Fillable Printable Form 8858

What is a Form 8858 ?

Form 8858, transactions between the foreign disregarded entity of a foreign tax owner and the filer or other related entities, is for the certain persons, who is the citizen of the United States, but own an FDE which is called foreign disregarded entity directly, or, in certain circumstances, indirectly or constructively. Use this form as well as the schedules attached to satisfy or suffice the reporting requirements in sections 6011, 6012, 6031, and 6038, and related regulations.

Fillable Printable Form 8858

What is a Form 8858 ?

Form 8858

(Rev. December 2013)

Department of the Treasury

Internal Revenue Service

Information Return of U.S. Persons With Respect

To Foreign Disregarded Entities

▶

Information about Form 8858 and its separate instructions is at www.irs.gov/form8858.

Information furnished for the foreign disregarded entity’s annual accounting period (see

instructions) beginning

, 20 , and ending , 20

OMB No. 1545-1910

Attachment

Sequence No. 140

Name of person filing this return Filer’s identifying number

Number, street, and room or suite no. (or P.O. box number if mail is not delivered to street address)

City or town, state, and ZIP code

Filer’s tax year beginning , 20 , and ending , 20

Important: Fill in all applicable lines and schedules. All information must be in English. All amounts must be stated in

U.S. dollars unless otherwise indicated.

1a Name and address of foreign disregarded entity b(1) U.S. identifying number, if any

b(2) Reference ID number (see instructions)

c Country(ies) under whose laws organized and entity type under local tax law d Date(s) of organization e Effective date as foreign

disregarded entity

f If benefits under a U.S. tax treaty were claimed with respect to

income of the foreign disregarded entity, enter the treaty and

article number

g Country in which principal business

activity is conducted

h Principal business

activity

i Functional currency

2 Provide the following information for the foreign disregarded entity’s accounting period stated above.

a Name, address, and identifying number of branch office or agent (if any) in

the United States

b Name and address (including corporate department, if applicable) of person(s)

with custody of the books and records of the foreign disregarded entity, and

the location of such books and records, if different

3 For the tax owner of the foreign disregarded entity (if different from the filer) provide the following (see instructions):

a Name and address b Annual accounting period covered by the return (see instructions)

c(1) U.S. identifying number, if any

c(2) Reference ID number (see instructions)

d Country under whose laws organized e Functional currency

4 For the direct owner of the foreign disregarded entity (if different from the tax owner) provide the following (see instructions):

a Name and address b Country under whose laws organized

c U.S. identifying number, if any d Functional currency

5 Attach an organizational chart that identifies the name, placement, percentage of ownership, tax classification, and country of organization of all entities in the chain of

ownership between the tax owner and the foreign disregarded entity, and the chain of ownership between the foreign disregarded entity and each entity in which the

foreign disregarded entity has a 10% or more direct or indirect interest. See instructions.

For Paperwork Reduction Act Notice, see the separate instructions.

Cat. No. 21457L

Form

8858 (Rev. 12-2013)

Form 8858 (Rev. 12-2013)

Page 2

Schedule C Income Statement (see instructions)

Important: Report all information in functional currency in accordance with U.S. GAAP. Also, report each amount in U.S.

dollars translated from functional currency (using GAAP translation rules or the average exchange rate determined under

section 989(b)). If the functional currency is the U.S. dollar, complete only the U.S. Dollars column. See instructions for

special rules for foreign disregarded entities that use DASTM.

If you are using the average exchange rate (determined under section 989(b)), check the following box . . . . . .

Functional Currency U.S. Dollars

1 Gross receipts or sales (net of returns and allowances) . . . . . . . . . 1

2 Cost of goods sold . . . . . . . . . . . . . . . . . . . . . 2

3 Gross profit (subtract line 2 from line 1) . . . . . . . . . . . . . . 3

4 Other income. . . . . . . . . . . . . . . . . . . . . . . 4

5 Total income (add lines 3 and 4) . . . . . . . . . . . . . . . . 5

6 Total deductions . . . . . . . . . . . . . . . . . . . . . 6

7 Other adjustments . . . . . . . . . . . . . . . . . . . . . 7

8 Net income (loss) per books . . . . . . . . . . . . . . . . . . 8

Schedule C-1 Section 987 Gain or Loss Information

Note. See the instructions if there are multiple recipients of remittances

from the foreign disregarded entity.

