Userid: CPM Schema: instrx Leadpct: 100% Pt. size: 9 Draft Ok to Print AH XSL/XML Fileid: … ns/i8986/202401/a/xml/cycle06/source (Init. & Date) _______ Page 1 of 7 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Department of the Treasury Internal Revenue Service Instructions for Form 8986 (January 2024) Partner’s Share of Adjustment(s) to Partnership-Related Item(s) (Required Under Sections 6226 and 6227) For use with Form 8986 (December 2019) Contents Page pass-through partner to which the adjustments in the statement Reminder . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 relate. Purpose of Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Audited partnership, for purposes of Form 8986, is a BBA partnership that made the election under section 6226 to have its Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 partners report their share of adjustments to partnership-related General Instructions . . . . . . . . . . . . . . . . . . . . . . . . . 2 items. Who Should Prepare Form 8986 . . . . . . . . . . . . . 2 Audited partnership’s adjustment year is the year that includes the date the court decision became final, if the Where To Submit Form 8986 . . . . . . . . . . . . . . . . 2 partnership filed a petition under section 6234. Otherwise, it is Due Dates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 the year that includes the date the final partnership adjustment Withholding for Foreign Partners . . . . . . . . . . . . . 2 (FPA) letter was mailed, or the FPA waiver was executed by the Instructions for Partners That Receive Form IRS. 8986 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Adjustments that do not result in an IU. A partnership adjustment does not result in an imputed underpayment (IU) if Specific Instructions . . . . . . . . . . . . . . . . . . . . . . . . . 3 the result of netting with respect to any grouping or subgrouping Part I—Information About the Entity that includes the particular partnership adjustment is zero or less Submitting This Form . . . . . . . . . . . . . . . . . . . 3 than zero. Adjustments do not result in an IU if the calculation of Part II—Information About the Audited the IU on those adjustments results in an amount that is zero or Partnership or the Partnership That Filed less than zero. Any adjustment to an item which is not a monetary item (for example, an election made by the an AAR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 partnership) is an adjustment that does not result in an IU. Part III—Information About the Pass-Through BBA AAR is an administrative adjustment request filed by a BBA Partner Issuing and Submitting This Form partnership. 8986 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 BBA partnership is a partnership that is subject to the Part IV—Information About the Partner centralized partnership audit regime that was enacted into law by Receiving This Form 8986 . . . . . . . . . . . . . . . . 3 section 1101 of the Bipartisan Budget Act of 2015 (BBA). The BBA is generally effective for tax years beginning on or after Part V—Partner’s Total Reviewed Year January 1, 2018. Income, Gain, Loss, Deductions, Credits, Designated individual (DI) is the individual through whom an and Other Items . . . . . . . . . . . . . . . . . . . . . . . 4 entity partnership representative acts. Part VI—Statements . . . . . . . . . . . . . . . . . . . . . . 6 Extended due date of the partnership’s adjustment year Section references are to the Internal Revenue Code unless return is, for purposes of Form 8986, the extended due date of otherwise noted. the AAR or audited partnership’s adjustment year return regardless of whether the partnership is required to file a return Future Developments for the adjustment year or timely filed a request for an extension. For the latest information about developments related to Form Finally determined. The partnership adjustment(s) becomes 8986 and its instructions, such as legislation enacted after they finally determined upon the later of the expiration of the time to were published, go to IRS.gov/Form8986. file a petition under section 6234 or, if a petition is filed under section 6234, the date when the court’s decision becomes final Reminder or the date the closing agreement is entered into between the The Bipartisan Budget Act of 2015 (BBA) created a centralized IRS and the partnership. partnership audit regime that replaced the partnership audit First affected year is the partner’s tax year that includes the procedures under the Tax Equity and Fiscal Responsibility Act of end of the audited or AAR partnership’s reviewed year(s). Each 1982 (TEFRA). Form 8986 was created for partnerships to show reviewed year of an audited partnership