Caution: DRAFT—NOT FOR FILING

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Note: The draft you are looking for begins on the next page.Caution: DRAFT—NOT FOR FILINGThis is an early release draft of an IRS tax form, instructions, or publication,which the IRS is providing for your information. Do not file draft forms and donot rely on draft forms, instructions, and publications for filing. We do notrelease draft forms until we believe we have incorporated all changes (exceptwhen explicitly stated on this coversheet). However, unexpected issuesoccasionally arise, or legislation is passed—in this case, we will post a new draftof the form to alert users that changes were made to the previously posted draft.Thus, there are never any changes to the last posted draft of a form and thefinal revision of the form. Forms and instructions generally are subject to OMBapproval before they can be officially released, so we post only drafts of themuntil they are approved. Drafts of instructions and publications usually havesome changes before their final release.Early release drafts are at IRS.gov/DraftForms and remain there after thefinal release is posted at IRS.gov/LatestForms. All information about all forms,instructions, and pubs is at IRS.gov/Forms.Almost every form and publication has a page on IRS.gov with a friendlyshortcut. For example, the Form 1040 page is at IRS.gov/Form1040; the Pub.501 page is at IRS.gov/Pub501; the Form W-4 page is at IRS.gov/W4; and theSchedule A (Form 1040/SR) page is at IRS.gov/ScheduleA. If typing in a linkabove instead of clicking on it, be sure to type the link into the address bar ofyour browser, not a Search box.If you wish, you can submit comments to the IRS about draft or final forms,instructions, or publications at IRS.gov/FormsComments. We cannot respond toall comments due to the high volume we receive and may not be able toconsider many suggestions until the subsequent revision of the product.If you have comments on reducing paperwork and respondent (filer) burden,with respect to draft or final forms, please respond to the relevant informationcollection through the Federal Register process; for more info, click here.

AH XSL/XMLUserid: CPMSchema: instrx Leadpct: 100%Fileid: ns/i8986/202112/a/xml/cycle02/sourcePt. size: 9Page 1 of 7DraftOk to Print(Init. & Date)10:52 - 15-Nov-2021The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.Instructions for Form 8986Department of the TreasuryInternal Revenue Service(December 2021)Partner’s Share of Adjustment(s) to Partnership-Related Item(s)(Required Under Sections 6226 and 6227)DRAFT AS OFNovember 16, 2021ContentsReminder . . . . . . . . . . . . . . .Purpose of Form . . . . . . . . . . .Definitions . . . . . . . . . . . . . . .General Instructions . . . . . . . . .Who Should Prepare Form8986 . . . . . . . . . . . . .Where To Submit Form8986 . . . . . . . . . . . . .Due Dates . . . . . . . . . . . .Withholding for ForeignPartners . . . . . . . . . . .Instructions for PartnersThat Receive Form 8986 .Specific Instructions . . . . . . . . .Part I—Information Aboutthe Entity Submitting ThisForm . . . . . . . . . . . . .Part II—Information Aboutthe Audited Partnershipor the Partnership ThatFiled an AAR . . . . . . . .Part III—Information Aboutthe Pass-Through PartnerIssuing and SubmittingThis Form 8986 . . . . . .Part IV—Information Aboutthe Partner ReceivingThis Form 8986 . . . . . .Part V—Partner’s TotalReviewed Year Income,Gain, Loss, Deductions,Credits, and Other Items .Part VI—Statements . . . . .Page. 1. 1. 1. 1. 1. 2. 2. 2. 2. 2. 3. 3. 3. 3. 3. 6Section references are to the Internal RevenueCode unless otherwise noted.Future DevelopmentsFor the latest information aboutdevelopments related to Form 8986 andits instructions, such as legislationenacted after they were published, go toIRS.gov/Form8986.ReminderThe Bipartisan Budget Act of 2015 (BBA)created a centralized partnership auditregime that replaced the partnership auditprocedures under the Tax Equity andFiscal Responsibility Act of 1982(TEFRA). Form 8986 was created forpartnerships to show each partner’s shareof adjustments to partnership-relateditems as a result of a BBA audit or BBAadministrative adjustment request (AAR).Purpose of FormForm 8986 is used by BBA