Information Return of U.S. Persons With Respect to Foreign                                                 OMB No. 1545-1910
Form  8858                          Disregarded Entities (FDEs) and Foreign Branches (FBs)
(Rev. September 2020)                  ▶ 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 8858                       Final 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 g  Country in which principal business     h  Principal business      i  Functional currency 
     income of the FDE or FB, enter the treaty and article number      activity is conducted                      activity 

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. 9-2020) 

Form 8858 (Rev. 9-2020)                                                                                                    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 DASTM. 
If you are using the average exchange rate (determined under section 989(b)), check the following box . . . . . .
                                                                                            Functional Currency    U.S. Dollar
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 the following question 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. 9-2020) 

Form 8858 (Rev. 9-2020)                                                                                                           Page 3 
Schedule G              Other Information (continued)
                                                                                                                              Yes No
6 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 6b 
     and 6c .  .        . . . .  . . .    . . . .  . .    . .    . . . . .      .  . . .   .    .   . . . .   . .
b    Enter the total amount of the base erosion payments         $
c    Enter the total amount of the base erosion tax benefit      $
7 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 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    Is the FDE or FB a qualified business unit as defined in section 989(a)?.  .  . . .   .    .   . . . .   . .
9    Answer  the  following  question  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?  .     . . .   . . 
10 a 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: 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.
                                                                                                                Form 8858 (Rev. 9-2020) 

Form 8858 (Rev. 9-2020)                                                                                                            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 (see instructions)
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)  
Country or    Foreign Currency   Conversion Rate       U.S.       Foreign Branch       Passive              General           Other
Possession                                           Dollars

Totals
                                                                                                                    Form 8858 (Rev. 9-2020)