8804 Schedule A Penalty for Underpayment of Estimated Section 1446 Tax B

Penalty for Underpayment of Estimated
Section 1446 Tax by Partnerships

Schedule A
(Form 8804)

OMB No. 1545-0123

2023

Attach to Form 8804.
Go to www.irs.gov/Form8804 for instructions and the latest information.

Department of the Treasury
Internal Revenue Service

Employer identification number

Name

Note: Generally, the partnership isn’t required to file this Schedule A (see Part I below for exceptions) because the IRS will figure any penalty
owed and bill the partnership. However, the partnership may still use this Schedule A to figure the penalty. If so, enter the amount from line 65
of this Schedule A on line 8 of Form 8804, but don’t attach this Schedule A.

Part I

Reasons for Filing—Check the boxes below that apply. If any boxes are checked, the partnership must file
Schedule A (Form 8804) even if it doesn’t owe a penalty. See instructions.
The partnership is using the adjusted seasonal installment method.
The partnership is using the annualized income installment method.

Part II

Current Year and Prior Year Safe Harbors

1

Enter the total section 1446 tax shown on the partnership’s 2023 Form 8804, line 5f. If less than $500,
don’t complete or file this form. The partnership doesn’t owe the penalty . . . . . . . . . .

2

Enter the total section 1446 tax that would have been due for 2022, without regard to reductions for
certified foreign partner-level items, on the effectively connected taxable income (ECTI) allocable to
foreign partners for 2022.
Caution: This line 2 amount only applies if certain conditions are met. See instructions .

3

Part III

Figuring the Underpayment
(a)

Installment due dates. Enter in columns (a) through (d)
the 15th day of the 4th, 6th, 9th, and 12th months of the
partnership’s tax year . . . . . . . . . . .

4

5

Required installments. If the partnership uses the
adjusted seasonal installment method and/or the
annualized income installment method, enter the amounts
from line 43. If neither of those methods is used, enter
25% (0.25) of line 3 above in each column . . . . .

5

6

Estimated section 1446 tax paid or credited for each
period. See instructions. For column (a) only, enter the
amount from line 6 on line 10 . . . . . . . . .

6

4

.

.

.

.

.

Enter the smaller of line 1 or line 2. If the partnership is required to skip line 2, enter the amount from
line 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
(b)

1

2
3
(c)

(d)

Complete lines 7 through 13 of one column before
going to the next column.
7

Enter amount, if any, from line 13 of the preceding column

7

8

Add lines 6 and 7

8

9

Add amounts on lines 11 and 12 of the preceding column

9

10
11

Subtract line 9 from line 8. If zero or less, enter -0- . .
If the amount on line 10 is zero, subtract line 8 from line 9.
Otherwise, enter -0- . . . . . . . . . . . .

10

12

Underpayment. If line 10 is less than or equal to line 5,
subtract line 10 from line 5. Then, go to line 7 of the next
column. Otherwise, go to line 13 . . . . . . . .

13

Overpayment. If line 5 is less than line 10, subtract line 5
from line 10. Then, go to line 7 of the next column . .

.

.

.

.

.

.

.

.

.

.

.

.

11

12

13
Go to Part VII on page 5 to figure the penalty. Don’t go to Part VII if there are no entries on line 12—no penalty is owed.
For Paperwork Reduction Act Notice, see separate instructions.

Cat. No. 40853F

Schedule A (Form 8804) 2023

Page 2

Schedule A (Form 8804) 2023

Part IV

Adjusted Seasonal Installment Method (Caution: Use this method only if the base period percentage for
any 6 consecutive months is at least 70%. See instructions.)

Check this box if the partnership has elected to attach a schedule
that expands lines 15 and 22 through 25 to reflect Regulations
section 1.1446-3(a)(2). See instructions . . . . . . . . .
14
a

Tax year beginning in 2021

14b

c

Tax year beginning in 2022

14c

Enter ECTI allocable to all foreign partners for each period for the
tax year beginning in 2023 (see instructions for the treatment of
extraordinary items).

15

16

(b)

(c)

(d)

First 5
months

First 8
months

First 11
months

First 4
months

First 6
months

First 9
months

Entire year

Enter ECTI allocable to all foreign partners for the following periods:
Tax year beginning in 2020
14a

b

15

(a)
First 3
months

a

Enter ECTI allocable to all foreign partners for the following periods:
Tax year beginning in 2020
16a

b

Tax year beginning in 2021

16b

c

Tax year beginning in 2022

16c

17

Divide the amount in each column on line 14a by the amount in
column (d) on line 16a.

17

18

Divide the amount in each column on line 14b by the amount in
column (d) on line 16b.

18

19

Divide the amount in each column on line 14c by the amount in
column (d) on line 16c.

19

20

Add lines 17 through 19.

20

21

Divide line 20 by 3.0.

21

22a

Divide line 15 by line 21.

22a

b

Extraordinary items. See instructions.

22b

c

Combine lines 22a and 22b.

22c

23

Reduction to line 22c amount for state and local taxes under
Regulations section 1.1446-6(c)(1)(iii) and for certified foreign
partner-level items submitted using Form 8804-C. See instructions.

23

24
25a

Subtract line 23 from line 22c. If zero or less, enter -0-.
Multiply the ECTI on line 24 allocable to non-corporate partners by
37% (0.37).

b

Multiply the ECTI on line 24 allocable to corporate partners by
21% (0.21).

c
26a

Combine lines 25a and 25b.
Divide the amount in columns (a) through (c) on line 16a by the
amount in column (d) on line 16a.

b

Divide the amount in columns (a) through (c) on line 16b by the
amount in column (d) on line 16b.

c

Divide the amount in columns (a) through (c) on line 16c by the
amount in column (d) on line 16c.

