SCHEDULE O                                   Transfer of Property to a Foreign Partnership 
(Form 8865)                                                      (Under Section 6038B)                                                   OMB No. 1545-1668
(Rev. October 2021)                            ▶ Attach to Form 8865. See the Instructions for Form 8865. 
Department of the Treasury             ▶ Go to www.irs.gov/Form8865 for instructions and the latest information.
Internal Revenue Service
Name of transferor                                                                                                    Filer’s identifying number

Name of foreign partnership                                                         EIN (if any)                      Reference ID number (see instructions)

  1 a        Is the partnership a section 721(c) partnership (as defined in Regulations section 1.721(c)-1(b)(14))? See 
             instructions . . .      . .     . .   .   .    . .  .    .   .  .    . . . .        . . . . . .    .     . . .  .     .   .        Yes     No
       b     If “Yes,” was the gain deferral method applied to avoid the recognition of gain upon the contribution of property?                 Yes     No
  2          Was any intangible property transferred considered or anticipated to be, at the time of the transfer or at any
             time thereafter, a platform contribution as defined in Regulations section 1.482-7(c)(1)? .              . . .  .     .   .        Yes     No
Part I             Transfers Reportable Under Section 6038B
                            (a)                (b)                 (c)                  (d) 
      Type of property      Date of          Description of   Fair market value       Cost or other        (e)               (f)                   (g) 
                            transfer         property         on date of transfer       basis          Recovery period  Section 704(c)   Gain recognized 
                                                                                                                        allocation method       on transfer
Cash
Stock,     notes 
receivable      and 
payable,       and other 
     securities
     
Inventory
     
     Tangible 
     property 
used      in trade 
or     business
     Intangible 
      property 
described       in 
section     197(f)(9)
Intangible      property,  
other     than intangible 
property       described  
in     section 197(f)(9)
      
     Other 
      property
     
Totals
  3          Enter the transferor’s percentage interest in the partnership: (a) Before the transfer                   %   (b) After the transfer             %
Supplemental Information Required To Be Reported  (see instructions):

Part II            Dispositions Reportable Under Section 6038B
                                                                                                         (f) 
               (a)            (b)                (c)                  (d)               (e)            Depreciation          (g)                    (h) 
           Type of          Date of            Date of           Manner of          Gain recognized    recapture        Gain allocated          Depreciation 
           property        original transfer disposition         disposition        by partnership     recognized         to partner     recapture allocated 
                                                                                                       by partnership                           to partner

Part III           Is  any  transfer  reported  on  this  schedule  subject  to  gain  recognition  under  section  904(f)(3)  or 
                   section 904(f)(5)(F)? .   . .   .   .    . .  .    .   .  .    . . . .        . . . . . .    .     . . .   ▶                 Yes     No
For Paperwork Reduction Act Notice, see the Instructions for Form 8865.                              Cat. No. 25909U         Schedule O (Form 8865) 10-2021