SCHEDULE G                                             Statement of Application of the Gain Deferral Method  
(Form 8865)
                                                                                       Under Section 721(c)
(Rev. December 2021)                                                                                                                                                                               OMB No. 1545-1668
                                                                         ▶ 
Department of the Treasury                                                  Attach to Form 8865. See the Instructions for Form 8865.
Internal Revenue Service                                   ▶ Go to www.irs.gov/Form8865 for instructions and the latest information.
Name of person filing Form 8865                                                                                                                                               Filer’s identification number

Name of partnership                                                                                                         Successor          EIN (if any)                   Reference ID number (see instructions)
                                                                                                                            partnership
Name of U.S. transferor (see instructions)                                                                                  Successor          Filing year: (see instructions)
                                                                                                                            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 Regulations section 1.721(c)‐ 3(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) (Rev. 12-2021)

Schedule G (Form 8865) (Rev. 12-2021)                                                                                                                                                                      Page 2 
Part III         Allocation Percentages of Partnership Items With Respect to Section 721(c) Property (see instructions)  
                                 1. Income                                           2. Gain                                        3. Deduction                                         4. Loss
Part I,          (a)                (b)             (c)              (a)               (b)             (c)             (a)               (b)                (c)            (a)             (b)             (c) 
line             U.S.       Related domestic  Related foreign        U.S.       Related domestic  Related foreign      U.S.       Related domestic  Related foreign        U.S.       Related domestic  Related foreign 
     number      transferor      partners       partners           transferor        partners      partners            transferor       partners        partners         transferor      partners      partners
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 
number               Book                   Tax                          Book                   Tax                        Book                      Tax                       Book                  Tax
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 Regulations section 1.721(c) 4‐                       or Regulations section 1.721(c)     ‐
        5(d)) occur with respect to one or more section 721(c) properties?  .                 . .  .   .   .      . .  . .  .     .    . .   .   . .    .   .   . . .    . .    .   . .  .  .       1
2       During the tax year, did a termination event (as described in Regulations section 1.721(c)‐ 5(b)) occur with respect to one or more section 721(c) properties?                              2
3       During the tax year, did a successor event (as described in Regulations section 1.721(c)‐ 5(c)) occur with respect to one or more section 721(c) properties?                                3
4       During the tax year, was there a tax disposition of a portion of an interest in the partnership (as described in Regulations section 1.721(c)‐ 5(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 
        Regulations section 1.721(c)‐ 5(e))?            . .   .    . .    .   . .    .  .  .  . .  .   .   .      . .  . .  .     .    . .   .   . .    .   .   . . .    . .    .   . .  .  .       5
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   .                          . .    . .    .   . .  .  .     6a
     b  Is the gain deferral method applied with respect to one or more of such additional section 721(c) property contributed?                             .   . . .    . .    .   . .  .  .     6b
7 a     Was a copy of the waiver of treaty benefits (as described in Regulations section 1.721(c) 6(b)(2)(iii))‐                  filed with respect to each section 721(c) property 
        contribution to the section 721(c) partnership? If “Yes,” complete line 7b  .              .   .   .      . .  . .  .     .    . .   .   . .    .   .   . . .    . .    .   . .  .  .     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 Regulations section 1.721‐ 6(b)(3)(vi)            .    . .    .   . .    .  .  .  . .  .   .   .      . .  . .  .     .    . .   .   . .    .   .   . . .    . .    .   . .  .  .     7b
Part VI          Supplemental Information (see instructions) 

                                                                                                                                                                                Schedule G (Form 8865) (Rev. 12-2021)