partnerships tofurnish and transmit each partner’s shareNov 15, 2021of adjustments to partnership-relateditems.DefinitionsAAR partnership is a BBA partnership(see below) that has filed anadministrative adjustment request (AAR)under section 6227. For purposes of theseinstructions, AAR filers should assumethat the term “audited partnership”includes AAR partnerships.AAR partnership’s adjustment year isthe partnership tax year that includes theyear the AAR was filed with the IRS.Affected partner is a partner that held aninterest in the pass-through partner entityat any time during the tax year of thepass-through partner to which theadjustments in the statement relate.Audited partnership, for purposes ofForm 8986, is a BBA partnership thatmade the election under section 6226 tohave its partners report their share ofadjustments to partnership-related items.Audited partnership’s adjustment yearis the year that includes the date the courtdecision became final, if the partnershippetitioned the Tax Court. Otherwise, it isthe year that includes the date the finalpartnership adjustment (FPA) letter wasmailed, or the FPA waiver was executedby the IRS.BBA AAR is an administrative adjustmentrequest filed by a BBA partnership.BBA partnership is a partnership that issubject to the centralized partnership auditregime that was enacted into law bysection 1101 of the Bipartisan Budget Actof 2015.Designated individual (DI) is theindividual through whom an entitypartnership representative acts.Extended due date of the AARpartnership’s adjustment year returnis, for purposes of Form 8986, theextended due date of the AARpartnership’s adjustment year returnregardless of whether the partnership isrequired to file a return for the adjustmentyear or timely filed a request for anextension.Extended due date of the auditedpartnership’s adjustment year returnis, for purposes of Form 8986, theextended due date of the auditedpartnership’s adjustment year returnregardless of whether the partnership isrequired to file a return for the adjustmentyear or timely filed a request for anextension.Cat. No. 69668GFinally determined. The partnershipadjustment(s) become finally determinedupon the later of the expiration of the timeto file a petition under section 6234 or, if apetition is filed under section 6234, thedate when the court’s decision becomesfinal.First affected year is the partner’s taxyear that includes the end of the auditedpartnership’s reviewed year(s). Eachreviewed year of an audited partnershipshould have a corresponding first affectedyear for each partner.Imputed underpayment (IU) is theamount determined under sections 6225,6226, and 6227, and the regulationsthereunder.Partnership representative (PR) is theperson designated by the partnership orby the IRS under section 6223 and theregulations thereunder to act on behalf ofthe audited partnership.Pass-through partner is a pass-throughentity that holds an interest, either directlyor indirectly, in a partnership.Pass-through entities includepartnerships, S corporations, trusts, anddecedents’ estates. For purposes of Form8986, a pass-through entity is not a whollyowned entity disregarded as separatefrom its owner for federal tax purposes.Reporting year is the partner’s taxyear(s) that includes the date the auditedpartnership furnished the Forms 8986 toits partners.Reviewed year is the auditedpartnership’s tax year to which thepartnership adjustment(s) relates.Reviewed year adjustments areadjustments originating from thepartnership’s reviewed year(s).Reviewed year partner is any personthat held an interest in the auditedpartnership at any time during thepartnership’s reviewed year.General InstructionsWho Should Prepare Form 8986The following persons or entities shouldprepare Form 8986. Audited partnerships that have madean election under section 6226. Direct or indirect pass-through partnersthat receive a Form 8986 related to anaudited partnership if they choose tofurnish statements to their partners tofurther push out the adjustments. Partnerships that file an AAR undersection 6227 and either elect to push out

