If the partnership chooses either Option 1 or 2, it must annually elect to use the option by filing Form 8842, Election To Use Different Annualization Periods for Corporate Estimated Tax. Form 8842 must be filed by the 15th day of the 4th month of the tax year for which the election is to apply. The Standard Option can be used without filing Form 8842. Enter in each column on line 1 the number of months in the annualization periods for the option chosen by the partnership. Line 3—Annualization Amounts If the partnership chose the Standard Option, enter 4 in column (a), 4 in column (b), 2 in column (c), and 1.33333 in column (d). If the partnership chose Option 1, enter 6 in column (a), 3 in column (b), 1.71429 in column (c), and 1.2 in column (d). If the partnership chose Option 2, enter 4 in column (a), 2.4 in column (b), 1.5 in column (c), and 1.09091 in column (d).

Page 6 Country Codes Congo (Brazzaville)...... CF Jersey ...... JE Congo, Democratic Republic of ...... Johnston Atoll...... JQ Enter on line 4, Form 8805, the code, (Zaire) ...... CG Jordan ...... JO from the list below, for the country of Cook Islands ...... CW Juan de Nova Island ...... JU which the partner is a resident for tax Coral Sea Islands Territory ...... CR Kazakhstan ...... KZ purposes. These codes are used by the Corsica ...... VP Kenya ...... KE IRS to provide information to all tax treaty Costa Rica...... CS Kingman Reef ...... KQ countries for purposes of their tax Cote D'Ivoire (Ivory Coast)...... IV Kiribati (Gilbert Islands)...... KR administration. Generally, the partner's Croatia ...... HR Korea, Democratic People's country for both tax and mailing purposes Cuba ...... CU Republic of (North)...... KN will be the same. In some cases, Curacao ...... NT Korea, Republic of (South) ...... KS however, two different countries are Cyprus ...... CY Kurile Islands...... RS involved. Czech Republic ...... EZ Kuwait ...... KU Country Code Denmark ...... DA Kyrgyzstan ...... KG Abu Dhabi ...... TC Djibouti ...... DJ Laos ...... LA Afghanistan ...... AF Dominica ...... DO Latvia ...... LG Albania ...... AL Dominican Republic ...... DR Lebanon ...... LE Algeria ...... AG Dubai ...... TC Lesotho ...... LT American Samoa...... AQ Ecuador ...... EC Liberia ...... LI Andorra ...... AN Egypt ...... EG ...... LY ...... AO Eleuthera Island ...... BF Liechtenstein ...... LS Anguilla ...... AV El Salvador...... ES Lithuania ...... LH Antarctica ...... AY Equatorial Guinea ...... EK Luxembourg ...... LU Antigua and Barbuda ...... AC Eritrea ...... ER Macau ...... MC Argentina ...... AR Estonia ...... EN Macedonia (former Yugoslav ...... Armenia ...... AM Ethiopia ...... ET Republic of ...... MK Aruba ...... AA Europa Island ...... EU Madagascar (Malagasy Republic) .. MA Ashmore and Cartier Islands ...... AT Falkland Islands (Islas Malvinas).... FK Malawi ...... MI Australia ...... AS Faroe Islands ...... FO Malaysia ...... MY Austria ...... AU Fiji ...... FJ Maldives ...... MV Azerbaijan ...... AJ Finland ...... FI Mali ...... ML Azores ...... PO ...... FR Malta ...... MT Bahamas, The...... BF French Guiana ...... FG Marshall Islands ...... RM Bahrain ...... BA French Polynesia (Tahiti) ...... FP Martinique ...... MB Baker Island ...... FQ French Southern and Antarctic Mauritania ...... MR Balearic Islands (Mallorca, etc.)...... SP Lands ...... FS Mauritius ...... MP Bangladesh ...... BG Gabon ...... GB ...... MF Barbados ...... BB Gambia, The ...... GA Mexico ...... MX Bassas da India ...... BS Gaza Strip ...... GZ Micronesia, Federated States of..... FM Belarus ...... BO Georgia ...... GG Midway Islands...... MQ Belgium ...... BE Germany ...... GM Moldova ...... MD Belize ...... BH Ghana ...... GH Monaco ...... MN Benin (Dahomey) ...... BN Gibraltar ...... GI Mongolia ...... MG Bermuda ...... BD Glorioso Islands ...... GO Montenegro ...... MW Bhutan ...... BT Great Britain (United Kingdom)...... UK Montserrat ...... MH Bolivia ...... BL Greece ...... GR Morocco ...... MO Bonaire ...... NT Greenland ...... GL Mozambique ...... MZ Bosnia-Herzegovina ...... BK Grenada (Southern Grenadines) .... GJ Namibia ...... WA Botswana ...... BC Guadeloupe ...... GP Nauru ...... NR Bouvet Island ...... BV Guam ...... GQ Navassa Island...... BQ Brazil ...... BR Guatemala ...... GT Nepal ...... NP British Indian Ocean Territory ...... IO Guernsey ...... GK Netherlands ...... NL Brunei ...... BX Guinea ...... GV Netherlands Antilles ...... NT Bulgaria ...... BU Guinea-Bissau ...... PU New Caledonia...... NC Burkina Faso (Upper Volta) ...... UV Guyana ...... GY New Zealand ...... NZ Burma ...... BM Haiti ...... HA Nicaragua ...... NU Burundi ...... BY Heard Island and McDonald Islands. HM Niger ...... NG Cambodia (Kampuchea) ...... CB Honduras ...... HO Nigeria ...... NI Cameroon ...... CM Hong Kong ...... HK Niue ...... NE Canada ...... CA Howland Island...... HQ Norfolk Island ...... NF Canary Islands ...... SP Hungary ...... HU Northern Ireland ...... UK Cape Verde ...... CV Iceland ...... IC Northern Mariana Islands...... CQ Cayman Islands ...... CJ India ...... IN Norway ...... NO Central African Republic ...... CT Indonesia (including Bali, Belitung,. Oman ...... MU Chad ...... CD Flores, Java, Moluccas, Sumatra,. Pakistan ...... PK Chile ...... CI Timor, etc.) ...... ID Palau, Republic of...... PS China, People's Republic of...... Iran ...... IR Palmyra Atoll ...... LQ (including Inner Mongolia, Tibet,... Iraq ...... IZ Panama ...... PM and Manchuria) ...... CH Ireland, Republic of (Eire) ...... EI Papua New Guinea...... PP Christmas Island (Indian Ocean) .... KT Isle of Man ...... IM Paracel Islands...... PF Clipperton Island ...... IP Israel ...... IS Paraguay ...... PA Cocos (Keeling) Islands ...... CK Italy ...... IT Peru ...... PE Colombia ...... CO Jamaica ...... JM Philippines ...... RP Comoros ...... CN Jan Mayen...... JN Pitcairn Island...... PC Japan ...... JA Poland ...... PL

