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                                                                                                           Department of the Treasury
                                                                                                           Internal Revenue Service
Instructions for Form 8986

(December 2021)
Partner’s Share of Adjustment(s) to Partnership-Related Item(s)
(Required Under Sections 6226 and 6227)

Contents                                    Page    of adjustments to partnership-related        to file a petition under section 6234 or, if a 
Reminder . . . . . . . . . . . . . . . . . . . 1    items.                                       petition is filed under section 6234, the 
Purpose of Form .   . . . . . . . . . . . . . . 1                                                date when the court’s decision becomes 
Definitions . . . . . . . . . . . . . . . . . . . 1 Definitions                                  final or the date the closing agreement is 
General Instructions .  . . . . . . . . . . . . 1   AAR partnership is a BBA partnership         entered into between the IRS and the 
Who Should Prepare Form                             (see below) that has filed an                partnership.
8986          . . . . . . . . . . . . . . . . . 1   administrative adjustment request (AAR)      First affected year is the partner’s tax 
Where To Submit Form                                under section 6227.                          year that includes the end of the audited 
8986          . . . . . . . . . . . . . . . . . 2   AAR partnership’s adjustment year is         partnership’s reviewed year(s). Each 
Due Dates .       . . . . . . . . . . . . . . . 2   the partnership tax year that includes the   reviewed year of an audited partnership 
Withholding for Foreign                             year the AAR was filed with the IRS.         should have a corresponding first affected 
Partners .          . . . . . . . . . . . . . . 2   Affected partner is a partner that held an   year for each partner.
Instructions for Partners                           interest in a pass-through partner at any    Imputed underpayment (IU) is the 
That Receive Form 8986 .                . . . . 2   time during the tax year of the              amount determined under sections 6225, 
Specific Instructions . . . . . . . . . . . . . 2   pass-through partner to which the            6226, and 6227, and the regulations 
Part I—Information About                            adjustments in the statement relate.         thereunder.
the Entity Submitting This                          Audited partnership, for purposes of         Partnership representative (PR) is the 
Form          . . . . . . . . . . . . . . . . . 3   Form 8986, is a BBA partnership that         person designated by the partnership or 
Part II—Information About                           made the election under section 6226 to      by the IRS under section 6223 and the 
the Audited Partnership                             have its partners report their share of      regulations thereunder to act on behalf of 
or the Partnership That                             adjustments to partnership-related items.    the audited partnership.
Filed an AAR .            . . . . . . . . . . . 3   Audited partnership’s adjustment year        Pass-through partner is a pass-through 
Part III—Information About                          is the year that includes the date the court entity that holds an interest, either directly 
the Pass-Through Partner                            decision became final, if the partnership    or indirectly, in a partnership. 
Issuing and Submitting                              petitioned the Tax Court. Otherwise, it is   Pass-through entities include 
This Form 8986              . . . . . . . . . . 3   the year that includes the date the final    partnerships, S corporations, trusts, and 
Part IV—Information About                           partnership adjustment (FPA) letter was      decedents’ estates. For purposes of Form 
the Partner Receiving                                                                            8986, a pass-through entity is not a wholly 
This Form 8986              . . . . . . . . . . 3   mailed, or the FPA waiver was executed 
Part V—Partner’s Total                              by the IRS.                                  owned entity disregarded as separate 
Reviewed Year Income,                               BBA AAR is an administrative adjustment      from its owner for federal tax purposes.
Gain, Loss, Deductions,                             request filed by a BBA partnership.          Reporting year is the partner’s tax 
Credits, and Other Items .              . . . . 3   BBA partnership is a partnership that is     year(s) that includes the date the audited 
Part VI—Statements            . . . . . . . . . 5   subject to the centralized partnership audit partnership furnished the Forms 8986 to 
Section references are to the Internal Revenue      regime that was enacted into law by          its partners.
Code unless otherwise noted.                        section 1101 of the Bipartisan Budget Act    Reviewed year is the audited 
                                                    of 2015.                                     partnership’s tax year to which the 
Future Developments                                 Designated individual (DI) is the            partnership adjustment(s) relates.
For the latest information about                    individual through whom an entity            Reviewed year adjustments are 
developments related to Form 8986 and               partnership representative acts.             adjustments originating from the 
its instructions, such as legislation               Extended due date of the AAR                 partnership’s reviewed year(s).
enacted after they were published, go to            partnership’s adjustment year return         Reviewed year partner is any person 
IRS.gov/Form8986.                                   is, for purposes of Form 8986, the           that held an interest in the audited 
                                                    extended due date of the AAR                 partnership at any time during the 
Reminder                                            partnership’s adjustment year return         partnership’s reviewed year.
                                                    regardless of whether the partnership is 
The Bipartisan Budget Act of 2015 (BBA)             required to file a return for the adjustment General Instructions
created a centralized partnership audit             year or timely filed a request for an 
regime that replaced the partnership audit          extension.                                   Who Should Prepare Form 8986
procedures under the Tax Equity and                 Extended due date of the audited             The following persons or entities should 
Fiscal Responsibility Act of 1982                   partnership’s adjustment year return         prepare Form 8986.
(TEFRA). Form 8986 was created for                  is, for purposes of Form 8986, the           Audited partnerships that have made 
partnerships to show each partner’s share           extended due date of the audited             an election under section 6226.
of adjustments to partnership-related               partnership’s adjustment year return         Direct or indirect pass-through partners 
items as a result of a BBA audit or BBA             regardless of whether the partnership is     that receive a Form 8986 related to an 
administrative adjustment request (AAR).            required to file a return for the adjustment audited partnership if they choose to 
                                                    year or timely filed a request for an        furnish statements to their partners to 
Purpose of Form                                     extension.                                   further push out the adjustments.
Form 8986 is used by BBA partnerships to            Finally determined. The partnership          Partnerships that file an AAR under 
furnish and transmit each partner’s share           adjustment(s) become finally determined      section 6227 and either elect to push out 
                                                    upon the later of the expiration of the time the resulting adjustments to their partners 