Page 2 of 710:52 - 15-Nov-2021Fileid: ns/i8986/202112/a/xml/cycle02/sourceThe type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.the resulting adjustments to their partnersor have adjustments that do not result inan IU. Direct or indirect pass-through partnersthat receive a Form 8986 related to anAAR partnership, if the direct or indirectpass-through partner chooses to furnishstatements to its partners to further pushout adjustments or have adjustments thatdo not result in an IU.Pass-through partners. Direct andindirect pass-through partners mustfurnish Forms 8986 to their partners andsubmit them to the IRS, along with Form8985, by the extended due date of theaudited partnership’s adjustment yearreturn (or the extended due date of theAAR partnership’s adjustment yearreturn). This date can be found in Part II,item F, of the Form 8986 that wasreceived by the pass-through partner.Failure to submit these forms by the duedate results in the pass-through partnerbeing liable for an IU.A pass-through partner can submitcorrected Forms 8986, along with Form8985, within 60 days of the original duedate without IRS permission. If correctedforms need to be submitted after the60-day correction period, the auditedpartnership must contact the IRS forpermission to submit. Figuring and paying an IU andsubmitting Form 8985 to the IRS. SeeForm 8985 and its instructions.One of these two options must becompleted by the extended due date ofthe audited partnership’s adjustment yearreturn (or the extended due date of theAAR partnership’s adjustment yearreturn).DRAFT AS OFNovember 16, 2021Where To Submit Form 8986Audited partnerships andpass-through partners of audited partnerships. Section 6241(10) gives the IRSauthority to require electronic submissionof anything required to be filed orsubmitted under section 6226(a). AuditedBBA Partnerships and their pass-throughpartners are required to submit Forms8985 and 8986 electronically. From theBBA website IRS.gov/BBAPartnerships,search for “Electronic Submission ofForms by Audited BBA Partnerships andtheir Pass-through Partners” for stepsrequired to submit electronically.AAR partnerships. AAR partnershipsthat are electing to push out adjustmentsto their partners or have adjustments thatdo not result in an inputed underpaymentmust include Form 8985 with their AARalong with Forms 8986. The Forms 8985and 8986 must be filed with, and in thesame manner, as the AAR.Pass-through partners of an AAR partnership. Pass-through partners of anAAR partnership must submit Form 8985to the IRS by fax at 888-981-6982, with orwithout Forms 8986, as applicable.Due DatesAudited partnerships. An auditedpartnership that has made an electionunder section 6226 must furnish Forms8986 to its partners and submit them tothe IRS, along with Form 8985, no laterthan 60 days after the date on which thepartnership adjustments are finallydetermined. Failure to furnish and submitby the due date results in the auditedpartnership being liable for the IU.An audited partnership can submitcorrected Forms 8986, along with Form8985, within 60 days of the original duedate without IRS permission. If correctedforms need to be submitted after the60-day correction period, the auditedpartnership must contact the IRS forpermission to submit.AAR partnerships. An AAR partnershipthat either elects to push out the resultingadjustments to its partners or hasadjustments that do not result in an IUmust furnish Forms 8986 to all partnersand include them with their AAR, alongwith Form 8985.Withholding for ForeignPartnersAn audited partnership may havewithholding and reporting obligations if itfurnishes a Form 8986 to a reviewed yearpartner that includes an adjustmentsubject to withholding under chapter 3(Withholding of Tax on Nonresident Aliensand Foreign Corporations) or chapter 4(Taxes To Enforce Reporting on CertainForeign Accounts). In those cases, theaudited partnership must withhold theamount required under chapter 3 orchapter 4 and deposit the amount with theIRS before the due date for furnishing theForm 8986. See Instructions for Form1042, Annual Withholding Tax Return forU.S. Source Income of Foreign Persons;or Form 8804, Annual Return forPartnership Withholding Tax (Section1446), for deposit procedures. Theaudited partnership must also file anapplicable withholding tax return, Form1042 or Form 8804, and the associatedinformation returns, Forms 1042-S,Foreign Person's U.S. Source IncomeSubject