INTRODUCTION
The I.R.S. recently released drafts of two new partnership
return schedules and accompanying instructions to replace,
supplement, and clarify the way partnership income, loss,
deductions, credits and other items from international transactions
are reported by a partnership to the I.R.S. and to its
partners.1
Partnerships that have no foreign activities or foreign partners
are not expected to be affected by these new forms.
EFFECTIVE DATES AND PURPOSE
Once finalized, partnerships (including limited liability
companies ("L.L.C.'s") taxed as partnerships) that
file Form 1065, U.S. Partnership Tax Return, would use
these two new forms for tax years beginning in 2021 (filing season
2022) to report items of international tax relevance.
