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)                     2
3       During  the properties? 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)             3
4       Duringproperties?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)