Page 7 Portugal ...... PO Somalia ...... SO Tuvalu ...... TV Puerto Rico ...... RQ South Africa...... SF Uganda ...... UG Qatar (Katar) ...... QA South Georgia and the Ukraine ...... UP Redonda ...... VI South Sandwich Islands...... SX United Arab Emirates...... TC Reunion ...... RE Spain ...... SP United Kingdom (England, Wales,.. Romania ...... RO Spratly Islands...... PG Scotland, No. Ireland) ...... UK Russia ...... RS Sri Lanka ...... CE Uruguay ...... UY Rwanda ...... RW Sudan ...... SU Uzbekistan ...... UZ Ryukyu Islands...... JA Suriname ...... NS Vanuatu ...... NH St. Helena (Ascension Island and .. Svalbard (Spitsbergen) ...... SV Vatican City ...... VT Tristan de Cunha Island Group) ... SH Swaziland ...... WZ Venezuela ...... VE St. Kitts (St. Christopher and Nevis). SC Sweden ...... SW Vietnam ...... VM St. Lucia ...... ST Switzerland ...... SZ Virgin Islands (British) ...... VI St. Pierre and Miquelon ...... SB Syria ...... SY Virgin Islands (U.S.) ...... VQ St. Vincent and the Grenadines...... Taiwan ...... TW Wake Island ...... WQ (Northern Grenadines) ...... VC Tajikistan ...... TI Wallis and Futuna ...... WF San Marino...... SM Tanzania, United Republic of...... TZ West Bank...... WE Sao Tome and Principe ...... TP Thailand ...... TH Western Sahara ...... WI Sarawak ...... MY Togo ...... TO Western Samoa ...... WS Saudi Arabia...... SA Tokelau ...... TL Windward Islands...... VC Senegal ...... SG Tonga ...... TN Yemen (Aden) ...... YM Serbia ...... SR Tortola ...... VI Zaire (Democratic Republic of ...... Seychelles ...... SE Trinidad and Tobago...... TD Congo) ...... CG Sierra Leone...... SL Tromelin Island...... TE Zambia ...... ZA Singapore ...... SN Tunisia ...... TS ...... ZI Slovakia ...... LO Turkey ...... TU Other Countries...... OC Slovenia ...... SI Turkmenistan ...... TX Solomon Islands...... BP Turks and Caicos Islands ...... TK

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