to Withholding; or Forms 8805,Foreign Partner's Information Statement ofSection 1446 Withholding Tax, for thecalendar year (if filing Forms1042/1042-S) or tax year (if filing Forms8804/8805) that includes the date onwhich the Form 8986 was furnished.If a pass-through partner fails totimely furnish and submit theCAUTION relevant statements, thepass-through partner is liable for an IU aswell as any penalties and interest withrespect to the adjustments reflected onthe Form 8986 received by thepass-through partner.!Other partners. All other partners thatreceive Form 8986 should report theinformation on Form 8978, Partner’sAdditional Reporting Year Tax, and attachthe Form 8978 to the partner’s reportingyear tax return. For more information, seeForm 8978 and its instructions.These partners may pay in advance tostop the running of interest. Pay by EFTPS, debit, or credit card, orDirect Pay (Forms 1040 only). Select Prepayment on BBA AAR/ExamPush Out as payment type. As applicable, apply payment to the taxform that will have the Form 8978 attachedto it.Specific InstructionsSubmitting a corrected form due to anincorrect TIN. If submitting a correctedform due to an incorrect TIN on apreviously submitted and acceptedoriginal Form 8986, you will need tosubmit two corrected forms:1. A corrected Form 8986 with thecorrect TIN, and2. A corrected Form 8986 with theincorrect TIN and zeros in Part IV sectionsE through G, and in Part V. Anytime acorrected Form 8986 is submitted, acorrected Form 8985 must also beincluded.Original or corrected. At the top of theform, check the appropriate box toindicate if the form is original or corrected.Pass-through partners. In general, apass-through partner that receives a Form8986 should take into account theadjustments reflected on the form byeither: Furnishing Forms 8986 to its ownpartners and submitting those forms,along with Form 8985, to the IRS orTracking number. Enter the outgoingtracking number shown on the relatedForm 8985 that was completed by anaudited BBA partnership or apass-through partner of an audited BBApartnership. This field should be left blankfor all Forms 8986 related to the filing of aForm 8985 by a BBA partnership that filedan administrative adjustment request(AAR) or a pass-though partner (direct orindirect) of a BBA partnership that filed anAAR.-2-Instructions for Form 8986 (Dec. 2021)Instructions for Partners ThatReceive Form 8986

Page 3 of 7Fileid: ns/i8986/202112/a/xml/cycle02/source10:52 - 15-Nov-2021The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.Audit control number. Enter the auditcontrol number that is provided oncorrespondence with the IRS.Pass-through partners can locate thisnumber at the top of the Form 8986 theyreceived. AAR partnerships, includingpass-through partners of an AARpartnership, should leave this field blank.city, state, country code, and ZIP code. Inthe state field, enter the two-letterabbreviation or the full name of the foreignprovince. U.S. partnerships leave thecountry code field blank. Foreignpass-through partners enter the countrycode found at Foreign Country Codes.Item B—Enter the pass-through partner’stax identification number.Item C—Enter the pass-through partner’stax year end to which the adjustmentsrelate.Item D—Enter the name of the entity thatissued the Form 8986 to the pass-throughpartner, if different from the auditedpartnership or AAR partnership in Part II.Item E—Enter the tax identificationnumber of the entity that issued the Form8986 to the pass-through partner, ifdifferent from the audited partnership orAAR partnership in Part II.change per audit or AAR (if none, enterzero), and the corrected amounts.Item G—Enter the components of thepartner’s capital account as originallyreported on Schedule K-1, the change peraudit or AAR (if none, enter zero), and thecorrected amounts.Part V—Partner’s TotalReviewed Year Income, Gain,Loss, Deductions, Credits, andOther ItemsDRAFT AS OFNovember 16, 2021Part I—Information About theEntity Submitting This FormItem A—Indicate which entity is issuingthis form by checking one of the boxes.Item B—Check the box that correspondsto the type of return normally filed by theentity issuing this form. If “Other,” alsoindicate the type of return filed on the lineprovided.Part