Jan 26, 2022                                                    Cat. No. 69668G



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or have adjustments that do not result in    furnish Forms 8986 to their partners and    Figuring and paying an IU and 
an IU.                                       submit them to the IRS, along with Form     submitting Form 8985 to the IRS, where 
Direct or indirect pass-through partners   8985, by the extended due date of the       the adjustments result in an IU to the 
that receive a Form 8986 related to an       audited partnership’s adjustment year       pass-through entity. See Form 8985 and 
AAR partnership, if the direct or indirect   return (or the extended due date of the     its instructions.
pass-through partner chooses to furnish      AAR partnership’s adjustment year           One of these two options must be 
statements to its partners to further push   return). This date can be found in Part II, completed by the extended due date of 
out adjustments or have adjustments that     item F, of the Form 8986 that was           the audited partnership’s adjustment year 
do not result in an IU.                      received by the pass-through partner.       return (or the extended due date of the 
                                             Failure to submit these forms by the due    AAR partnership’s adjustment year 
Where To Submit Form 8986                    date results in the pass-through partner    return).
Audited partnerships and                     being liable for an IU.
                                                                                                 If a pass-through partner fails to 
pass-through partners of audited part-         A pass-through partner can submit           !     timely furnish and submit the 
nerships. Section 6241(10) gives the IRS     corrected Forms 8986, along with Form       CAUTION relevant statements, the 
authority to require electronic submission   8985, within 60 days of the original due    pass-through partner is liable for an IU as 
of anything required to be filed or          date without IRS permission. If corrected   well as any penalties and interest with 
submitted under section 6226(a). Audited     forms need to be submitted after the        respect to the adjustments reflected on 
BBA Partnerships and their pass-through      60-day correction period, the audited       the Form 8986 received by the 
partners are required to submit Forms        partnership must contact the IRS for        pass-through partner.
8985 and 8986 electronically. From the       permission to submit.
BBA website IRS.gov/BBAPartnerships,                                                     Other partners.  All other partners that 
search for “Electronic Submission of         Withholding for Foreign                     receive Form 8986 should report the 
Forms by Audited BBA Partnerships and        Partners                                    information on Form 8978, Partner’s 
their Pass-through Partners” for steps       An audited partnership may have             Additional Reporting Year Tax, and attach 
required to submit electronically.           withholding and reporting obligations if it the Form 8978 to the partner’s reporting 
AAR partnerships. AAR partnerships           furnishes a Form 8986 to a reviewed year    year tax return. For more information, see 
that are electing to push out adjustments    partner that includes an adjustment         Form 8978 and its instructions.
to their partners or have adjustments that   subject to withholding under chapter 3        These partners may pay in advance to 
do not result in an imputed underpayment     (Withholding of Tax on Nonresident Aliens   stop the running of interest.
must include Form 8985 with their AAR        and Foreign Corporations) or chapter 4      Pay by EFTPS, debit, or credit card, or 
along with Forms 8986. The Forms 8985        (Taxes To Enforce Reporting on Certain      Direct Pay (Forms 1040 only).
and 8986 must be filed with, and in the      Foreign Accounts). In those cases, the      Select Prepayment on BBA AAR/Exam 
same manner, as the AAR.                     audited partnership must pay the amount     Push Out as payment type.
