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Schedule A                                   Penalty for Underpayment of Estimated                                              OMB No. 1545-0123
(Form 8804)
                                                  Section 1446 Tax by Partnerships
Department of the Treasury                                          Attach to Form 8804.                                             23
Internal Revenue Service                Go to www.irs.gov/Form8804 for instructions and the latest information.                 20
Name                                                                                                         Employer identification number

Note: Generally, the partnership isn’t required to file this Schedule A (see Part I below for exceptions) because the IRS will figure any penalty 
owed and bill the partnership. However, the partnership may still use this Schedule A to figure the penalty. If so, enter the amount from line 65 
of this Schedule A on line 8 of Form 8804, but don’t attach this Schedule A.
Part I    Reasons for Filing—Check the boxes below that apply. If any boxes are checked, the partnership must file 
          Schedule A (Form 8804) even if it doesn’t owe a penalty. See instructions.
          The partnership is using the adjusted seasonal installment method.
          The partnership is using the annualized income installment method.
Part II   Current Year and Prior Year Safe Harbors
1     Enter the total section 1446 tax shown on the partnership’s 2023 Form 8804, line 5f. If less than $500, 
      don’t complete or file this form. The partnership doesn’t owe the penalty  .           . . . .     . . . . .          1
2     Enter  the  total  section  1446  tax  that  would  have  been  due  for  2022,  without  regard  to  reductions  for 
      certified  foreign  partner-level  items,  on  the  effectively  connected  taxable  income  (ECTI)  allocable  to 
      foreign partners for 2022. 
      Caution: This line 2 amount only applies if certain conditions are met. See instructions .         . . . . .          2
3     Enter the   smaller     of line 1 or line 2. If the partnership is required to skip line 2, enter the amount from 
      line 1  .   .      .    . .    .  .    . .  .    . . . .      . .    .     . . . . .   . . . .     . . . . .          3
Part III  Figuring the Underpayment
                                                                                         (a)             (b)                (c)            (d)
4     Installment  due  dates.         Enter  in  columns  (a)  through  (d) 
      the 15th day of the 4th, 6th, 9th, and 12th months of the             
      partnership’s tax year  .         .    . .  .    . . . .      . .          4
5     Required  installments.           If  the  partnership  uses  the 
      adjusted    seasonal  installment  method  and/or  the 
      annualized income installment method, enter the amounts 
      from  line  43.  If  neither  of  those  methods  is  used,  enter 
      25% (0.25) of line 3 above in each column .          . .      . .          5
6     Estimated  section  1446  tax  paid  or  credited  for  each 
      period.  See  instructions.  For  column  (a)  only,  enter  the 
      amount from line 6 on line 10  .         .  .    . . . .      . .          6
      Complete  lines  7  through  13  of  one  column  before 
      going to the next column.
7     Enter amount, if any, from line 13 of the preceding column                 7

8     Add lines 6 and 7         .    .  .    . .  .    . . . .      . .          8

9     Add amounts on lines 11 and 12 of the preceding column                     9

10    Subtract line 9 from line 8. If zero or less, enter -0-  .      .          10
11    If the amount on line 10 is zero, subtract line 8 from line 9. 
      Otherwise, enter -0- .         .  .    . .  .    . . . .      . .          11
12    Underpayment.        If  line  10  is  less  than  or  equal  to  line  5, 
      subtract line 10 from line 5. Then, go to line 7 of the next 
      column. Otherwise, go to line 13  .         .    . . . .      . .          12
13    Overpayment.         If line 5 is less than line 10, subtract line 5 
      from line 10. Then, go to line 7 of the next column  .          .          13
      Go to Part VII on page 5 to figure the penalty. Don’t go to Part VII if there are no entries on line 12—no penalty is owed.
For Paperwork Reduction Act Notice, see separate instructions.                           Cat. No. 40853F                    Schedule A (Form 8804) 2023