II—Information About theAudited Partnership or thePartnership That Filed an AARItems A and B—On lines 1–6, enter thename and address of the partnership. Thename must be entered exactly as itappears on the Form 8985 associatedwith this Form 8986. For example, if youentered XYZ LLC on the Form 8985, youmust enter XYZ LLC on the Form 8986. Inthe state field, enter the two-letterabbreviation or the full name of the foreignprovince. U.S. partnerships leave thecountry code field blank. Foreignpartnerships enter the country code foundat Foreign Country Codes.Item C—Enter the partnership's taxidentification number. This number mustbe entered exactly as it appears on theForm 8985 associated with this Form8986.Item D—Enter the tax year end date of thereviewed year of the partnership. Eachreviewed year should have a separateForm 8986. This form must be completedfor reviewed years that have adjustmentsrelated to an audit or an AAR.Item E—Enter the partnership’sadjustment year ending date.Item F—Enter the extended due date ofthe partnership’s adjustment year taxreturn, regardless of whether thepartnership has filed for an extension. ForAAR partnerships, this will be theextended due date of the tax year the AARwas filed.Item G—Enter the date the partnershipfurnished the Forms 8986 to its partners.Part IV—Information About thePartner Receiving This Form8986Part III—Information About thePass-Through Partner Issuingand Submitting This Form 8986Item A—On lines 1–6, enter the partner’sname, address, city, state, country code,and ZIP code. In the state field, enter thetwo-letter abbreviation or the full name ofthe foreign province. U.S. partners leavethe country code field blank. Foreignpartners enter the country code found atForeign Country Codes.Item B—Enter the partner’s taxidentification number.Item C—Indicate by checking box 1 or 2 ifthe partner is a general partner or LLCmember manager, limited partner, or LLCmember. Indicate by checking box 3 or 4 ifthe partner is a domestic or foreignpartner.Item D—Indicate if, for tax purposes, thepartner is an individual, S corporation, Ccorporation, partnership, or other type ofentity by checking one of the boxes 1–5. If“Other,” indicate what type on the lineprovided. Also indicate if the partner is aretirement plan or other tax-exempt entity.Note: If you entered a social securitynumber as the partner's tax identificationnumber in box B, you should check box 1.You should only select boxes 2–5 whenyou have entered an EIN in box B.Item E—Enter the partner’s percentageshare of partnership profits, losses, andcapital as originally reported onSchedule K-1, the change per audit orAAR (if none, enter zero), and thecorrected percentage.Item F—Enter the partner’s share of totalliabilities—recourse and nonrecourse—asoriginally reported on Schedule K-1, theInstructions for Form 8986 (Dec. 2021)-3-Item A—On lines 1–6, enter thepass-through partner’s name, address,Note. Adjustments that increase aschedule K-1 item as originally reported oras corrected should be shown as positiveamounts; adjustments that decreaseschedule K-1 items should be shown asnegative amounts.For columns (a)–(c), refer to the relevantSchedule K-1 and instructions. Seespecial instructions for changes toSchedule K-3. For each item that wasadjusted, enter the following.Column (a), Line number—TheSchedule K-1 line number that wasadjusted. If you have changes toSchedule K-3, enter “K3” (no dash).Column (b), Line title—The title of theSchedule K-1 item that was adjusted. Foradjustments to Schedule K-3, enter thepart, section (if applicable), line, andcolumn reference.Column (c), Code*—If applicable, usethe code letters listed in the Schedule K-1instructions that correspond to the linenumber shown in column (a). Foradjustments to Schedule K-3, ifapplicable, enter the country code. Seethe Schedule K-3 instructions.Column (d), As reported—Enter theoriginal amount reported to the partner ontheir Schedule K-1 or as previouslycorrected by the partnership.Column (e), Check if statement in PartVI—Check the box in this column if theitem shown in column (a) has acorresponding statement in Part VI. Foradjustments to Schedule K-3, enter anexplanation of the adjustment on Part VI ofForm 8986 with reference to the entry onPart V, column (b).