should have a each partner’s share of adjustments to partnership-related items corresponding first affected year for each partner. as a result of a BBA audit or BBA administrative adjustment Imputed underpayment (IU) is the amount determined under request (AAR). sections 6225, 6226, and 6227, and the regulations thereunder. Partnership representative (PR) is the person designated by Purpose of Form the partnership or by the IRS under section 6223 and the regulations thereunder to act on behalf of the BBA partnership. Form 8986 is used by BBA partnerships to furnish and transmit Pass-through partner is a pass-through entity that holds an each partner’s share of adjustments to partnership-related items. interest, either directly or indirectly, in a partnership. Pass-through entities include partnerships, S corporations, Definitions trusts, and decedents’ estates. For purposes of Form 8986, a AAR partnership is a BBA partnership (see below) that has pass-through entity is not a wholly owned entity disregarded as filed an administrative adjustment request (AAR) under section separate from its owner for federal tax purposes or a trust that is 6227. wholly owned by only one person. AAR partnership’s adjustment year is the partnership tax year Pass-through partner’s tax year end to which the that includes the year the AAR was filed with the IRS. adjustments relate is the end of the pass-through partner's tax Affected partner is a partner that held an interest in a year which includes the audited or AAR partnership's reviewed pass-through partner at any time during the tax year of the year end date. Jan 16, 2024 Cat. No. 69668G |
Page 2 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Note. Certain entity partners can be both a non-pass-through An audited partnership can submit corrected Forms 8986, partner and a pass-through partner. To the extent the along with Form 8985, within 60 days of the original due date adjustments an entity partner received on a Form 8986 relate to without IRS permission. If corrected forms need to be submitted items that are taxable at the entity level, it is considered a after the 60-day correction period, the audited partnership must non-pass-through partner, and with regard to adjustments that contact the IRS for permission to submit. pass through to its owners/beneficiaries it is considered a AAR partnerships. An AAR partnership that either elects to pass-through partner. push out the resulting adjustments to its partners or has Reporting year is the partner’s tax year(s) that includes the date adjustments that do not result in an IU must furnish Forms 8986 the audited or AAR partnership furnished the Forms 8986 to its to all partners and include them with their AAR, along with Form partners. 8985. Reviewed year is the audited or AAR partnership’s tax year to which the partnership adjustment(s) relates. Pass-through partners. Direct and indirect pass-through Reviewed year adjustments are adjustments originating from partners must furnish Forms 8986 to their partners and submit the AAR or audited partnership’s reviewed year(s). them to the IRS, along with Form 8985, by the extended due Reviewed year partner is any person that held an interest in date of the audited partnership’s adjustment year return (or the the audited or AAR partnership at any time during the extended due date of the AAR partnership’s adjustment year partnership’s reviewed year. return). This date can be found in Part II, item F, of the Form 8986 that was received by the pass-through partner. Failure to submit General Instructions these forms by the due date results in the pass-through partner being liable for an IU. Who Should Prepare Form 8986 A pass-through partner who receives a Form 8986 related to The following persons or entities should prepare Form 8986. an audited partnership can submit corrected Forms 8986, along • Audited partnerships that have made an election under with Form 8985, within 60 days of the original due date without section 6226. IRS permission. If corrected forms need to be submitted after the • Direct or indirect pass-through partners that receive a Form 60-day correction period, the pass-through partner must contact 8986 related to an audited partnership if they choose to furnish the IRS for permission to submit. statements to their partners to further push out the adjustments. Direct or indirect pass-through partners that receive a Form 8986 Withholding for Foreign Partners related to an AAR partnership, if the direct or indirect An audited partnership may have withholding and reporting pass-through partner chooses to furnish statements to its obligations if it furnishes a Form 8986 to a reviewed year partner partners to further