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Title 26, Internal Revenue CodeRelease 119-110

§6046A Returns as to Interests in Foreign Partnerships

Title 26 › Subtitle F — Procedure and Administration › CHAPTER 61 — INFORMATION AND RETURNS › Subchapter A — Returns and Records › PART III — INFORMATION RETURNS › Subpart B — Information Concerning Transactions With Other Persons › § 6046A

Last updated Sep 22, 2026|Official source

Summary

U.S. persons must file a return when they get an interest in a foreign partnership, sell part of their interest, or have a big change in their share. This rule only applies if they had or will have at least a 10% interest before or after the change, or if the change equals at least a 10% interest (see section 6038(e)(3)(C)). The Treasury Secretary will decide the form and the information required. File within 90 days after you become required to file, unless the Secretary allows more time. Penalties are in sections 6679 and 7203.

Full Legal Text

Title 26, §6046A

Internal Revenue Code, Source: USLM XML via OLRC

(a)Requirement of return
Any United States person, except to the extent otherwise provided by regulations—
(1)who acquires any interest in a foreign partnership,
(2)who disposes of any portion of his interest in a foreign partnership, or
(3)whose proportional interest in a foreign partnership changes substantially,
shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.
(b)Form and contents of return
Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.
(c)Time for filing return
Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.
(d)10-percent interest
For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).
(e)Cross reference
For provisions relating to penalties for violations of this section, see section 6679 and 7203.

Legislative History

Notes & Related Subsidiaries

Editorial Notes

Amendments

1997—Subsec. (a). Pub. L. 105–34, § 1143(a)(1), inserted at end “Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.” Subsecs. (d), (e). Pub. L. 105–34, § 1143(a)(2), added subsec. (d) and redesignated former subsec. (d) as (e).

Statutory Notes and Related Subsidiaries

Effective Date

of 1997 Amendment Pub. L. 105–34, title XI, § 1143(c), Aug. 5, 1997, 111 Stat. 984, provided that: “The

Amendments

made by this section [amending this section and section 6679 of this title] shall apply to transfers and changes after the date of the enactment of this Act [Aug. 5, 1997].”

Effective Date

Pub. L. 97–248, title IV, § 407(b), Sept. 3, 1982, 96 Stat. 671, provided that: “The

Amendments

made by section 405 [enacting this section and amending section 6679 of this title] shall apply with respect to acquisitions or dispositions of, or substantial changes in, interests in foreign partnerships occurring after the date of the enactment of this Act [Sept. 3, 1982].” Special Rule for Certain International Satellite PartnershipsFor provision that this section is not applicable to certain international satellite partnerships, see section 406 of Pub. L. 97–248, set out as a note under section 6231 of this title.

Reference

Citations & Metadata

Citation

26 U.S.C. § 6046A

Title 26, Internal Revenue Code

Last Updated

Sep 22, 2026

Release point: 119-110