                                             of tax required to be withheld under        As applicable, apply payment to the tax 
Pass-through partners of an AAR part-        chapter 3 or chapter 4 before the due date  form that will have the Form 8978 attached 
nership. Pass-through partners of an         of the audited partnership's adjustment     to it.
AAR partnership must submit Form 8985        year return (without regard to extension) 
to the IRS by fax at 888-981-6982, with or   or the extended due date of the audited 
                                                                                         Specific Instructions
without Forms 8986, as applicable.           partnership's adjustment year return in the 
Due Dates                                    case of a pass-through partner. See         Submitting a corrected form due to an 
                                             Instructions for Form 1042, Annual          incorrect TIN.   If submitting a corrected 
Audited partnerships.   An audited           Withholding Tax Return for U.S. Source      form due to an incorrect TIN on a 
partnership that has made an election        Income of Foreign Persons; or Form 8804,    previously submitted and accepted 
under section 6226 must furnish Forms        Annual Return for Partnership Withholding   original Form 8986, you will need to 
8986 to its partners and submit them to      Tax (Section 1446), for deposit             submit two corrected forms:
the IRS, along with Form 8985, no later      procedures. The audited partnership must      1. A corrected Form 8986 with the 
than 60 days after the date on which the     also file an applicable withholding tax     correct TIN, and
partnership adjustments are finally          return, Form 1042 or Form 8804, and the 
determined. Failure to furnish and submit    associated information returns, Forms         2. A corrected Form 8986 with the 
by the due date results in the audited       1042-S, Foreign Person's U.S. Source        incorrect TIN and zeros in Part IV sections 
partnership being liable for the IU.         Income Subject to Withholding; or Forms     E through G, and in Part V. Anytime a 
  An audited partnership can submit          8805, Foreign Partner's Information         corrected Form 8986 is submitted, a 
corrected Forms 8986, along with Form        Statement of Section 1446 Withholding       corrected Form 8985 must also be 
8985, within 60 days of the original due     Tax, for the calendar year (if filing Forms included.
date without IRS permission. If corrected    1042/1042-S) or tax year (if filing Forms   Original or corrected. At the top of the 
forms need to be submitted after the         8804/8805) that includes the date on        form, check the appropriate box to 
60-day correction period, the audited        which the Form 8986 was furnished.          indicate if the form is original or corrected.
partnership must contact the IRS for         Instructions for Partners That              Tracking number. Enter the outgoing 
permission to submit.
                                             Receive Form 8986                           tracking number shown on the related 
AAR partnerships. An AAR partnership                                                     Form 8985 that was completed by an 
that either elects to push out the resulting Pass-through partners. In general, a        audited BBA partnership or a 
adjustments to its partners or has           pass-through partner that receives a Form   pass-through partner of an audited BBA 
adjustments that do not result in an IU      8986 should take into account the           partnership. This field should be left blank 
must furnish Forms 8986 to all partners      adjustments reflected on the form by        for all Forms 8986 related to the filing of a 
and include them with their AAR, along       either:                                     Form 8985 by a BBA partnership that filed 
with Form 8985.                              Furnishing Forms 8986 to its own          an administrative adjustment request 
                                             partners and submitting those forms,        (AAR) or a pass-though partner (direct or 
Pass-through partners.  Direct and           along with Form 8985, to the IRS or
indirect pass-through partners must 

