Information Return of U.S. Persons With Respect to Foreign                                                  OMB No. 1545-1910
Form 8858                         Disregarded Entities (FDEs) and Foreign Branches (FBs)
(Rev. December 2024)                     Go to www.irs.gov/Form8858 for instructions and the latest information.
Department of the Treasury        Information furnished for the FDE’s or FB’s annual accounting period (see instructions)                     Attachment   
Internal Revenue Service                  beginning                   , 20              , and ending                          , 20            Sequence No.  140 
Name of person filing this return                                                                                                          Filer’s identifying number

Number, street, and room or suite no. (or P.O. box number if mail is not delivered to street address)

City or town, state, and ZIP code

Filer’s tax year beginning                                                         , 20      , and ending                                                    , 20
Important: Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in  
              U.S. dollars unless otherwise indicated. 
Check here             FDE of a U.S. person                      FDE of a controlled foreign corporation (CFC)                  FDE of a controlled foreign partnership
                       FB of a U.S. person                       FB of a CFC                                                    FB of a controlled foreign partnership 
Check here             Initial Form 8858                         Final Form 8858
1a  Name and address of FDE or FB                                                         b(1)  U.S. identifying number, if any 

                                                                                          b(2)  Reference ID number (see instructions)

    cFor FDE, country(ies) under whose laws organized and entity type under local tax law                       d  Date(s) of organization e  Effective date as FDE

 f   If benefits under a U.S. tax treaty were claimed with respect to income of the FDE or FB, enter the treaty g  Country in which principal business activity is conducted 
     and article number.

h  Principal business activity code number          i  Principal business activity                                                         j  Functional currency

2    Provide the following information for the FDE’s or FB’s accounting period stated above. 
 a  Name, address, and identifying number of branch office or agent (if any) in           b  Name and address (including corporate department, if applicable) of person(s) 
     the United States                                                                       with custody of the books and records of the FDE or FB, and the location of 
                                                                                             such books and records, if different 

3    For the tax owner of the FDE or FB (if different from the filer), provide the following. See instructions. 
 a  Name and address                                                                      b  Annual accounting period covered by the return (see instructions) 

                                                                                          c(1)  U.S. identifying number, if any 

                                                                                          c(2)  Reference ID number (see instructions)

                                                                                          d  Country under whose laws organized            e  Functional currency 

4    For the direct owner of the FDE or FB (if different from the tax owner), provide the following. See instructions.
 a  Name and address                                                                      b  Country under whose laws organized 

                                                                                          c  U.S. identifying number, if any               d  Functional currency 

5    Attach an organizational chart that identifies the name, placement, percentage of ownership, tax classification, and country of organization of all entities in the chain of 
     ownership between the tax owner and the FDE or FB, and the chain of ownership between the FDE or FB and each entity in which the FDE or FB has a 10%-or-more 
     direct or indirect interest. See instructions. 
For Paperwork Reduction Act Notice, see the separate instructions.                                   Cat. No. 21457L                          Form 8858 (Rev. 12-2024) 