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Schedule A (Form 8804) 2023                                                                                       Page 2
Part IV Adjusted Seasonal Installment Method (Caution:Use this method only if the base period percentage for 
        any 6 consecutive months is at least 70%. See instructions.)
Check this box if the partnership has elected to attach a schedule                  (a)      (b)      (c)      (d)
that  expands  lines  15  and  22  through  25  to  reflect  Regulations            First 3  First 5  First 8  First 11 
section 1.1446-3(a)(2). See instructions  . . . . . . .          . .                months   months   months   months
14   Enter ECTI allocable to all foreign partners for the following periods:
a    Tax year beginning in 2020                                                  14a

b    Tax year beginning in 2021                                                  14b

c    Tax year beginning in 2022                                                  14c
15   Enter ECTI allocable to all foreign partners for each period for the 
     tax  year  beginning  in  2023  (see  instructions  for  the  treatment  of 
     extraordinary items).                                                       15
                                                                                    First 4  First 6  First 9  Entire year
                                                                                    months   months   months
16   Enter ECTI allocable to all foreign partners for the following periods:
a    Tax year beginning in 2020                                                  16a

b    Tax year beginning in 2021                                                  16b

c    Tax year beginning in 2022                                                  16c
17   Divide the amount in each column on line 14a by the amount in 
     column (d) on line 16a.                                                     17
18   Divide the amount in each column on line 14b by the amount in 
     column (d) on line 16b.                                                     18
19   Divide the amount in each column on line 14c by the amount in 
     column (d) on line 16c.                                                     19

20   Add lines 17 through 19.                                                    20

21   Divide line 20 by 3.0.                                                      21

22a  Divide line 15 by line 21.                                                  22a

b    Extraordinary items. See instructions.                                      22b

c    Combine lines 22a and 22b.                                                  22c
23   Reduction  to  line  22c  amount  for  state  and  local  taxes  under 
     Regulations  section  1.1446-6(c)(1)(iii)  and  for  certified  foreign 
     partner-level items submitted using Form 8804-C. See instructions.          23
24   Subtract line 23 from line 22c. If zero or less, enter -0-.                 24
25a  Multiply the ECTI on line 24 allocable to non-corporate partners by 
     37% (0.37).                                                                 25a
b    Multiply  the  ECTI  on  line  24  allocable  to  corporate  partners  by 
     21% (0.21).                                                                 25b
c    Combine lines 25a and 25b.                                                  25c
26a  Divide  the  amount  in  columns  (a)  through  (c)  on  line  16a  by  the 
     amount in column (d) on line 16a.                                           26a
b    Divide  the  amount  in  columns  (a)  through  (c)  on  line  16b  by  the 
     amount in column (d) on line 16b.                                           26b
c    Divide  the  amount  in  columns  (a)  through  (c)  on  line  16c  by  the 
     amount in column (d) on line 16c.                                           26c
27   Add lines 26a through 26c.                                                  27
28   Divide line 27 by 3.0.                                                      28
29   Multiply  the  amount  in  columns  (a)  through  (c)  of  line  25c  by 
     columns (a) through (c) of line 28. In column (d), enter the amount 
     from line 25c, column (d).                                                  29
                                                                                                      Schedule A (Form 8804) 2023



