I contributed appreciated software IP to a foreign partnership. Is Schedule O the main Form 8865 schedule I should expect?
I am a U.S. founder who transferred software-related intangible property into a foreign partnership in exchange for a partnership interest. The transfer was made as part of a restructuring and the initial FMV of the property was materially above tax basis. My advisers say the transaction should be nontaxable under partnership transfer rules, but the reporting side looks heavy.
I keep seeing references to Category 3 and Schedule O, and in some cases extra schedules if section 721(c) is involved. Before we finalize the file, I want to know whether Schedule O is the baseline disclosure and when the reporting expands beyond that.
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Our transfer adviser keeps mentioning Schedules G and H on top of Schedule O. Is that because this may be section 721(c) property?
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