(a)

Amount stated in

functional currency of

foreign disregarded entity

(b)

Amount stated in

functional currency of

recipient

1 Remittances from the foreign disregarded entity . . . . . . . . . . . 1

2 Section 987 gain (loss) of recipient . . . . . . . . . . . . . . . 2

Yes No

3 Were all remittances from the foreign disregarded entity treated as made to the direct owner? . . . . .

Did the tax owner change its method of accounting for section 987 gain or loss with respect to remittances

from the foreign disregarded entity during the tax year? . . . . . . . . . . . . . . . . . .

Schedule F Balance Sheet

Important: Report all amounts in U.S. dollars computed in functional currency and translated into U.S. dollars in

accordance with U.S. GAAP. See instructions for an exception for foreign disregarded entities that use DASTM.

Assets

(a)

Beginning of annual

accounting period

(b)

End of annual

accounting period

1 Cash and other current assets . . . . . . . . . . . . . . . . . 1

2 Other assets . . . . . . . . . . . . . . . . . . . . . . . 2

3 Total assets . . . . . . . . . . . . . . . . . . . . . . . 3

Liabilities and Owner’s Equity

4 Liabilities . . . . . . . . . . . . . . . . . . . . . . . . 4

5 Owner’s equity . . . . . . . . . . . . . . . . . . . . . . 5

6 Total liabilities and owner’s equity . . . . . . . . . . . . . . . . 6

Schedule G Other Information

Yes No

1 During the tax year, did the foreign disregarded entity own an interest in any trust?. . . . . . . . .

2 During the tax year, did the foreign disregarded entity own at least a 10% interest, directly or indirectly, in

any foreign partnership? . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3 Answer the following question only if the foreign disregarded entity made its election to be treated as

disregarded from its owner during the tax year: Did the tax owner claim a loss with respect to stock or

debt of the foreign disregarded entity as a result of the election? . . . . . . . . . . . . . . .

4 If the interest in the foreign disregarded entity is a separate unit under Reg. 1.1503(d)-1(b)(4) or part of a

combined separate unit under Reg. 1.1503(d)-1(b)(4)(ii) does the separate unit or combined separate unit

have a dual consolidated loss as defined in Reg. 1.1503(d)-1(b)(5)(ii)? . . . . . . . . . . . . .

If “Yes,” enter the amount of the dual consolidated loss

▶

Answer question 5a.

Form 8858 (Rev. 12-2013)

Page 3

Schedule G Other Information (continued)

Yes No

Was any portion of the dual consolidated loss in question 4 taken into account in computing consolidated

taxable income for the year? If “Yes,” go to 5b. If “No,” skip 5b and 5c . . . . . . . . . . . .

Was this a permitted domestic use of the dual consolidated loss under Reg. 1.1503(d)-6? If “Yes,” see

instructions and skip 5c. If “No,” go to 5c . . . . . . . . . . . . . . . . . . . . . .

If this was not a permitted domestic use, was the dual consolidated loss used to compute consolidated

taxable income as provided under Reg. 1.1503(d)-4? . . . . . . . . . . . . . . . . . .

If “Yes,” enter the separate unit's contribution to the cumulative consolidated taxable income (“cumulative

▶

See instructions.

6 During the tax year, did the foreign disregarded entity pay or accrue any foreign tax that was disqualified

for credit under section 901(m)? . . . . . . . . . . . . . . . . . . . . . . . . .

7 During the tax year, did the foreign disregarded entity pay or accrue foreign taxes to which section 909

applies, or treat foreign taxes that were previously suspended under section 909 as no longer suspended?

8 Answer the following question only if the tax owner of the foreign disregarded entity is a controlled foreign

corporation (CFC): Were there any intracompany transactions between the foreign disregarded entity and

the CFC or any other branch of the CFC during the tax year, in which the foreign disregarded entity acted

as a manufacturing, selling, or purchasing branch? . . . . . . . . . . . . . . . . . . .

Schedule H Current Earnings and Profits or Taxable Income (see instructions)

Important: Enter the amounts on lines 1 through 6 in functional currency.

Current year net income or (loss) per foreign books of account . . . . . . . . . . . . .

Total net additions . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Total net subtractions . . . . . . . . . . . . . . . . . . . . . . . . . . .

Current earnings and profits (or taxable income—see instructions) (line 1 plus line 2 minus line 3) . .

DASTM gain or loss (if applicable) . . . . . . . . . . . . . . . . . . . . . . .

Combine lines 4 and 5 . . . . . . . . . . . . . . . . . . . . . . . . . . .

7 Current earnings and profits (or taxable income) in U.S. dollars (line 6 translated at the average

exchange rate determined under section 989(b) and the related regulations (see instructions)) . . .

Enter exchange rate used for line 7

▶

Form 8858 (Rev. 12-2013)