1120-F

List of Foreign Partner's Interests in Partnerships

Agency
IRS
Revision
2025
Fillable fields
173
Pages
3
Official source
IRS form page
Checked
October 21, 2026
Fill 1120-F online
Page 1 of form 1120-F

Schedule P (Form 1120-F): List of Foreign Partner's Interests in Partnerships

Schedule P (Form 1120-F) is the 2025 schedule a foreign corporation uses to identify and reconcile its directly held partnership interests with its distributive shares of partnership effectively connected income (ECI), and its effectively connected outside tax basis in each interest.

The instructions say it is also used to report a foreign corporate partner's transfer of an interest in a partnership, and the gain or loss on the transfer, when the partnership is engaged in a trade or business within the United States or holds U.S. real property interests (sections 864(c)(8) and 897(g)). Most amounts come from the Schedule K-3 (Form 1065) the partnership issues, and several totals carry over to Schedule I (Form 1120-F).

The form says to attach it to Form 1120-F. You can fill out Schedule P free in your browser on this page and download it without an account.

What's on Schedule P (Form 1120-F)

Part I: partnership list

Name, address and EIN of each partnership, rows A to D, and column (d) asking whether the share is ECI with a U.S. trade or business under section 875.

Part II, lines 1 to 8

Summary of the partner's income and expenses from Schedule K-3 (Form 1065), Part X, including directly allocable interest and interest on U.S. booked liabilities.

Part III, lines 9 to 14

Average outside basis under Regulations sections 1.882-5(b) and 1.884-1(d)(3), the part allocable to ECI, and the income or asset method box.

Part IV: transfers

Each partnership interest transferred during the tax year, with the Part I row letter, percentage or units transferred, date acquired and date transferred.

Part V, lines 1 to 10

Gain or loss on each transfer: amount realized, outside basis, ordinary and capital pieces, recognized effectively connected gain or loss, and section 897(g) gain or loss.

How to fill out Schedule P (Form 1120-F)

  1. 1

    Part I

    List each directly owned partnership interest with ECI. The instructions say not to include disregarded entities, and to check Yes in column (d) when the corporation is engaged in a U.S. business through the partnership's activities.

  2. 2

    Part II

    Copy the amounts from Schedule K-3 (Form 1065), Part X. The form says to include the line 7 total on Schedule I, line 22, and the line 8 total on Schedule I, line 9, column (b).

  3. 3

    Part III

    Enter the average section 705 outside basis, adjust it for liabilities on lines 10a and 10b, and carry line 13 to Schedule I, line 5, column (b). On line 14 check the income or asset method.

  4. 4

    Part IV

    Use a separate line for each interest transferred, and for each acquisition date. The instructions say to enter -0- when a distribution leaves the ownership interest unchanged.

  5. 5

    Part V

    Enter the amount realized and outside basis, then lines 4, 6, 7 and 10 from Schedule K-3 (Form 1065), Part XIII. If no Part XIII arrived, the instructions say to contact the partnership.

  6. 6

    Carry the gain

    The instructions say line 8 goes to Form 4797, Part II, line 10, and line 9 goes to Form 8949 with "From Schedule P (Form 1120-F)" in column (a).

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Where it goes and related reporting

Where to send it

Attach it to Form 1120-F. The instructions point to the Instructions for Form 1120-F for the time, place, and manner of filing the return.

More than four partnerships

The instructions say to report extra interests on attached sheets in the same size and format, and to include them in the Total column.

Ties to Schedule I

The form says line 7 goes to Schedule I (Form 1120-F), line 22; line 8 to line 9, column (b); part of line 11 to line 8, column (b); and line 13 generally to line 5, column (b).

Treaty positions

If a treaty-based position applies to any amount in Part V, the instructions say to attach Form 8833 to Form 1120-F with a detailed explanation.

Withholding on transfers

The instructions say that, unless an exception applies, the transferee withholds tax on the amount realized and reports it on Form 8288-A.

Related forms

Who files Schedule P (Form 1120-F)?

  • Foreign corporate partners with ECI

    A foreign corporation whose distributive share from a partnership includes ECI lists that partnership in Part I and reconciles it in Parts II and III.

  • Partners treating a share as ECI

    If the corporation treats its share from a partnership not engaged in a U.S. business as ECI with its own business, the instructions say the entire share is reconciled on Schedule P.

  • Corporations that transfer an interest

    A foreign corporation that transfers an interest in a partnership engaged in a U.S. trade or business, or holding U.S. real property interests, completes Parts IV and V.

  • Treaty exceptions

    The instructions say Parts II and III are not required if no business profits are attributable to a U.S. permanent establishment and the corporation files a protective return with Form 8833.

  • When it is not filed

    The instructions say not to file it if no distributive share includes ECI, or expenses allocable to ECI, and there was no transfer of a covered partnership interest.

The instructions say a foreign corporation engaged directly or indirectly in a trade or business within the United States completes Schedule P for its directly owned partnership interests that have gross ECI, or expenses allocable to gross ECI, reported on Schedule K-3 (Form 1065). It is a corporate schedule, not a form for individuals.

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Questions about Form 1120-F

What is Schedule P (Form 1120-F) used for?

To identify and reconcile a foreign corporation's directly held partnership interests with its shares of partnership ECI and outside basis, and to report transfers of certain partnership interests.

Where do the numbers come from?

Mostly from the Schedule K-3 (Form 1065) the partnership issues: Part X for Parts II and III, and Part XIII for Part V.

What if the corporation has more than four partnership interests?

The form says to continue on a separate page. The instructions say to use the same size and format and to include the extra interests in the Total column.

Are lower-tier partnerships listed?

The instructions say not to report indirectly owned lower-tier partnership interests unless the corporation also owns a direct interest in that partnership.

When are Parts IV and V completed?

Only if the foreign corporation transferred a partnership interest subject to section 864(c)(8) or 897(g), according to the instructions.

What if the partnership did not send Schedule K-3 Part XIII?

The instructions say the corporation will need to contact the partnership to get the information for lines 4, 6, 7 and 10 of Part V.