Form 8865

Return of U.S. Persons With Respect to Certain Foreign Partnerships, filed under §§6038, 6038B and 6046A. It mirrors Form 5471's structure with four categories: control of the partnership (broadly, more than 50%), a 10%-or-greater interest in a US-controlled partnership, contributions of property to a foreign partnership, and certain acquisitions, dispositions or changes in proportional interest. The trap is characterisation rather than the form itself — many foreign entities are partnerships for US purposes even where local law calls them something else, and an entity can be elected into or out of the classification on Form 8832. The §6038 penalty structure follows Form 5471: $10,000 per form per year, with continuation penalties, whether or not tax is due.