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indirect) of a BBA partnership that filed an  city, state, country code, and ZIP code. In  reported on Schedule K-1, the change per 
AAR.                                          the state field, enter the two-letter        audit or AAR (if none, enter zero), and the 
                                              abbreviation or the full name of the foreign corrected amounts.
Audit control number. Enter the audit 
                                              province. U.S. partnerships leave the 
control number that is provided on                                                         Part V—Partner’s Total 
                                              country code field blank. Foreign 
correspondence with the IRS.                                                               Reviewed Year Income, Gain, 
                                              pass-through partners enter the country 
Pass-through partners can locate this 
                                              code found at Foreign Country Codes.
number at the top of the Form 8986 they                                                    Loss, Deductions, Credits, and 
                                              Item B—Enter the pass-through partner’s 
received. AAR partnerships, including                                                      Other Items
                                              tax identification number.
pass-through partners of an AAR                                                            Note. Adjustments that increase a 
                                              Item C—Enter the pass-through partner’s 
partnership, should leave this field blank.                                                schedule K-1 item as originally reported or 
                                              tax year end to which the adjustments 
Part I—Information About the                  relate.                                      as corrected should be shown as positive 
Entity Submitting This Form                   Item D—Enter the name of the entity that     amounts; adjustments that decrease 
                                              issued the Form 8986 to the pass-through     schedule K-1 items should be shown as 
Item A—Indicate which entity is issuing       partner, if different from the audited       negative amounts.
this form by checking one of the boxes.       partnership or AAR partnership in Part II.   For columns (a)–(c), refer to the relevant 
Item B—Check the box that corresponds         Item E—Enter the tax identification          Schedule K-1 and instructions. See 
to the type of return normally filed by the   number of the entity that issued the Form    special instructions for changes to 
entity issuing this form. If “Other,” also    8986 to the pass-through partner, if         Schedule K-3. For each item that was 
indicate the type of return filed on the line different from the audited partnership or    adjusted, enter the following.
provided.                                     AAR partnership in Part II.                  Column (a), Line number—The 
                                                                                           Schedule K-1 line number that was 
Part II—Information About the                 Part IV—Information About the                adjusted. If you have changes to 
Audited Partnership or the                    Partner Receiving This Form                  Schedule K-3, enter “K3” (no dash).
Partnership That Filed an AAR                 8986                                         Column (b), Line title—The title of the 
                                                                                           Schedule K-1 item that was adjusted. For 
Items A and B—On lines 1–6, enter the         Item A—On lines 1–6, enter the partner’s     adjustments to Schedule K-3, enter the 
name and address of the partnership. The      name, address, city, state, country code,    part, section (if applicable), line, and 
name must be entered exactly as it            and ZIP code. In the state field, enter the  column reference.