Page 4 of 710:52 - 15-Nov-2021Fileid: ns/i8986/202112/a/xml/cycle02/sourceThe type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.Example 1On its filed 2021 return, partnership ABC reported 1,000 of other foreign source interest income with respect to Country Y onPartner A’s Schedule K-3. Partnership ABC later determined that the amount should have been reported as passive categoryforeign 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. PartnershipABC includes in Part V of the Form 8986 sent to Partner A the information as follows.DRAFT AS OFNovember 16, 2021Example 1. Part V. Partner’s Total Reviewed Year Income, Gain, Loss, Deduction, Credits, and Other ItemsSchedule K-1(a)Line number(b)Line title(c)Code*K-3Part II, Sec. 1, Line 6A,column (e)YYK-3Part II, Sec. 1, Line 6A,column (c)YY(d)As reported(e)Check if statementin Part VI(f)Reviewed yearadjustments asfinally determinedPartnership ABC includes in Part VI of the Form 8986 sent to Partner A the information as follows.Example 1. Part VI. Statements(a)Line no./codeK-3(b)StatementLine titleCodeAs reportedReview year adjustmentsAs correctedPart II, Sec. 1, Line 6A,column (e)YY 1,000 (1,000) 0Part II, Sec. 1, Line 6A,column (c)YY 0 1,000 1,000Example 2On December 15, 2021, after a Country Y audit of the tax year ending December 31, 2019, Partnership ABC paid withholding tax toCountry Y with respect to passive category interest income. Partner A’s share of the withholding tax is 2,000. Partnership ABC didnot report any foreign tax redeterminations on its Schedule K-3 filed with the Form 1065 for the 2021 tax year. To reflect theredetermination on the tax year 2021 Schedule K-3, on December 30 , 2022, ABC filed an AAR and attached Forms 8985 and8986. The two-letter code from the list at Foreign Country Codes for Country Y is YY. Partnership ABC includes the followinginformation in Part V of the Form 8986 sent to Partner A.Example 2. Part V. Partner’s Total Reviewed Year Income, Gain, Loss, Deduction, Credits, and Other ItemsSchedule K-1(a)Line number(b)Line title(c)Code*K-3Part III, Sec. 4, Line 3A,column (d) foreignYY(d)As reported(e)Check If statementin Part VI(f)Reviewed yearadjustments asfinally determinedBecause all the adjustment information cannot be entered on Part V, Partnership A includes the following additional information inPart VI of Form 8986.-4-Instructions for Form 8986 (Dec. 2021)

Page 5 of 710:52 - 15-Nov-2021Fileid: ns/i8986/202112/a/xml/cycle02/sourceThe type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.Example 2. Part VI. Statements(a)Line number(b)StatementK-3Line: Part III, Sec. 4, Line 3A, column (d) foreignCountry Code: “YY”Type of tax: WHTIRelated tax year: 2019Date tax paid: 12/15/2021As reported amount: 0Reviewed year adjustments: 2,000As corrected amount: 2,000DRAFT AS OFNovember 16, 2021Example 3On its filed return, Partnership ABC reported on Partner A’s Schedule K-3, Part VIII, as follows.Example 3. K-3, Part VIII.LineEntryA1234BPASCiiiUnitEuro QBU11a1iYY1a1ii1000Subsequent to filing its return, Partnership ABC determines that the amount reported on Line 1a1ii of Partner A’s Schedule K-3, PartVIII, should have been 1,500. Partnership ABC makes the correction by filing an AAR with Forms 8985 and 8986 attached. Itincludes the following information in Part V of the Form 8986.Example 3. Part V. Partner’s Total Reviewed Year Income, Gain, Loss, Deduction, Credits, and Other ItemsSchedule K-1(a)Line number(b)Line title(c)Code*K-3Part VIII, Line 1a1YY(d)As reported(e)Check If statementin Part VI(f)Reviewed yearadjustments asfinally determinedPartnership ABC must report the adjustment amount with respect to Partner A in Part VI of Form 8986 as follows.Example 3. Part VI. Statements(a)Line number/codeK-3(b)StatementPart VIII, K-3 LineAs reportedA1234BPASCiiiUnitEuro QBU11a1iYY1a1ii1,000Instructions for Form 8986 (Dec. 2021)-5-AdjustmentsAs corrected5001,500

