Entity & Partnership

Foreign partnerships (Form 8865)

US persons with interests in foreign partnerships — including UK LLPs treated as partnerships — may need to file Form 8865.

Entity & Partnership
Overview

Why this filing matters

US persons with interests in foreign partnerships — including UK LLPs treated as partnerships — may need to file Form 8865.

Note — UK/overseas partnerships.

Who this is for

  • US partners in UK partnerships or LLPs

What you get

  • Category of filer determination
  • Form 8865 preparation
Our approach

Built for the cross-border edge cases.

Most US-UK filings fail the same way: a treaty position that wasn’t disclosed, a foreign account that slipped under FBAR thresholds, a PFIC election filed in the wrong year, a carry-forward not tracked from one preparer to the next. The cost of any single one of those is rarely catastrophic on its own — it’s the compounding over multiple filing seasons that quietly turns a clean tax life into a six-figure remediation project.

We start every engagement by looking at the edge cases first — the elections, the disclosures, the carry-forwards, the side-effects on next year’s return — and only then turn to the routine line items. The result is a filing that reads cleanly to anyone who picks it up next: another preparer, the IRS, or a successor in your own business.

  • Position memo on every meaningful election, with the reasoning written down for the next return
  • Carry-forwards (FTC, capital losses, PFIC basis) tracked year-on-year so nothing expires unused
  • Plain-English commentary on every position taken — the kind that makes a future audit a non-event
Reviewing UK company shareholdings for US disclosure
Our process

How we handle your foreign partnerships (form 8865)

Four steps from first call to filed return. Fixed fee confirmed before any work begins.

  1. 01

    Intake

    30-minute scoping call. We confirm your situation, required filings, and send a tailored document list.

  2. 02

    Review

    We analyse your position, flag any cross-border risks, and confirm the scope and fee before any work starts.

  3. 03

    Prepare

    Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

  4. 04

    File

    E-file with the IRS / FinCEN, send confirmations, and handle any follow-up notices or questions.

Pricing

Fixed fees — no surprises

Form 8865 preparation starts from £650 + VAT. Complex multi-category filings (contributions, dispositions, multiple partners) are quoted per case after scoping.

FAQs

Common questions about Foreign partnerships (Form 8865)

Do I always need to file if I'm in a UK partnership?
Only if you meet one of the Category 1–4 tests (typically >10% interest or specific ownership changes). Below the thresholds, no 8865 filing is needed — though 8938 might still apply to your partnership interest.
What's Category 1 vs Category 2?
Category 1 is a US person owning >50% of the partnership (you effectively report the whole partnership). Category 2 is a US person owning ≥10% when the partnership is majority-controlled by US persons.
Do I need to send K-1s to UK partners?
Only if the partnership is a US partnership. Form 8865 is for foreign partnerships, so typically no US K-1 goes to UK partners — but they may still need their own UK self-assessment reporting.
What about transfers of partnership interests?
Category 3 (contributions of property to the partnership) and Category 4 (changes in proportional interest) filings cover these events. Both are commonly missed in first-time compliance.

Ready to get this filed?

Tell us your situation and we'll confirm scope, a fixed fee, and the documents we need — usually within one business day.