Form 8858 (Rev. 12-2024)                                                                                                    Page 2 
Schedule C        Income Statement (see instructions) 
Important: Report all information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S. 
dollars translated from functional currency (using GAAP translation rules or the average exchange rate determined under 
section 989(b)). If the functional currency is the U.S. dollar, complete only the U.S. dollars column. See instructions for 
special rules for FDEs or FBs that use U.S. dollar approximate separate transactions method of accounting (DASTM). 
If you are using the average exchange rate (determined under section 989(b)), check the following box        . . . . . .
                                                                                            Functional currency    U.S. dollars
1  Gross receipts or sales (net of returns and allowances)  . .  . . .  . . . .    .      1
2  Cost of goods sold .        . . . . .  . .    . . . . .    .  . . .  . . . .    .      2
3  Gross profit (subtract line 2 from line 1)  . . . . . .    .  . . .  . . . .    .      3
4  Dividends .           . . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      4
5  Interest  .           . . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      5
6  Gross rents, royalties, and license fees  .   . . . . .    .  . . .  . . . .    .      6
7  Gross income from performance of services  .      . . .    .  . . .  . . . .    .      7
8  Foreign currency gain (loss)  .   . .  . .    . . . . .    .  . . .  . . . .    .      8
9  Other income            . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      9
10 Total income (add lines 3 through 9)  .  .    . . . . .    .  . . .  . . . .    .      10
11 Total deductions (exclude income tax expense)  .    . .    .  . . .  . . . .    .      11
12 Income tax expense  .         . . . .  . .    . . . . .    .  . . .  . . . .    .      12
13 Other adjustments  .        . . . . .  . .    . . . . .    .  . . .  . . . .    .      13
14 Net income (loss) per books .     . .  . .    . . . . .    .  . . .  . . . .    .      14
Schedule C-1      Section 987 Gain or Loss Information
                                                                                                  (a)                  (b)  
   Note: See the instructions if there are multiple recipients of remittances from             Amount stated in    Amount stated in  
   the FDE or FB.                                                                           functional currency of   functional currency of 
                                                                                                FDE or FB          recipient 
1  Remittances from the FDE or FB  .      . .    . . . . .    .  . . .  . . . .    .      1
2  Section 987 gain (loss) recognized by recipient   . . .    .  . . .  . . . .    .      2
3  Section  987  gain  (loss)  deferred  under  Regulations  section  1.987-12  (attach 
   statement)            . . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      3
                                                                                                                  Yes       No
4  Were all remittances from the FDE or FB treated as made to the direct owner?  . .    . . . . . .        . .
5  Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances
   from the FDE or FB during the tax year? If “Yes,” attach a statement describing the method used prior to 
   the change and new method of accounting .       . . . .    .  . . .  . . . .    .    . . . . . .        . .
Schedule F        Balance Sheet
Important: Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in  
accordance with U.S. GAAP. See instructions for an exception for FDEs or FBs that use DASTM. 
                                                                                                  (a)                  (b)  
                                            Assets                                          Beginning of annual    End of annual  
                                                                                              accounting period   accounting period 
1  Cash and other current assets  .    .  . .    . . . . .    .  . . .  . . . .    .      1
2  Other assets .          . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      2
3  Total assets  .         . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      3
                                   Liabilities and Owner’s Equity
4  Liabilities  .        . . . . . . . .  . .    . . . . .    .  . . .  . . . .    .      4
5  Owner’s equity  .         . . . . . .  . .    . . . . .    .  . . .  . . . .    .      5
6  Total liabilities and owner’s equity . . .    . . . . .    .  . . .  . . . .    .      6
Schedule G        Other Information
                                                                                                                  Yes       No
1  During the tax year, did the FDE or FB own an interest in any trust? . . . .    .    . . . . . .        . .
2  During the tax year, did the FDE or FB own at least a 10% interest, directly or indirectly, in any foreign
   partnership?  .         . . . . . . .  . .    . . . . .    .  . . .  . . . .    .    . . . . . .        . .
3  Answer only if the FDE made its election to be treated as disregarded from its owner during the tax year: 
   Did the tax owner claim a loss with respect to stock or debt of the FDE as a result of the election?  . . .
4  During the tax year, did the FDE or FB pay or accrue any foreign tax that was disqualified for credit under 
   section 901(m)? .         . . . . . .  . .    . . . . .    .  . . .  . . . .    .    . . . . . .        . .
5  During the tax year, did the FDE or FB pay or accrue foreign taxes to which section 909 applies, or treat 
   foreign taxes that were previously suspended under section 909 as no longer suspended?  .  . . .        . .
                                                                                                             Form 8858 (Rev. 12-2024) 

Form 8858 (Rev. 12-2024)                                                                                                                    Page 3 
Schedule G      Other Information (continued)
                                                                                                                                       Yes  No
6    Is the FDE or FB a qualified business unit as defined in section 989(a)?   .  . .    . .   . . . .                       . . .
     Do not complete lines 7 and 8 if you are an individual who owns an FB or FDE directly or through tiers of
     FBs and FDEs.

