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SCHEDULE P                                                                                                                   OMB No. 1545-0123
(Form 1120-F)                         List of Foreign Partner Interests in Partnerships
                                                       Attach to Form 1120-F.
Department of the Treasury                                                                                                      2023
Internal Revenue Service                 Go to www.irs.gov/Form1120F for instructions and the latest information.
Name of corporation (foreign partner)                                                                            Employer identification number (EIN)

Part I    List of Foreign Partner’s Interests in Partnerships
                                                                                             (d) For each partnership interest, is the 
                                                                                             foreign corporation’s distributive share 
      (a) Name of partnership                      (b) Address               (c) EIN         ECI, or             treated     as ECI, in whole     or in part, 
                                                                                             with a              U.S. trade or business determined 
                                                                                             under section 875 (see instructions)?
A 
                                                                                                                   Yes                  No
B 
                                                                                                                   Yes                  No
C 
                                                                                                                   Yes                  No
D 
                                                                                                                   Yes                  No
Note: If the corporation has more than 4 partnership interests, continue on a separate page. See instructions.
Part II   Summary of Foreign Partner’s Income and Expenses From Schedule K-3 (Form 1065)
                                                                             Schedules K-3
                                                   A                 B           C                               D                      Total
1  Total gross income. Enter the amount  
   from Schedule K-3, Part X, Section 1, 
   line 21, column (a) .      .       . . .    . .
2  Gross ECI—Partnership determination. 
   Enter the sum of  Schedule K-3, Part X, 
   Section  1,  line  21,  column  (c)  plus 
   column (d)   .        .  . .       . . .    . .
3  Gross  ECI—Partner  determination.  
   Enter  all  applicable  amounts  from 
   Schedule  K-3,  Part  X,  Section  1, 
   column (b) (see instructions)  .            . .
4  Total  deductions  and  losses.  Enter 
   the  amount  from  Schedule  K-3,  Part 
   X, Section 2, line 24, column (a)  .          .
5  Total  deductions            and       losses 
   deductible  against  gross  ECI—
   Partnership determination. Enter the 
   sum of Schedule K-3, Part X, Section 
   2, line 24, column (c) plus column (d)  
6  Total  deductions            and         losses 
   deductible against gross ECI—Partner 
   determination.  Enter  all  applicable 
   amounts  from  Schedule  K-3,  Part  X, 
   Section 2, column (b) (see instructions)  
7  Interest  expense  directly  allocable 
   under  Regulations  section  1.882-5(a)
   (1)(ii)(B). (Note: Include the line 7 total 
   on Schedule I, line 22.) .           . .    . .
8  Interest  expense  on  U.S.  booked 
   liabilities  as          described       under 
   Regulations  section  1.882-5(d)(2)(vii). 
   Enter the amount from Schedule K-3, 
   Part  X,  Section  2,  line  7,  column  (b). 
   Include the line 8 total on Schedule I, 
   line 9, column (b)  .      .       . . .    . .
For Paperwork Reduction Act Notice, see the Instructions for Form 1120-F.    Cat. No. 49677Z                     Schedule P (Form 1120-F) 2023



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Schedule P (Form 1120-F) 2023                                                                            Page 2 
Part III  Foreign Partner’s Average Outside Basis Under Regulations sections 1.882-5(b) and 1.884-1(d)(3)
                                                              Schedules K-3
                                                A      B      C            D     Total
9   Section 705 outside basis  .      . . .
10a Partner’s liabilities included in outside 
    basis under section 752 that give rise 
    to  directly  allocable  interest  expense 
    under  Regulations  section  1.882-5(a)
    (1)(ii)(B)  . . . .       . . .   . . .
b   All other liabilities included in partner’s 
    outside basis under section 752  .    .
c   Add lines 10a and 10b  .      .   . . .
d   Subtract line 10c from line 9  .    . .
11  Partner’s  liabilities  under  Regulations 
    section  1.884-1(d)(3)(vi).  (Note:  Enter 
    the  portion  of  the  line  11  total  on 
    Schedule  I,  line  8,  column  (b)  that 
    represents  U.S.  booked  liabilities 
    under Regulations section 1.882-5(d).)  
12  Partner’s     outside       basis   under 
  Regulations  section  1.884-1(d)(3)
    (vi). Add lines 10d and 11  .     . . .
13  Partner’s  outside  basis  allocable  to 
    ECI   under     Regulations       sections 
    1.884-1(d)(3)(i)  and  1.882-5.  (Note: 
    The  line  13  total  should  generally  be 
    entered on Schedule I, line 5, column 
    (b). However, see the instructions for 
    Schedule  I,  line  5,  column  (b)  before 
    entering an amount on that line.)  .  .
14  Check either the “income” box or the 
    “asset” box to indicate the allocation      Income Income Income       Income
    method  used  on  line  13  (see            Asset  Asset  Asset        Asset
    instructions)   . .       . . .   . . .
                                                                           Schedule P (Form 1120-F) 2023



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Schedule P (Form 1120-F) 2023                                                                                                       Page 3 
Name of corporation (foreign partner)                                                                 Employer identification number (EIN)

Part IV   Foreign Partner’s Interests in Partnerships Transferred During Tax Year
         (a)  Enter the letter of the row in Part I 
          that corresponds to the partnership       (b)(1) Percentage    (b)(2) Units transferred (c) Date acquired   (d) Date transferred 
          whose interest was transferred.           interest transferred                              (Mo., Day, Yr.)   (Mo., Day, Yr.)
                  See instructions.
   (i)

   (ii)

  (iii)

  (iv)
Note: If the corporation transferred more than four partnership interests, continue on a separate page. See instructions.
 Part V   Foreign Partner’s Gain or Loss on Transfer of Partnership Interests
                                                                             Partnership Interest Transferred (see instructions)
                                                                         (i)   (ii)                   (iii)                     (iv)

1  Amount realized on transfer of partnership interest
2  Section 705 outside basis .          . . .    .  . . .  .
3  Total outside gain (loss) on         transfer of 
   partnership interest. Subtract line 2 from line 1       .  
4  Total outside ordinary gain (loss) that would be 
   recognized on the deemed sale of section 751 
   property. Enter amount from Schedule K-3 (Form 
   1065), Part XIII, line 1 .         . . . .    .  . . .  .
5  Total  outside  capital  gain  (loss)  related  to  the 
   transfer of the partnership interest. Subtract line 
   4 from line 3  . .  .      .       . . . .    .  . . .  .
6  Aggregate  effectively  connected  ordinary  gain 
   (loss) that would be recognized on the deemed 
   sale of section 751 property. Enter amount from 
   Schedule K-3 (Form 1065), Part XIII, line 2  .       .  .
7  Aggregate  effectively  connected  capital  gain 
   (loss) that would be recognized on the deemed 
   sale  of  non-section  751  property.  Enter  amount 
   from Schedule K-3 (Form 1065), Part XIII, line 3        .
8  Recognized effectively connected ordinary gain 
   (loss).  Enter  the  smaller  of  line  4  or  line  6.  See 
   instructions  .  .  .      .       . . . .    .  . . .  .
9  Recognized  effectively  connected  capital  gain 
   (loss).  Enter  the  smaller  of  line  5  or  line  7.  See 
   instructions  .  .  .      .       . . . .    .  . . .  .
10 Gain  (loss)  that  would  be  recognized  under 
   section 897(g) on the deemed sale of U.S. real 
   property  interests.  Enter  amount  from  Schedule 
   K-3 (Form 1065), Part XIII, line 7. See instructions  .
                                                                                                                      Schedule P (Form 1120-F) 2023






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