US Code

Public Law 119-73 (01/23/2026)

26 U.S.C. § 6046A

Returns as to interests in foreign partnerships

(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 sections 6679 and 7203.

Pub. L. 97–248, title IV, § 405(a)96 Stat. 669Pub. L. 105–34, title XI, § 1143(a)111 Stat. 983(Added , , ; amended , , .)

Editorial Notes

Amendments

Pub. L. 105–34, § 1143(a)(1)1997—Subsec. (a). , 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.”

Pub. L. 105–34, § 1143(a)(2)Subsecs. (d), (e). , 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)111 Stat. 984

section 6679 of this title“The amendments made by this section [amending this section and ] shall apply to transfers and changes after the date of the enactment of this Act [].”
, , , provided that:

Effective Date

Pub. L. 97–248, title IV, § 407(b)96 Stat. 671

section 6679 of this title“The amendments made by section 405 [enacting this section and amending ] 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 [].”
, , , provided that:

Special Rule for Certain International Satellite Partnerships

section 406 of Pub. L. 97–248section 6231 of this titleFor provision that this section is not applicable to certain international satellite partnerships, see , set out as a note under .