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Schedule A (Form 8804) 2023                                                                                Page 3
Part V   Annualized Income Installment Method
                                                                                 (a)    (b)    (c)    (d)
                                                                                 First  First  First  First
30  Annualization periods. See instructions.                                 30  months months months months
31  Enter ECTI allocable to all foreign partners for each annualization 
    period (see instructions for the treatment of extraordinary items):
a   Total ECTI allocable to corporate partners.                              31a
b   Total ECTI allocable to non-corporate partners other than on lines 
    31c, 31d, and 31e.                                                       31b
c   28% rate gain (non-corporate partners only).                             31c
d   Unrecaptured section 1250 gain (non-corporate partners only).            31d
e   Adjusted net capital gain (including qualified dividend income and 
    net section 1231 gain) (non-corporate partners only).                    31e
32  Annualization amounts. See instructions.                                 32
33  Annualized ECTI allocable to all foreign partners (see instructions 
    for the treatment of extraordinary items):
a   Total ECTI allocable to corporate partners (multiply line 31a by line 
    32).                                                                     33a
b   Reduction to line 33a for state and local taxes under Regulations 
    section 1.1446-6(c)(1)(iii). See instructions.                           33b (                    ) (                    ) (                    ) (                    ) 
c   Reduction  to  line  33a  for  certified  foreign  partner-level  items 
    submitted using Form 8804-C. See instructions.                           33c (                    ) (                    ) (                    ) (                    ) 
d   Combine lines 33a, 33b, and 33c.                                         33d
e   Total ECTI allocable to non-corporate partners other than on lines 
    33i, 33m, and 33q (multiply line 31b by line 32).                        33e
f   Reduction to line 33e for state and local taxes under Regulations 
    section 1.1446-6(c)(1)(iii). See instructions.                           33f (                    ) (                    ) (                    ) (                    ) 
g   Reduction  to  line  33e  for  certified  foreign  partner-level  items 
    submitted using Form 8804-C. See instructions.                           33g (                    ) (                    ) (                    ) (                    ) 
h   Combine lines 33e, 33f, and 33g.                                         33h
i   28%  rate  gain  allocable  to  non-corporate  partners  (multiply  line 
    31c by line 32).                                                         33i
j   Reduction to line 33i for state and local taxes under Regulations 
    section 1.1446-6(c)(1)(iii). See instructions.                           33j (                    ) (                    ) (                    ) (                    ) 
k   Reduction  to  line  33i  for  certified  foreign  partner-level  items 
    submitted using Form 8804-C. See instructions.                           33k (                    ) (                    ) (                    ) (                    ) 
l   Combine lines 33i, 33j, and 33k.                                         33l
m   Unrecaptured section 1250 gain allocable to non-corporate partners 
    (multiply line 31d by line 32).                                          33m
n   Reduction to line 33m for state and local taxes under Regulations 
    section 1.1446-6(c)(1)(iii). See instructions.                           33n (                    ) (                    ) (                    ) (                    ) 
o   Reduction  to  line  33m  for  certified  foreign  partner-level  items 
    submitted using Form 8804-C. See instructions.                           33o (                    ) (                    ) (                    ) (                    ) 
p   Combine lines 33m, 33n, and 33o.                                         33p
q   Adjusted net capital gain (including qualified dividend income and 
    net  section  1231  gain)  allocable  to  non-corporate  partners 
    (multiply line 31e by line 32).                                          33q
r   Reduction to line 33q for state and local taxes under Regulations 
    section 1.1446-6(c)(1)(iii). See instructions.                           33r (                    ) (                    ) (                    ) (                    ) 
s   Reduction  to  line  33q  for  certified  foreign  partner-level  items 
    submitted using Form 8804-C. See instructions.                           33s (                    ) (                    ) (                    ) (                    ) 
t   Combine lines 33q, 33r, and 33s.                                         33t
34  Figure the tax on line 33 amounts as follows:
a   Multiply line 33d by 21% (0.21).                                         34a
b   Multiply line 33h by 37% (0.37).                                         34b
c   Multiply line 33l by 28% (0.28).                                         34c
d   Multiply line 33p by 25% (0.25).                                         34d
e   Multiply line 33t by 20% (0.20).                                         34e
f   Add lines 34a through 34e.                                               34f
                                                                                               Schedule A (Form 8804) 2023