appears on the Form 8985 associated           two-letter abbreviation or the full name of  Column (c), Code—If applicable, use the 
with this Form 8986. For example, if you      the foreign province. U.S. partners leave    code letters listed in the Schedule K-1 
entered XYZ LLC on the Form 8985, you         the country code field blank. Foreign        instructions that correspond to the line 
must enter XYZ LLC on the Form 8986. In       partners enter the country code found at     number shown in column (a). For 
the state field, enter the two-letter         Foreign Country Codes.                       adjustments to Schedule K-3, if 
abbreviation or the full name of the foreign  Item B—Enter the partner’s tax               applicable, enter the country code. See 
province. U.S. partnerships leave the         identification number.                       the Schedule K-3 instructions. If no 
country code field blank. Foreign             Item C—Indicate by checking box 1 or 2 if    specific code applies, enter “NA.”
partnerships enter the country code found     the partner is a general partner or LLC      Column (d), As reported—Enter the 
at Foreign Country Codes.                     member manager, limited partner, or LLC      original amount reported to the partner on 
Item C—Enter the partnership's tax            member. Indicate by checking box 3 or 4 if   their Schedule K-1 or as previously 
identification number. This number must       the partner is a domestic or foreign         corrected by the partnership. For 
be entered exactly as it appears on the       partner.                                     adjustments to Schedule K-3, do not enter 
Form 8985 associated with this Form           Item D—Indicate if, for tax purposes, the    amounts on column (d).
8986.                                         partner is an individual, S corporation, C   Column (e), Check if statement in Part 
Item D—Enter the tax year end date of the     corporation, partnership, or other type of   VI—Check the box in this column if the 
reviewed year of the partnership. Each        entity by checking one of the boxes 1–5. If  item shown in column (a) has a 
reviewed year should have a separate          “Other,” indicate what type on the line      corresponding statement in Part VI. For 
Form 8986. This form must be completed        provided. Also indicate if the partner is a  adjustments to Schedule K-3, enter an 
for reviewed years that have adjustments      retirement plan or other tax-exempt entity.  explanation of the adjustment on Part VI of 
related to an audit or an AAR.                Note: If you entered a social security       Form 8986 with reference to the entry on 
Item E—Enter the partnership’s                number as the partner's tax identification   Part V, column (b).
adjustment year ending date.                  number in box B, you should check box 1. 
Item F—Enter the extended due date of         You should only select boxes 2–5 when 
the partnership’s adjustment year tax         you have entered an EIN in box B.
return, regardless of whether the             Item E—Enter the partner’s percentage 
partnership has filed for an extension. For   share of partnership profits, losses, and 
AAR partnerships, this will be the            capital as originally reported on 
extended due date of the tax year the AAR     Schedule K-1, the change per audit or 
was filed.                                    AAR (if none, enter zero), and the 
Item G—Enter the date the partnership         corrected percentage.
furnished the Forms 8986 to its partners.     Item F—Enter the partner’s share of total 
Part III—Information About the                liabilities—recourse and nonrecourse—as 
                                              originally reported on Schedule K-1, the 
Pass-Through Partner Issuing                  change per audit or AAR (if none, enter 
and Submitting This Form 8986                 zero), and the corrected amounts.
Item A—On lines 1–6, enter the                Item G—Enter the components of the 
pass-through partner’s name, address,         partner’s capital account as originally 