push out adjustments or have adjustments that includes an adjustment subject to withholding under that do not result in an IU. chapter 3 (Withholding of Tax on Nonresident Aliens and Foreign • Partnerships that file an AAR under section 6227 and either Corporations) or chapter 4 (Taxes To Enforce Reporting on elect to push out the resulting adjustments to their partners or Certain Foreign Accounts). In those cases, the audited have adjustments that do not result in an IU. partnership must pay the amount of tax required to be withheld under chapter 3 or chapter 4 before the due date of the audited Where To Submit Form 8986 partnership's adjustment year return (without regard to Audited partnerships and pass-through partners of audi- extension) or the extended due date of the audited partnership's ted partnerships. Section 6241(10) gives the IRS authority to adjustment year return in the case of a pass-through partner. require electronic submission of anything required to be filed or See Instructions for Form 1042, Annual Withholding Tax Return submitted under section 6226(a). Audited BBA Partnerships and for U.S. Source Income of Foreign Persons; or Form 8804, their pass-through partners are required to submit Forms 8985, Annual Return for Partnership Withholding Tax (Section 1446), Pass-Through Statement—Transmittal/Partnership Tracking for deposit procedures. The audited partnership must also file an Report, and 8986 electronically. See IRS.gov/BBAeSubmit for applicable withholding tax return, Form 1042 or Form 8804, and steps required to register and submit electronically. the associated information returns, Forms 1042-S, Foreign Person's U.S. Source Income Subject to Withholding; or Forms AAR partnerships. AAR partnerships that are electing to push 8805, Foreign Partner's Information Statement of Section 1446 out adjustments to their partners or have adjustments that do not Withholding Tax, for the calendar year (if filing Forms result in an imputed underpayment must include Form 8985 with 1042/1042-S) or tax year (if filing Forms 8804/8805) that their AAR along with Forms 8986. The Forms 8985 and 8986 includes the date on which the Form 8986 was furnished. must be filed with, and in the same manner as, the AAR. Pass-through partners of an AAR partnership. Pass-through Instructions for Partners That Receive Form partners of an AAR partnership must submit Form 8985 to the 8986 IRS by fax at 888-981-6982, with or without Forms 8986, as applicable. This fax number is not for general use. Taxpayers Pass-through partners. In general, a pass-through partner that should not use this for anything besides Forms 8985 and 8986. receives a Form 8986 should take into account the adjustments Illegible or other submissions received via this fax number will reflected on the form by either: not be processed. See IRS.gov/BBAAAR for additional • Furnishing Forms 8986 to its own partners and submitting information. those forms, along with Form 8985, to the IRS or • Figuring and paying an IU and submitting Form 8985 to the IRS, where the adjustments result in an IU to the pass-through Due Dates entity. See Form 8985 and its instructions. Audited partnerships. An audited partnership that has made One of these two options must be completed by the extended an election under section 6226 must furnish Forms 8986 to its due date of the audited partnership’s adjustment year return (or partners and submit them to the IRS, along with Form 8985, no the extended due date of the AAR partnership’s adjustment year later than 60 days after the date on which the partnership return). adjustments are finally determined. Failure to furnish and submit by the due date may result in the audited partnership being liable for the IU. 2 Instructions for Form 8986 (January 2024) |
Page 3 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. If a pass-through partner fails to timely furnish and if you entered XYZ LLC on the Form 8985, you must enter XYZ ! submit the relevant statements, the pass-through partner LLC on the Form 8986. In the state field, enter the two-letter CAUTION may be liable for an IU as well as any penalties and abbreviation or the full name of the foreign province. U.S. interest with respect to the adjustments reflected on the Form partnerships leave the country code field blank. Foreign 8986 received by the pass-through partner. partnerships enter the country code found at Foreign Country Codes. Other partners. All other partners that receive Form 8986 Item C—Enter the partnership's tax identification number. This should report the information on Form 8978, Partner’s Additional number must be entered exactly as it appears on the Form 8985 Reporting Year Tax, and attach the