GILTI, Subpart F & BEATAnswered

Our transfer adviser keeps mentioning Schedules G and H on top of Schedule O. Is that because this may be section 721(c) property?

M5
marcus_56a0subscriber
April 19, 2024 1,581 views 1 answer
form-8865section-721cschedule-gschedule-hforeign-partnershipproperty-transfer

I am a U.S. person who transferred appreciated operating assets into a foreign partnership as part of an internal group restructuring. The transaction was planned as tax-deferred, but now our reporting checklist includes Form 8865 Schedule O plus possible Schedules G and H. No one explained clearly why the extra schedules appeared.

The only clue I got was that the property may fall into a section 721(c) bucket because the built-in gain is significant and the partnership is foreign. I want to understand whether those extra schedules are tied specifically to that rule and not just routine Form 8865 over-preparation.

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