Instructions for Form 8986 (Dec. 2021)                      -3-



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Example 1
On its filed 2021 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 2021 return, ABC filed an AAR on 
November 10, 2022, 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)

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

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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                    distributions if the partner received money, Applicable penalties.   The applicability 
adjustments as finally determined          and as a code C if the partner received      of penalties is determined at the audited 
Enter the partner’s share of reviewed year   property other than money.                   partnership or AAR partnership level. In 
adjustments that corresponds to the line                                                  the penalties section of Part V, enter the 
                                             Disguised sale adjustments. 
item in column (a). For adjustments to                                                    penalty code sections, descriptions, rates, 
                                             Distributions to a partner that were 
Schedule K-3, do not enter amounts on                                                     adjustment line numbers, and total 
                                             changed as part of an audit proceeding to 
column (f).                                                                               adjustment amount to which the penalty 
                                             disguised sale proceeds under section 
Column (g), Approved modifications                                                      applies.
                                             707 should be reported with the column 
Enter the partner’s share of the total 
                                             (a) line number that corresponds to the 
modifications approved by the IRS with                                                    Part VI—Statements
                                             Schedule K-1 “Other” category and with 
respect to the item adjusted. Modifications                                               Column (a), Line no./code—List the 
                                             column (c), code DS. The partnership 
related to the filing of an AAR should not                                                corresponding Part V column (a) 
                                             should also include a statement in Part VI 
be shown in this column. For adjustments                                                  Schedule K-1 line number and column (c) 
                                             describing the asset that was sold, the 
to Schedule K-3, do not enter amounts on                                                  code (if applicable) for each item for which 
                                             proceeds, and the tax basis of the asset at 
column (g).                                                                               a statement is included.
                                             the time of the contribution.
Column (h), Net (column (f) minus                                                         Column (b), Statement—Include a 
column (g))—Enter the amount in column       Note.  Column (f) amounts should             detailed explanation of the amount(s) that 
(f) less the amount in column (g). For       correspond to the partner’s distributive     correspond to the item in column (a).
adjustments to Schedule K-3, do not enter    share of audit adjustments as finally 
amounts on column (h).                       determined (or AAR adjustments).             Supporting schedules and statements 
                                             Column (g) amounts should only include       should be in a format that shows the 
Loans and other items recharacterized                                                     original amount, the net change, and the 
                                             approved modifications with respect to the 
as distributions to partners. If a           partner receiving the Form 8986. Only        correct amount for each item listed in the 
reviewed year adjustment has been made       approved amended return and closing          statement. If any column (b) statements 
to change a partner loan or other item to a                                               exceed the space allowable in one box, 
                                             agreement modifications should be 
partner distribution, this adjustment should                                              continue in the next box with the same 
                                             included in column (g) above. All other 
be reported with the column (a) line                                                      information in column (a).
                                             modifications should be included in a 
number that corresponds to the 
                                             separate statement in Part VI.
Schedule K-1 “Distributions” category and                                                 Statements that need to be sent sepa-
with column (c), code A, for cash                                                         rately by fax. Adjustments that cannot be 
                                                                                          fully reflected in Part VI can be faxed 

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separately to 888-981-6982. All faxed         not per qualified trade or business, these include a statement for each trade or 
statements to be associated with a Form       should only be included once in the first  business identifying the adjustment(s) to 
8986 should have the following                section 199A statement attached to Form    qualified items of income, gain, deduction, 
information at the top of the statement:      8986, regardless of how many statements    and loss and W-2 wages allocable to 
“Statement for Form 8986,” Submitting         may be necessary.                          qualified payments.
Entity Name, Submitting Entity TIN,           Adjustments that increase or decrease 
Partner’s TIN (if related to Form 8986),      section 199A information reported to the   Note.  Because section 199A(g) 
Tax Year (should be the same as the year      partners must be shown in a separate       deductions are reported as a cumulative 
in the Form 8986 Part II, section D), and     statement for each trade or business or    amount and not per qualified trade or 
Audit Control Number (if applicable). All     each aggregated trade or business. See     business, these should only be included 
changes should be reported in the             below for an example of the information    once in the first statement of adjustments 
“Description, Line Number, Amount             that should be included in Part VI of the  to items allocable to qualified payments 
Reported, Adjustments, and As                 Form 8986.                                 attached to Form 8986, regardless of how 
Corrected” format. This section can also                                                 many statements may be necessary.
be used to report any intervening year        Note.  Section 199A dividends should       Example. Assume Partnership ABC 
adjustments that result from related review   only be included in the first section 199A has one trade or business that is an SSTB 
year adjustments. If reporting intervening    statement attached to Form 8986.           and is not a patron in a specified 
year adjustments be sure to list in the tax   Each trade or business should indicate     agricultural or horticultural cooperative. On 
year, line number, as reported,               if it is a PTP, Aggregated, or an SSTB.    its filed return, Partnership ABC reported 
adjustments, and as corrected format.         See the Instructions for Schedule K-1      the items shown in Table 1 on Statement 
Statements related to section 199A in-        (Form 1065 or Form 1120-S).                A—QBI Pass-Through Entity Reporting, 
                                                                                         attached to Partner A’s Schedule K-1.
formation.                                    If the partnership is a patron of a 
                                              specified agricultural or horticultural 
Note. Because section 199A dividends          cooperative, the partnership must also 
are reported as a cumulative amount and 

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

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.

                                                                      -6-                Instructions for Form 8986 (Dec. 2021)



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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

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Instructions for Form 8986 (Dec. 2021)                   -7-






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