Form 8978 to the partner’s associated with this Form 8986. reporting year tax return. For more information, see Form 8978 Item D—Enter the tax year end date of the reviewed year of the and its instructions. partnership. Each reviewed year should have a separate Form These partners may pay in advance to stop the running of 8986. This form must be completed for reviewed years that have interest. adjustments related to an audit or an AAR. • Pay by EFTPS, debit or credit card, or Direct Pay (Forms 1040 Item E—Enter the partnership’s adjustment year ending date. only). Item F—Enter the extended due date of the partnership’s • Select Prepayment on BBA AAR/Exam Push Out as payment adjustment year tax return, regardless of whether the partnership type. has filed for an extension. For AAR partnerships, this will be the • As applicable, apply payment to the tax form that will have the extended due date of the tax year the AAR was filed. Form 8978 attached to it. Item G—Enter the date the partnership furnished the Forms 8986 to its partners. Special Instructions for certain entity partners. Certain entity partners (such as trusts and estates) that receive a Form Part III—Information About the Pass-Through 8986 may have some adjustments that are taxable at the entity level, and other adjustments that pass through to the owners and Partner Issuing and Submitting This Form 8986 beneficiaries of the entity partner. The adjustments taxable to the Item A—On lines 1–6, enter the pass-through partner’s name, entity partner should be reported on the Form 8978 attached to address, city, state, country code, and ZIP code. In the state the entity partner’s reporting year tax return. For all other field, enter the two-letter abbreviation or the full name of the adjustments that flow through to its owners or beneficiaries, the foreign province. U.S. partnerships leave the country code field entity partner should follow the above instructions for blank. Foreign pass-through partners enter the country code “pass-through partners.” found at Foreign Country Codes. Item B—Enter the pass-through partner’s tax identification Specific Instructions number. Item C—Enter the pass-through partner’s tax year end to which Submitting a corrected form due to an incorrect TIN. If the adjustments relate. submitting a corrected form due to an incorrect TIN on a Item D—Enter the name of the entity that issued the Form 8986 previously submitted and accepted original Form 8986, you will to the pass-through partner, if different from the audited need to submit two corrected forms: partnership or AAR partnership in Part II. 1. A corrected Form 8986 with the correct TIN, and Item E—Enter the tax identification number of the entity that 2. A corrected Form 8986 with the incorrect TIN and zeros in issued the Form 8986 to the pass-through partner, if different Part IV, sections E through G, and in Part V. Anytime a corrected from the audited partnership or AAR partnership in Part II. Form 8986 is submitted, a corrected Form 8985 must also be included. Part IV—Information About the Partner Receiving This Form 8986 Original or corrected. At the top of the form, check the Item A—On lines 1–6, enter the partner’s name, address, city, appropriate box to indicate if the form is original or corrected. state, country code, and ZIP code. In the state field, enter the Tracking number. Enter the outgoing tracking number shown two-letter abbreviation or the full name of the foreign province. on the related Form 8985 of a BBA partnership or a pass through U.S. partners leave the country code field blank. Foreign partner of a BBA partnership. partners enter the country code found at Foreign Country Codes. Item B—Enter the partner’s tax identification number. Audit control number. Enter the audit control number that is Item C—Indicate by checking box 1 or 2 if the partner is a provided on correspondence with the IRS. Pass-through general partner or LLC member manager, limited partner, or LLC partners can locate this number at the top of the Form 8986 they member. Indicate by checking box 3 or 4 if the partner is a received. AAR partnerships, including pass-through partners of domestic or foreign partner. an AAR partnership, should leave this field blank. Item D—Indicate if, for tax purposes, the partner is an individual, S corporation, C corporation, partnership, or other type of entity Part I—Information About the Entity Submitting by checking one of the boxes 1–5. If “Other,” indicate what type This Form on the line provided. Also indicate if the partner is a retirement Item A—Indicate which entity is issuing this form by checking plan or other tax-exempt entity. Note: If you entered a social one of the boxes. security