8865

Partners' Distributive Share Items—International

Agency
IRS
Revision
2025
Fillable fields
2106
Pages
14
Official source
IRS form page
Checked
October 21, 2026
Fill 8865 online
Page 1 of form 8865

Schedule K-2 (Form 8865): Partners' Distributive Share Items, International

Schedule K-2 (Form 8865), Partners' Distributive Share Items, International, is a 14-page schedule for the 2025 tax year. The Instructions for Form 8865 say Schedule K-2 is an extension of Schedule K of Form 8865 and is used to report items of international tax relevance from the operation of a partnership. The top of the schedule says to attach it to Form 8865.

Form 8865 is the Return of U.S. Persons With Respect to Certain Foreign Partnerships. In the filing requirements chart of the instructions, Schedule K-2 is checked for Category 1 filers only. The instructions say Schedule K-3 (Form 8865) is generally used to report each partner's share of the items reported on Schedule K-2.

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What's on Schedule K-2 (Form 8865)

Header and items A and B

Name of partnership, EIN (if any) and reference ID number, then Yes or No questions A1 to A8 on whether Parts I through VIII apply, and box B(1) for an amended K-2.

Part I: other international information

The partnership's other current year international information: checkboxes for additional specified attachments, such as gain on personal property sale, foreign oil and gas taxes, Form 5471 information, partner loan transactions and dual consolidated loss.

Part II: foreign tax credit limitation

Section 1 lists gross income and Section 2 lists deductions, in columns for U.S. source, foreign branch, passive, general and other category income, income sourced by partner, and total.

Part III: information for Form 1116 or 1118

Sections for R&E expenses apportionment factors, interest expense apportionment factors, FDII deduction apportionment factors, foreign taxes and other tax information.

Parts IV to VI

Part IV gives information on partners' section 250 deduction for Form 8993, Part V lists distributions from foreign corporations to the partnership, and Part VI covers partners' section 951(a)(1) and section 951A inclusions.

Parts VII and VIII

Part VII holds information on passive foreign investment companies (PFICs) and qualified electing funds. Part VIII holds partners' information for the base erosion and anti-abuse tax under section 59A.

How to fill out Schedule K-2 (Form 8865)

  1. 1

    Identify the partnership

    Enter the name of the partnership, its EIN if it has one, and the reference ID number. The Instructions for Form 8865 describe the reference ID number as a number assigned to a foreign partnership to keep track of it from tax year to tax year.

  2. 2

    Schedules K and K-1, line 16

    The instructions say that if the partnership had items of international tax relevance, see the Instructions for Schedules K-2 and K-3 (Form 8865) to decide whether to check the box and attach Schedules K-2 and K-3.

  3. 3

    Answer A1 to A8

    Check Yes or No for each of Parts I through VIII. The form says that for a Yes answer, complete and attach that part.

  4. 4

    Mark an amended schedule

    Check box B(1) when the schedule is an amended K-2. Box B(2) is reserved for future use.

  5. 5

    Complete the parts that apply

    Fill in the lines and columns of each part answered Yes. Many lines say see instructions, and Part I asks for a description and statement for other international items.

  6. 6

    Attach it to Form 8865

    The schedule says Attach to Form 8865. Each partner's share of these items then goes on that partner's Schedule K-3 (Form 8865).

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Where it goes, deadlines and penalties

Where it goes

Schedule K-2 is attached to Form 8865. The instructions say to attach Form 8865 to the filer's income tax return (or, if applicable, partnership or exempt organization return) and file both by the due date, including extensions, for that return.

No income tax return

If the filer does not have to file an income tax return, the instructions say Form 8865 is filed separately with the IRS at the time and place an income tax return would be filed.

Partnerships that file Form 1065

If the foreign partnership files Form 1065, the instructions say a Category 1 filer may attach Form 1065 Schedule K-2 and the other Form 1065 schedules listed there in place of the Form 8865 schedules.

Penalties

The instructions list a $10,000 penalty for each tax year of each foreign partnership when Category 1 and 2 filers do not furnish the required information on time, with additional penalties of up to $50,000 for each failure after an IRS notice.

Detailed instructions

The Instructions for Form 8865 have a short section on Schedules K-2 and K-3 and point to the separate Instructions for Schedules K-2 and K-3 (Form 8865) for more information.

Related forms

Who fills out Schedule K-2 (Form 8865)?

  • Category 1 filers

    The filing requirements chart in the Instructions for Form 8865 checks Schedule K-2 for Category 1 filers. The instructions define a Category 1 filer as a U.S. person who controlled the foreign partnership at any time during the partnership's tax year.

  • What control means

    The instructions say control of a partnership is ownership of more than a 50% interest in the partnership, and that there may be more than one Category 1 filer for a partnership in a tax year.

  • U.S. persons of any kind

    The instructions define a U.S. person as a citizen or resident of the United States, a domestic partnership, a domestic corporation, and any estate or trust that isn't foreign.

  • Multiple Category 1 filers

    When more than one U.S. person qualifies as a Category 1 filer, the instructions say only one of them is required to file Form 8865, and that single form holds the information each of them would have reported.

  • Other categories of filers

    The chart does not check Schedule K-2 for Category 2, 3 or 4 filers. It checks Schedule K-3 (Form 8865) for Category 1 and Category 2 filers.

The schedule is part of the Form 8865 package that a U.S. person files about a foreign partnership. It is not a form the partnership sends to its partners.

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Questions about Form 8865

Who files Schedule K-2 (Form 8865)?

The filing requirements chart in the Instructions for Form 8865 checks Schedule K-2 for Category 1 filers, U.S. persons who controlled the foreign partnership during its tax year.

How is Schedule K-2 different from Schedule K-3?

The instructions say Schedule K-2 is an extension of Schedule K and reports the partnership's items of international tax relevance. Schedule K-3 is an extension of Schedule K-1 and is generally used to report each partner's share of those items.

Is Schedule K-2 filed by itself?

No. The schedule says Attach to Form 8865, and the instructions say Form 8865 is attached to the filer's income tax return.

Can the Form 1065 version be used instead?

The instructions say that if the foreign partnership files Form 1065, a Category 1 filer may attach Form 1065 Schedule K-2 in place of the Form 8865 schedule.

Do all eight parts have to be filled in?

Questions A1 to A8 ask whether each of Parts I through VIII applies. The form says to complete and attach a part when the answer is Yes.

Which tax year does this version cover?

This is the 2025 schedule. The Instructions for Form 8865 say to file the 2025 Form 8865 with the income tax return for the tax year beginning in 2025.