Instructions For Schedule A (Form 8804) - 2009 Page 2

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each of its installment payments of
Column (a). Enter payments made by
The partnership may use the adjusted
section 1446 tax during the tax year.
the date on line 4, column (a).
seasonal installment method only if the
However, see Regulations section
partnership’s base period percentage for
Columns (b), (c), and (d). Enter
1.1446-3(b)(3)(ii) for an exception. Also,
any 6 consecutive months of the tax year
payments made on or before the date on
see the Note below. In addition, the
is 70% or more. The base period
line 4 for that column and after the date
partnership may only use the prior year
percentage for any period of 6
on line 4 of the preceding column.
safe harbor if all of the following apply:
consecutive months is the average of the
Line 12. If any of the columns in line 12
Each installment payment that was
three percentages figured by dividing the
shows an underpayment, complete Part
made during the tax year, when averaged
ECTI for the corresponding 6 consecutive
VII to figure the penalty.
with all prior installment payments, must
month period in each of the 3 preceding
have been 25% of the partnership’s total
tax years by the ECTI for each of their
Parts IV Through VI
section 1446 tax liability under the prior
respective tax years. Figure the base
year safe harbor,
Extraordinary items. Generally, under
period percentage using the 6-month
The prior tax year consisted of 12
the annualized income installment
period in which the partnership normally
months,
method, extraordinary items must be
receives the largest part of its ECTI.
The partnership timely files (including
taken into account after annualizing the
Example. An amusement park with a
extensions) a U.S. return of partnership
ECTI for the annualization period. Similar
2009 calendar tax year receives the
income (e.g., Form 1065) for the prior tax
rules apply in determining ECTI under the
largest part of its taxable income during a
year, and
adjusted seasonal installment method. An
6-month period, May through October. To
The amount of ECTI for the prior tax
extraordinary item includes:
compute its base period percentage for
year is not less than 50% of the ECTI
Any item identified in Regulations
this 6-month period, the amusement park
shown on the current year Form 8804 that
section 1.1502-76(b)(2)(ii)(C)(1), (2), (3),
figures its ECTI for each May – October
is (or will be) timely filed.
(4), (7), and (8);
period in 2006, 2007, and 2008. It then
A section 481(a) adjustment; and
If the partnership is not permitted to
divides the ECTI for each May – October
Net gain or loss from the disposition of
use the prior year safe harbor method
period by the total ECTI for that particular
because any of the necessary conditions
25% or more of the fair market value of
tax year. The resulting percentages are:
described above is not met, skip line 2
the partnership’s business assets during
69% (.69) for May – October 2006, 74%
and enter on line 3 the amount from line
the tax year.
(.74) for May – October 2007, and 67%
1.
These extraordinary items must be
(.67) for May – October 2008. Because the
accounted for in the appropriate
Note. If the partnership qualifies for and
average of 69%, 74%, and 67% is 70%,
annualization period. However, a section
uses the exception under Regulations
the base period percentage for May
481(a) adjustment (unless the partnership
section 1.1446-3(b)(3)(ii) to switch to the
through October 2009 is 70%. Therefore,
makes the alternative choice under
standard option annualization method
the amusement park qualifies for the
Regulations section 1.6655-2(f)(3)(ii)(C))
during the tax year, the partnership
adjusted seasonal installment method.
is treated as an extraordinary item
should include on line 2 the total of all
Line 15. If the partnership has certain
occurring on the first day of the tax year in
installment payments that were made
extraordinary items, special rules apply.
which the item is taken into account in
during the tax year under both the prior
Do not include on line 15 the de minimis
determining ECTI.
year safe harbor method and the
extraordinary items that the partnership
standard option annualization method.
For more information regarding
chooses to include on line 22b. See
Attach a schedule that explains the
extraordinary items, see Regulations
Extraordinary items above.
computation.
section 1.6655-2(f)(3)(ii) and the
examples in Regulations section
Line 22b. If the partnership has certain
Part III. Figuring the
1.6655-2(f)(3)(vii). Also see Regulations
extraordinary items of $1 million or more
section 1.6655-3(d)(3).
from a transaction, or a section 481(a)
Underpayment
adjustment, special rules apply. Include
De minimis rule. Extraordinary items
Line 6. Enter the estimated tax
these amounts on line 22b for the
identified above resulting from a particular
payments made by the partnership for its
appropriate period. Also include on line
transaction that totals less than $1 million
tax year as indicated below. Include any
22b the de minimis extraordinary items
(other than a section 481(a) adjustment)
overpayment from line 13 of the
that the partnership chooses to exclude
may be annualized using the general
partnership’s 2008 Form 8804 that was
from line 15. See Extraordinary items
rules of Regulations section 1.6655-2(f),
credited to the partnership’s first
above.
or, if the partnership chooses, may be
installment period on its 2009 Form 8804.
taken into account after annualizing the
Line 23. Enter the amount by which line
If an installment is due on a Saturday,
ECTI for the annualization period.
22c is being reduced for state and local
Sunday, or legal holiday, payments made
taxes under Regulations section
Part IV. Adjusted Seasonal
on the next day that is not a Saturday,
1.1446-6(c)(1)(iii) and for certified foreign
Sunday, or legal holiday are considered
Installment Method
partner-level items submitted using Form
made on the due date to the extent the
8804-C. See Reductions for State and
payment is applied against that required
Note. Part IV does not reflect the lower
Local Taxes and Certification of
installment.
preferential rates permitted under
Deductions and Losses in the Instructions
Also include on line 6 any:
Regulations section 1.1446-3(a)(2).
for Forms 8804, 8805, and 8813 for
Section 1446 tax paid or withheld by
These were omitted because, for most
additional information.
another partnership in which the
taxpayers, the income reported in Part IV
partnership filing this Schedule A (Form
will be predominantly (or exclusively)
Part V. Annualized Income
8804) was a partner during the tax year.
ordinary income. If the partnership wishes
See the instructions for Form 8804, line
to consider lower preferential rates for
Installment Method
6b, in the Instructions for Forms 8804,
Part IV (and if the requirements outlined
8805, and 8813.
in the third paragraph of the line 31
Line 30. Annualization periods. Enter
Section 1445(a) or 1445(e)(1)(B) tax
instructions are met), it must attach a
on line 30, columns (a) through (d),
withheld from or paid by the partnership
schedule which appropriately expands
respectively, the annualization periods for
filing this Schedule A (Form 8804) during
lines 15 and 22 through 25 to show the
the option listed below. For example, if
the tax year for a disposition of a U.S. real
applicable special types of income or gain
the partnership elected Option 1, enter on
property interest. See the instructions for
and the applicable percentages (see, for
line 30 the annualization periods 2, 4, 7,
Form 8804, line 6c, in the Instructions for
example, lines 33 and 34 of this
and 10, in columns (a) through (d),
Forms 8804, 8805, and 8813.
schedule).
respectively.
-2-
Instructions for Schedule A (Form 8804) (2009)

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