number as the partner's tax identification number in box Item B—Check the box that corresponds to the type of return B, you should check box 1. You should only select boxes 2–5 normally filed by the entity issuing this form. If “Other,” also when you have entered an EIN in box B. indicate the type of return filed on the line provided. Item E—Enter the partner’s percentage share of partnership profits, losses, and capital as originally reported on Part II—Information About the Audited Schedule K-1, the change per audit or AAR (if none, enter zero), Partnership or the Partnership That Filed an and the corrected percentage. Item F—Enter the partner’s share of total liabilities—recourse AAR and nonrecourse—as originally reported on Schedule K-1, the Items A and B—On lines 1–6, enter the name and address of change per audit or AAR (if none, enter zero), and the corrected the partnership. The name must be entered exactly as it appears amounts. on the Form 8985 associated with this Form 8986. For example, Instructions for Form 8986 (January 2024) 3 |
Page 4 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Item G—Enter the components of the partner’s capital account Schedule K-3. For each item that was adjusted, enter the as originally reported on Schedule K-1, the change per audit or following. AAR (if none, enter zero), and the corrected amounts. Column (a), Line number—The Schedule K-1 line number that was adjusted. If you have changes to Schedule K-3, enter “K3” Note. If the partner in the partnership is an entity, such as (no dash). single-member limited liability company (LLC), that is a Column (b), Line title—The title of the Schedule K-1 item that disregarded entity (DE) for federal income tax purposes, in item was adjusted. For adjustments to Schedule K-3, enter the part, A, enter the name and address of the beneficial owner of the DE section (if applicable), line, and column reference. partner. The beneficial owner is the taxpayer who owns the DE Column (c), Code—If applicable, use the code letters listed in partner. Enter the TIN of the beneficial owner of the DE partner in the Schedule K-1 instructions that correspond to the line number item B rather than the TIN of the DE partner. In addition to the shown in column (a). For adjustments to Schedule K-3, if beneficial owner information reported in Part IV, list the name applicable, enter the country code. See the Schedule K-3 and TIN of the DE partner in Part VI of the Form 8986. instructions. If no specific code applies, enter “NA.” Column (d), As reported—Enter the original amount reported Part V—Partner’s Total Reviewed Year Income, to the partner on their Schedule K-1 or as previously corrected Gain, Loss, Deductions, Credits, and Other by the partnership. For adjustments to Schedule K-3, do not Items enter amounts on column (d). Column (e), Check if statement in Part VI—Check the box in Note. Adjustments that increase a schedule K-1 item as this column if the item shown in column (a) has a corresponding originally reported or as corrected should be shown as positive statement in Part VI. For adjustments to Schedule K-3, enter an amounts; adjustments that decrease schedule K-1 items should explanation of the adjustment on Part VI of Form 8986 with be shown as negative amounts. reference to the entry on Part V, column (b). For columns (a)–(c), refer to the relevant Schedule K-1 and instructions. See special instructions for changes to Example 1 On its filed 2024 return, partnership ABC reported $1,000 of general category foreign source interest income with respect to Country Y on Partner A’s Schedule K-3. Partnership ABC later determined that the amount should have been reported as passive category foreign source interest income on Schedule K-3. To make the correction to the 2024 return, ABC filed an AAR on November 10, 2025, attaching Forms 8985 and 8986. The two-letter code from the list at Foreign Country Codes for Country Y is YY. Partnership ABC includes in Part V of the Form 8986 sent to Partner A the information as follows. Example 1. Form 8986, Part V. Partner’s Total Reviewed Year Income, Gain, Loss, Deduction, Credits, and Other Items Schedule K-1 (a) (b) (c) (d) (e) (f) Line number Line title Code* As reported Check if statement Reviewed year in Part VI adjustments as finally determined K-3 Part II, Sec. 1, Line 6A, YY column (e) K-3 Part II, Sec. 1, Line 6A, YY column (c) Partnership ABC includes in Part VI of the Form 8986 sent to Partner A the information as follows. Example 1. Form 8986, Part VI. Statements (a) (b) Line no./ Statement code Line title Code As reported Review year adjustments As corrected K-3 Part II, Sec. 1, Line 6A, YY $1,000 $(1,000) $0 column (e) Part II, Sec. 1, Line 6A, YY $0 $1,000 $1,000 column (c) 4 Instructions for Form 8986 (January 2024) |