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Schedule A (Form 8804) 2023                                                                                            Page 4
Part V    Annualized Income Installment Method (continued)
                                                                                (a)         (b)         (c)         (d)
35    Applicable percentage.                                                 35 25% (0.25)  50% (0.50)  75% (0.75)  100% (1.00)
36    Multiply line 34f by line 35.                                          36
Part VI   Required Installments
Note: Complete lines 37 through 43 of one column before completing              1st         2nd         3rd         4th  
the next column.                                                                installment installment installment installment
37    If only Part IV or Part V is completed, enter the amount in each 
      column from line 29 or line 36. If both parts are completed, enter 
      the smaller of the amounts in each column from line 29 or line 36.     37
38    Add the amounts in all preceding columns of line 43. See instructions. 38
39    Adjusted seasonal or annualized income installments. Subtract 
      line 38 from line 37. If zero or less, enter -0-.                      39
40    Enter 25% (0.25) of line 1 in each column.                             40
41    Subtract line 43 of the preceding column from line 42 of the preceding 
      column.                                                                41
42    Add lines 40 and 41.                                                   42
43    Required installments. Enter the smaller of line 39 or line 42 here 
      and on line 5. See instructions.                                       43
                                                                                                        Schedule A (Form 8804) 2023



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Schedule A (Form 8804) 2023                                                                                                         Page 5
Part VII    Figuring the Penalty
                                                                                  (a)               (b)           (c)            (d)
 44 Enter the date of payment or the 15th day of the 3rd month after 
    the close of the tax year, whichever is earlier. See instructions. 
    Partnerships  that  keep their records  and   books  of account 
    outside  the  United  States  and  Puerto Rico: Use  6th  month 
    instead of 3rd month.                                                    44
45  Number  of  days  from  due  date  of  installment  on  line  4  to  the 
    date shown on line 44  .   .  . .   .  .    . .     . .   . .            45

46  Number of days on line 45 after 4/15/2023 and before 7/1/2023            46

47  Underpayment on line 12  × Number of days on line 46 ×  7% (0.07)        47 $          $                    $               $
                                        365

48  Number of days on line 45 after 6/30/2023 and before 10/1/2023           48

49  Underpayment on line 12  × Number of days on line 48  ×  7% (0.07)       49 $          $                    $               $
                                        365

50  Number of days on line 45 after 9/30/2023 and before 1/1/2024            50

51  Underpayment on line 12  × Number of days on line 50  x  8% (0.08)       51 $          $                    $               $
                                        365

52  Number of days on line 45 after 12/31/2023 and before 4/1/2024           52

53  Underpayment on line 12  × Number of days on line 52  × 8% (0.08)        53 $          $                    $               $
                                        366

54  Number of days on line 45 after 3/31/2024 and before 7/1/2024            54

55  Underpayment on line 12  × Number of days on line 54  ×  *%              55 $          $                    $               $
                                        366

56  Number of days on line 45 after 6/30/2024 and before 10/1/2024           56

57  Underpayment on line 12  × Number of days on line 56  ×  *%              57 $          $                    $               $
                                        366

58  Number of days on line 45 after 9/30/2024 and before 1/1/2025            58

59  Underpayment on line 12  × Number of days on line 58  ×  *%              59 $          $                    $               $
                                        366

60  Number of days on line 45 after 12/31/2024 and before 4/1/2025           60

61  Underpayment on line 12  × Number of days on line 60  ×  *%              61 $          $                    $               $
                                        365

62  Number of days on line 45 after 3/31/2025 and before 5/16/2025           62

63  Underpayment on line 12  × Number of days on line 62  ×  *%              63 $          $                    $               $
                                        365

64  Add lines 47, 49, 51, 53, 55, 57, 59, 61, and 63  . . .   . .            64 $          $                    $               $

65 Penalty. Add columns (a) through (d) of line 64. Enter the total here and on Form 8804, line 8  ..   65      $
* Use the penalty interest rate for each calendar quarter, which the IRS will determine during the first month in the preceding quarter. These rates are 
published quarterly in an IRS News Release and in a revenue ruling in the Internal Revenue Bulletin (IRB). Go to www.irs.gov/IRB for the IRBs. You can 
subscribe to IRS Newswire to receive news releases of the quarterly interest rates, and IRS GuideWire to receive emails with a link to the revenue 
rulings in which the quarterly interest rates are published by going to www.irs.gov/UAC/E-News-Subscriptions-2.
                                                                                                                  Schedule A (Form 8804) 2023






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