I contributed software IP to a foreign partnership and ended up with 15%. Is that enough to trigger Form 8865 even though I do not control it?
I am a U.S. tax resident this year, originally from Brazil, and I contributed developed software rights to a foreign partnership based in Estonia. After the contribution I own 15%, but the business is still clearly controlled by other partners. Because I do not control the entity, I assumed the foreign-partnership filing rules would not really reach me.
The more I read, though, the more it looks like contributions can create their own filing category even without control. If that is right, I need to understand whether the filing is about my ownership percentage, the fact I transferred property, or both. I do not want to miss a return just because I used the wrong mental model for Form 8865.
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