Page 5 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Example 2 On its filed return, Partnership ABC reported on Partner A’s Schedule K-3, Part VIII, as follows. Example 2. Schedule K-3 (Form 1065), Part VIII. Line Entry A 1234 B PAS C iii Unit Euro QBU1 1a1i YY 1a1ii 1000 Subsequent to filing its return, Partnership ABC determines that the amount reported on Line 1a1ii of Partner A’s Schedule K-3, Part VIII, should have been €1,500. Partnership ABC makes the correction by filing an AAR with Forms 8985 and 8986 attached. It includes the following information in Part V of the Form 8986. Example 2. Form 8986, Part V. Partner’s Total Reviewed Year Income, Gain, Loss, Deduction, Credits, and Other Items Schedule K-1 (a) (b) (c) (d) (e) (f) Line number Line title Code* As reported Check If statement Reviewed year in Part VI adjustments as finally determined K-3 Part VIII, Line 1a1 YY Partnership ABC must report the adjustment amount with respect to Partner A in Part VI of Form 8986 as follows. Example 2. Form 8986, Part VI. Statements (a) (b) Line number/code Statement Part VIII, K-3 Line As reported Adjustments As corrected K-3 A 1234 B PAS C iii 1a1ii 1,000 500 1,500 Note. Although the first three lines are not adjusted, they are necessary to identify the adjustment line, because there might be more than one Part VIII. Column (f), Reviewed year adjustments as finally should not be shown in this column. For adjustments to determined—Enter the partner’s share of reviewed year Schedule K-3, do not enter amounts on column (g). adjustments that corresponds to the line item in column (a). For Column (h), Net (column (f) minus column (g))—Enter the adjustments to Schedule K-3, do not enter amounts on column amount in column (f) less the amount in column (g). For (f). adjustments to Schedule K-3, do not enter amounts on column Column (g), Approved modifications—Enter the partner’s (h). share of the total modifications approved by the IRS with respect Loans and other items recharacterized as distributions to to the item adjusted. Modifications related to the filing of an AAR partners. If a reviewed year adjustment has been made to change a partner loan or other item to a partner distribution, this Instructions for Form 8986 (January 2024) 5 |
Page 6 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. adjustment should be reported with the column (a) line number statements section can be used to add an “As Corrected” that corresponds to the Schedule K-1 “Distributions” category column to the amounts reported in Part V. If doing so be sure to and with column (c), code A, for cash distributions if the partner complete the line number field in column (a) which is a received money, and as a code C if the partner received property mandatory field for all items entered in Part VI (Statements). other than money. Statements related to section 199A information. Disguised sale adjustments. Distributions to a partner that were changed as part of an audit proceeding to disguised sale Note. Because section 199A dividends are reported as a proceeds under section 707 should be reported with the column cumulative amount and not per qualified trade or business, these (a) line number that corresponds to the Schedule K-1 “Other” should only be included once in the first section 199A statement category and with column (c), code DS. The partnership should attached to Form 8986, regardless of how many statements may also include a statement in Part VI describing the asset that was be necessary. sold, the proceeds, and the tax basis of the asset at the time of Adjustments that increase or decrease section 199A the contribution. information reported to the partners must be shown in a separate Note. Column (f) amounts should correspond to the partner’s statement for each trade or business or each aggregated trade distributive share of audit adjustments as finally determined (or or business. See below for an example of the information that AAR adjustments). Column (g) amounts should only include should be included in Part VI of the Form 8986. approved modifications with respect to the partner receiving the Form 8986. Only approved amended return and closing Note. Section 199A dividends should only be included in the agreement modifications should be included in column (g) first section 199A statement attached to Form 8986. above. All other modifications should be included in a separate Each trade or business should indicate if it is a PTP, an statement in Part VI. Aggregated, or an SSTB. See the Instructions for Schedule K-1 (Form 1065 or Form 1120-S). Applicable penalties. The applicability