SCHEDULE O                                        Transfer of Property to a Foreign Partnership 
(Form 8865)(Rev. December 2018)                                       (Under Section 6038B)                                                   OMB No. 1545-1668
                                                    ▶ Attach to Form 8865. See the Instructions for Form 8865. 
Department of the Treasury               ▶ Go to www.irs.gov/Form8865 for instructions and the latest information.
Internal Revenue Service
Name of transferor                                                                                                         Filer’s identifying number

Name of foreign partnership                                                              EIN (if any)                      Reference ID number (see instructions)

  1 a       Is the partnership a section 721(c) partnership (as defined in Temporary Regulations section  
            1.721(c)-1T(b)(14))? See instructions .              . .  .    .   .  .    . . . .        . . . . . .    .     . . .  .   .     .        Yes     No
       b    If “Yes,” was the gain deferral method applied to avoid the recognition of gain upon the contribution of property?                       Yes     No
  2         Was any intangible property transferred considered or anticipated to be, at the time of the transfer or at any
            time thereafter, a platform contribution as defined in Regulations section 1.482-7(c)(1)? .                    . . .  .   .     .        Yes     No
Part I             Transfers Reportable Under Section 6038B
                                (a)                 (b)                 (c)                  (d) 
      Type of property          Date of           Description of   Fair market value       Cost or other        (e)               (f)                (g) 
                                transfer          property         on date of transfer       basis          Recovery period  Section 704(c)   Gainrecognized 
                                                                                                                             allocationmethod        ontransfer 
Cash
Stock,     notes 
receivable      and 
payable,       and other 
     securities
     
Inventory
     
     Tangible 
     property 
used     in trade 
or     business
     Intangible 
      property 
described       in 
section     197(f)(9)
Intangible      property,  
other     than intangible 
property       described  
in     section 197(f)(9)
      
     Other 
      property
     
Totals
  3         Enter the transferor’s percentage interest in the partnership: (a) Before the transfer                         %   (b) After the transfer             %
Supplemental Information Required To Be Reported  (see instructions):

Part II            Dispositions Reportable Under Section 6038B
                                                                                                              (f) 
               (a)              (b)                 (c)                    (d)               (e)            Depreciation          (g)                    (h) 
           Type of              Date of             Date of           Manner of          Gain recognized    recapture        Gain allocated          Depreciation 
           property             original transfer disposition         disposition        bypartnership      recognized         to partner     recapture allocated 
                                                                                                            by partnership                           to partner

Part III           Is any transfer reported on this schedule subject to gain recognition under section 904(f)(3) or 
                   section 904(f)(5)(F)? .        . .   .   .    . .  .    .   .  .    . . . .        . . . . . .    .     . . .   ▶                 Yes     No
For Paperwork Reduction Act Notice, see the Instructions for Form 8865.                                   Cat. No. 25909U         Schedule O (Form 8865) 12-2018