Internal Revenue Code · 26 U.S.C.

§ 6046A. Returns as to interests in foreign partnerships

In force Text current through Public Law 119-121 (October 9, 2026) release point 119-121

Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).

Cite as 26 U.S.C. § 6046A

At a glance

Read from the text, the source credit and the official notes. Not part of the law.

Status: In force
Added: September 3, 1982 by Pub. L. 97–248
Last amended: August 5, 1997 by Pub. L. 105–34
Amendments: 1 dated changes in the source credit
Length: 5 subsections · 262 words · about 1 min to read
Cross-references: cites 3; cited by 1 Code section and 1 other regulation
Regulations: 1 issued under this section

¶(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.

(Added Pub. L. 97–248, title IV, § 405(a), Sept. 3, 1982, 96 Stat. 669; amended Pub. L. 105–34, title XI, § 1143(a), Aug. 5, 1997, 111 Stat. 983.)

Regulations under this section

Treasury regulations (26 CFR) issued under § 6046A

§ 1.6046A-1 Return requirement for United States persons who acquire or dispose of an interest in a foreign partnership, or whose proportional interest in a foreign partnership changes substantially.

Cross-references

Computed from the citations in the text of Title 26 and 26 CFR.

This section cites 3 other sections

Cited by 1 Code section

§ 6038B(b)(1)(A) Notice of certain transfers to foreign persons

Cited in 1 regulation not issued under it

§ 1.6038-3 Information returns required of certain United States persons with respect to controlled foreign partnerships (CFPs).

Amendment history

From the source credit and the official notes, newest first.

August 5, 1997Amended by Pub. L. 105–34Parts changed in 1997: (a) (d)
September 3, 1982Added by Pub. L. 97–248

Where it sits in the Code

Nearby sections

Official notes

Show the Law Revision Counsel's notes (amendments, effective dates)

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).

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 Partnerships

For 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.