7  a During  the  tax  year,  did  the  FDE  or  FB  receive,  or  accrue  the  receipt  of,  any  amounts  defined  as  a 
     base erosion payment under section 59A(d) or have a base erosion tax benefit under section 59A(c)(2) from
     a foreign person, which is a related party of the taxpayer? See instructions. If “Yes,” complete lines 7b 
     and 7c . .          . . . .  . . .  . . . .   .  .    . .   .  . . .   .   .  . .    . .   . . . .                       . . .
b    Enter the total amount of the base erosion payments     $
c    Enter the total amount of the base erosion tax benefit  $
8 a  During  the  tax  year,  did  the  FDE  or  FB  pay,  or  accrue  the  payment  of,  any  amounts  defined  as  a  base 
     erosion payment under section 59A(d) or have a base erosion tax benefit under section 59A(c)(2) to a foreign 
     person, which is a related party of the taxpayer? See instructions. If “Yes,” complete lines 8b and 8c  .                  . .
b    Enter the total amount of the base erosion payments   $
c    Enter the total amount of the base erosion tax benefit  $
9    Answer only if the tax owner of the FDE or FB is a CFC: Were there any intracompany transactions between
     the FDE or FB and the CFC or any other branch of the CFC during the tax year, in which the FDE or FB 
     acted as a manufacturing, selling, or purchasing branch?  .    . . .   .   .  . .    . .   . . . .                       . . .  
     Answer the remaining questions in Schedule G only if the tax owner of the FB or the interest in the FDE is a 
     U.S. corporation. Answer questions 10a through 11c if the tax owner of the FB or the interest in the FDE is
     treated as a U.S. corporation solely for purposes of these questions.
10 a If the FB or the interest in the FDE is a separate unit under Regulations section  1.1503(d)-1(b)(4), and is not 
     part of a combined separate unit under Regulations section 1.1503(d)-1(b)(4)(ii), does the separate unit have
     a dual consolidated loss as defined in Regulations section 1.1503(d)-1(b)(5)(ii)?  . . .   . . . .                       . . .
b    If “Yes,” enter the amount of the dual consolidated loss    .  . . .   .   .  . .    . . $ (                          )
11 a If  the  FB  or  the  interest  in  the  FDE  is  a  separate  unit  and  part  of  a  combined  separate  unit  under 
     Regulations section 1.1503(d)-1(b)(4)(ii), does the combined separate unit have a dual consolidated loss as 
     defined in Regulations section 1.1503(d)-1(b)(5)(ii)? If “Yes,” complete lines 11b and 11c . . . .                       . . .
b    Enter the amount of the dual consolidated loss for the combined separate unit .      . . $ (                          )
c    Enter the net income (loss) attributed to the individual FB or the individual interest in the FDE as determined
     under Regulations section 1.1503(d)-5(c)(4)(ii)(A)  . . .   .  . . .   .   .  . .    . .   $
12 a Was any portion of the dual consolidated loss on line 10b or 11b taken into account in computing U.S. 
     taxable income for the year? If “Yes,” go to line 12b. If “No,” go to line 13 . .    . .   . . . .                       . . .
b    Was this a permitted domestic use of the dual consolidated loss under Regulations section 1.1503(d)-6? If
     “Yes,” see the instructions and go to line 12c. If “No,” go to line 12d  . .  . .    . .   . . . .                       . . .
c    If “Yes,” is the documentation that is required for the permitted domestic use under Regulations section
     1.1503(d)-6 attached to the return? After answering this question, go to line 13a   .  .   . . . .                       . . .
d    If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated
     taxable income as provided under Regulations section 1.1503(d)-4? If “Yes,” go to line 12e .   . .                       . . .
e    Enter the           separate unit’s contribution to     the    cumulative     consolidated   taxable                     income
     (“cumulative register”) as of the beginning of the tax year  . . .   $                 . See instructions.
13 a During  the  tax  year,  did  any  triggering  event(s)  occur  under  Regulations  section  1.1503(d)-6(e)  requiring 
     recapture of any dual consolidated loss(es) attributable to the FB or interest in the FDE, individually or as 
     part of a combined separate unit, in any prior tax years?  .   . . .   .   .  . .    . .   . . . .                       . . .
b    If “Yes,” enter the total amount of recapture .  .    . .   .  . .   $                 . See instructions.
14a  During the tax year, did the FDE or FB pay or accrue any Top-up Tax? See instructions  .     . . .                       . . .
b    If “Yes,” enter the amount of each type of tax paid or accrued.                                                          
     (1) Income Inclusion Rule (IIR) (or similar taxes)  . . .   .  . . .   .   .  . .    . . $
     (2) Qualified Domestic Minimum Top-up Tax (QDMTT) (or similar taxes)   .      . .    . . $
     (3) UTPR (or similar taxes)  .   .  . . . .   .  .    . .   .  . . .   .   .  . .    . . $
                                                                                                                                  Form 8858 (Rev. 12-2024) 