of penalties is determined at the audited partnership or AAR partnership level. If the partnership is a patron of a specified agricultural or In the penalties section of Part V, enter the penalty code horticultural cooperative, the partnership must also include a sections, descriptions, rates, adjustment line numbers, and total statement for each trade or business identifying the adjustment amount to which the penalty applies. adjustment(s) to qualified items of income, gain, deduction, and loss and W-2 wages allocable to qualified payments. Part VI—Statements Note. Because section 199A(g) deductions are reported as a Column (a), Line no./code—List the corresponding Part V cumulative amount and not per qualified trade or business, these column (a) Schedule K-1 line number and column (c) code (if should only be included once in the first statement of applicable) for each item for which a statement is included. adjustments to items allocable to qualified payments attached to Column (b), Statement—Include a detailed explanation of the Form 8986, regardless of how many statements may be amount(s) that correspond to the item in column (a). necessary. Supporting schedules and statements should be in a format Example. Assume Partnership ABC has one trade or that shows the original amount, the net change, and the correct business that is an SSTB and is not a patron in a specified amount for each item listed in the statement. If any column (b) agricultural or horticultural cooperative. On its filed return, statements exceed the space allowable in one box, continue in Partnership ABC reported the items shown in Table 1 on the next box with the same information in column (a). Statement A—QBI Pass-Through Entity Reporting, attached to Statements provided in addition to amounts in Part V. To Partner A’s Schedule K-1. further explain the effect of any adjustment, the Part VI Table 1. Example of Section 199A Related Amounts Reported to Partner A on Statement A—QBI Pass-Through Entity Reporting EIN: PTP Aggregated ■ SSTB Partner A’s share of: QBI or qualified PTP items subject to partner-specific determinations: Ordinary business income (loss) $200,000 Rental income (loss) $10,000 Royalty income (loss) Section 1231 gain (loss) $50,000 Other deductions $80,000 W-2 wages $50,000 UBIA of qualified property $60,000 Section 199A dividends $5,000 6 Instructions for Form 8986 (January 2024) |
Page 7 of 7 Fileid: … ns/i8986/202401/a/xml/cycle06/source 14:12 - 16-Jan-2024 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Assume the adjustments per audit increased Partner A’s share of ordinary income by $10,000 and royalty income by $5,000, and decreased other deductions by $20,000. Assume that all of the adjustments are determined to be qualified items of income, gain, deduction, and loss at the partnership level. Partnership ABC should include in Part VI of the Form 8986 sent to Partner A the information shown in Table 2. Table 2. Example of Part VI of Form 8986 EIN: As Reported Net Adjustments As Corrected Partner’s Share: PTP PTP Aggregated Aggregated ■ SSTB ■ SSTB QBI or qualified PTP items subject to partner-specific determinations: Ordinary business income (loss) $200,000 $10,000 $210,000 Rental income (loss) $10,000 $10,000 Royalty income (loss) $5,000 $5,000 Section 1231 gain (loss) $50,000 $50,000 Other deductions $80,000 ($20,000) $60,000 W-2 wages $50,000 $50,000 UBIA of qualified property $60,000 $60,000 Section 199A dividends $5,000 $5,000 The time needed to complete and file this form will vary Paperwork Reduction Act Notice. We ask for the information depending on individual circumstances. The estimated burden on this form to carry out the Internal Revenue laws of the United for business taxpayers filing this form is approved under OMB States. You are required to give us the information. We need it to control number 1545-0123 and is included in the estimates ensure that you are complying with these laws and to allow us to shown in the instructions for their business income tax return. figure and collect the right amount of tax. You are not required to provide the information requested on If you have comments concerning the accuracy of these time a form that is subject to the Paperwork Reduction Act unless the estimates or suggestions for making this form simpler, we would form displays a valid OMB control number. Books or records be happy to hear from you. See the instructions for the tax return relating to a form or its instructions must be retained as long as with which this form is filed. their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return information are confidential, as required by section 6103. Instructions for Form 8986 (January 2024) 7 |