Page 6 of 710:52 - 15-Nov-2021Fileid: ns/i8986/202112/a/xml/cycle02/sourceThe type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing.Column (f), Reviewed yearadjustments as finally determined—Enter the partner’s share of reviewed yearadjustments that corresponds to the lineitem in column (a).Column (g), Approved modifications—Enter the partner’s share of the totalmodifications approved by the IRS withrespect to the item adjusted. Modificationsrelated to the filing of an AAR should notbe shown in this column.Column (h), Net (column (f) minuscolumn (g))—Enter the amount in column(f) less the amount in column (g).“International,” in column (b) and a checkmark in column (e). Then, in the free formsection of Part V, enter the changes in the“Description, Line Number, AmountReported, Adjustments, and AsCorrected” format. Note: If theadjustments cannot be fully reflected inPart V, fax separate statement(s), andenter a note in Part V indicating that youhave faxed the statement(s) to888-981-6982.Note. Section 199A dividends shouldonly be included in the first section 199Astatement attached to Form 8986.Each trade or business should indicateif it is a PTP, Aggregated, or an SSTB.See the Instructions for Schedule K-1(Form 1065 or Form 1120-S).If the partnership is a patron of aspecified agricultural or horticulturalcooperative, the partnership must alsoinclude a statement for each trade orbusiness identifying the adjustment(s) toqualified items of income, gain, deduction,and loss and W-2 wages allocable toqualified payments.DRAFT AS OFNovember 16, 2021Loans and other items recharacterizedas distributions to partners. If areviewed year adjustment has been madeto change a partner loan or other item to apartner distribution, this adjustment shouldbe reported with the column (a) linenumber that corresponds to theSchedule K-1 “Distributions” category andwith column (c), code A, for cashdistributions if the partner received money,and as a code C if the partner receivedproperty other than money.Disguised sale adjustments.Distributions to a partner that werechanged as part of an audit proceeding todisguised sale proceeds under section707 should be reported with the column(a) line number that corresponds to theSchedule K-1 “Other”category and withcolumn (c), code DS. The partnershipshould also include a statement in Part VIdescribing the asset that was sold, theproceeds, and the tax basis of the asset atthe time of the contribution.Note. Column (f) amounts shouldcorrespond to the partner’s distributiveshare of audit adjustments as finallydetermined (or AAR adjustments).Column (g) amounts should only includeapproved modifications with respect to thepartner receiving the Form 8986. Onlyapproved amended return and closingagreement modifications should beincluded in column (g) above. All othermodifications should be included in aseparate statement in Part VI.Applicable penalties. The applicabilityof penalties is determined at the auditedpartnership or AAR partnership level. Inthe penalties section of Part V, enter thepenalty code sections, descriptions, rates,adjustment line numbers, and totaladjustment amount to which the penaltyapplies.How to enter adjustments related toForm K-3. If you have changes toSchedule K-3, the changes for all partnersin the aggregate should be shown on theForm 8985. Enter “K3” (no dash) incolumn (a) of the 8985, Part IV,Part VI—StatementsColumn (a), Line no./code—List thecorresponding Part V column (a)Schedule K-1 line number and column (c)code (if applicable) for each item for whicha statement is included.Column (b), Statement—Include adetailed explanation of the amount(s) thatcorrespond to the item in column (a).Supporting schedules and statementsshould be in a format that shows theoriginal amount, the net change, and thecorrect amount for each item listed in thestatement. If any column (b) statementsexceed the space allowable in one box,continue in the next box with the sameinformation in column (a).Statements that need to be sent separately by fax. Adjustments that cannot befully reflected in Part VI can be faxedseparately to 888-981-6982.

partnership adjustment (FPA) letter was mailed, or the FPA waiver was executed by the IRS. BBA AAR is an administrative adjustment request filed by a BBA partnership. BBA partnership is a partnership that is subject to the centralized partnership audit regime that was enacted into

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