Form 8858 (Rev. 12-2024)                                                                                                            Page 4 
Schedule H        Current Earnings and Profits or Taxable Income (see instructions) 
Important: Enter the amounts on lines 1 through 6 in functional currency. 
1     Current year net income (loss) per foreign books of account  .            . . . .    . .   . . .    . . . .         1
2     Total net additions  .      . .    . .     . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .         2
3     Total net subtractions .      .    . .     . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .         3
4     Current earnings and profits (or taxable income—see instructions) (line 1 plus line 2 minus line 3)  .    .         4
5     DASTM gain (loss) (if applicable)  .         . . .   .     . . .  . .     . . . .    . .   . . .    . . . .         5
6     Combine lines 4 and 5         .    . .     . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .         6
7     Current  earnings  and  profits  (or  taxable  income)  in  U.S.  dollars  (line  6  translated  at  the  average 
      exchange rate determined under section 989(b) and the related regulations (see instructions))  .        . .         7
8     Enter exchange rate used for line 7  .         . .   .     . . .  . .     . . . .    . .
Schedule I        Transferred Loss Amount 
Important: See instructions for who has to complete this section.
                                                                                                                               Yes  No
1     Were any assets of an FB (including an FB that is an FDE) transferred to a foreign corporation? If “No,”
      stop here. If “Yes,” go to line 2 .        . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .       . .
2     Was the transferor a domestic corporation that transferred substantially all of the assets of an FB (including 
      an FB that is an FDE) to a specified 10%-owned foreign corporation? If “No,” stop here. If “Yes,” go to 
      line 3 . .         .   .  . . .    . .     . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .       . .
3     Immediately  after  the  transfer,  was  the  domestic  corporation  a  U.S.  shareholder  with  respect  to  the
      transferee foreign corporation? If “No,” stop here. If “Yes,” go to line 4      .    . .   . . .    . . . .       . .
4     Enter  the  transferred  loss  amount  included  in  gross  income  as  required  under  section  91.  See 
      instructions .         .  . . .    . .     . . . .   .     . . .  . .     . . . .    . .   . . .    . . . .         4
Schedule J        Income Taxes Paid or Accrued (see instructions)
                                  Foreign Income Taxes                                       Foreign Tax Credit Separate Categories
(a)          (b)                    (c)              (d)             (e)              (f)            (g)                (h)         (i)  
Country or  Foreign tax year    Foreign currency Conversion rate   U.S. dollars   Foreign branch   Passive        General           Other
territory (YYYY-MM-DD)

Totals
                                                                                                                          Form 8858 (Rev. 12-2024)