24
25a
25b
25c
26a
26b

27
28

Add lines 26a through 26c.
Divide line 27 by 3.0.

26c
27
28

29

Multiply the amount in columns (a) through (c) of line 25c by
columns (a) through (c) of line 28. In column (d), enter the amount
from line 25c, column (d).

29
Schedule A (Form 8804) 2023

Page 3

Schedule A (Form 8804) 2023

Part V

Annualized Income Installment Method
(a)

(b)

First

30

Annualization periods. See instructions.

31

Enter ECTI allocable to all foreign partners for each annualization
period (see instructions for the treatment of extraordinary items):

a
b

Total ECTI allocable to corporate partners.
Total ECTI allocable to non-corporate partners other than on lines
31c, 31d, and 31e.

c
d
e

28% rate gain (non-corporate partners only).
Unrecaptured section 1250 gain (non-corporate partners only).
Adjusted net capital gain (including qualified dividend income and
net section 1231 gain) (non-corporate partners only).

32
33

Annualization amounts. See instructions.
Annualized ECTI allocable to all foreign partners (see instructions
for the treatment of extraordinary items):

30

(c)

First

months

(d)

First

months

First

months

months

31a
31b
31c
31d
31e
32

a

Total ECTI allocable to corporate partners (multiply line 31a by line
32).

33a

b

Reduction to line 33a for state and local taxes under Regulations
section 1.1446-6(c)(1)(iii). See instructions.

33b (

)(

)(

)(

)

c

Reduction to line 33a for certified foreign partner-level items
submitted using Form 8804-C. See instructions.

)(

)(

)

Combine lines 33a, 33b, and 33c.
Total ECTI allocable to non-corporate partners other than on lines
33i, 33m, and 33q (multiply line 31b by line 32).

33c (
33d

)(

d
e
f

Reduction to line 33e for state and local taxes under Regulations
section 1.1446-6(c)(1)(iii). See instructions.

33f (

)(

)(

)(

)

g

Reduction to line 33e for certified foreign partner-level items
submitted using Form 8804-C. See instructions.

)(

)(

)

Combine lines 33e, 33f, and 33g.
28% rate gain allocable to non-corporate partners (multiply line
31c by line 32).

33g (
33h

)(

h
i
j

Reduction to line 33i for state and local taxes under Regulations
section 1.1446-6(c)(1)(iii). See instructions.

33j (

)(

)(

)(

)

k

Reduction to line 33i for certified foreign partner-level items
submitted using Form 8804-C. See instructions.

33k (
l Combine lines 33i, 33j, and 33k.
33l
m Unrecaptured section 1250 gain allocable to non-corporate partners
(multiply line 31d by line 32).
33m

)(

)(

)(

)

33n (

)(

)(

)(

)

)(

)(

)(

)

33e

33i

n

Reduction to line 33m for state and local taxes under Regulations
section 1.1446-6(c)(1)(iii). See instructions.

o

Reduction to line 33m for certified foreign partner-level items
submitted using Form 8804-C. See instructions.

p

Combine lines 33m, 33n, and 33o.

33o (
33p

q

Adjusted net capital gain (including qualified dividend income and
net section 1231 gain) allocable to non-corporate partners
(multiply line 31e by line 32).

33q

r

Reduction to line 33q for state and local taxes under Regulations
section 1.1446-6(c)(1)(iii). See instructions.

33r (

)(

)(

)(

)

s

Reduction to line 33q for certified foreign partner-level items
submitted using Form 8804-C. See instructions.

)(

)(

)

Combine lines 33q, 33r, and 33s.
Figure the tax on line 33 amounts as follows:
Multiply line 33d by 21% (0.21).
Multiply line 33h by 37% (0.37).
Multiply line 33l by 28% (0.28).
Multiply line 33p by 25% (0.25).
Multiply line 33t by 20% (0.20).
Add lines 34a through 34e.

33s (
33t

)(

t
34
a
b
c
d
e
f

34a
34b
34c
34d
34e
34f
Schedule A (Form 8804) 2023

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Schedule A (Form 8804) 2023

Part V
35
36

Annualized Income Installment Method (continued)

Applicable percentage.
Multiply line 34f by line 35.

Part VI

35
36

(a)

(b)

(c)

(d)

25% (0.25)

50% (0.50)

75% (0.75)

100% (1.00)

1st
installment

2nd
installment

3rd
installment

4th
installment

Required Installments

Note: Complete lines 37 through 43 of one column before completing
the next column.
37

If only Part IV or Part V is completed, enter the amount in each
column from line 29 or line 36. If both parts are completed, enter
the smaller of the amounts in each column from line 29 or line 36.

38
39

Add the amounts in all preceding columns of line 43. See instructions.
Adjusted seasonal or annualized income installments. Subtract
line 38 from line 37. If zero or less, enter -0-.

40
41

Enter 25% (0.25) of line 1 in each column.
Subtract line 43 of the preceding column from line 42 of the preceding
column.

42
43

Add lines 40 and 41.
Required installments. Enter the smaller of line 39 or line 42 here
and on line 5. See instructions.

37
38
39
40
41
42
43
Schedule A (Form 8804) 2023

Page 5

Schedule A (Form 8804) 2023

Part VII

Figuring the Penalty
(a)

44 Enter the date of payment or the 15th day of the 3rd month after
the close of the tax year, whichever is earlier. See instructions.
Partnerships that keep their records and books of account
outside the United States and Puerto Rico: Use 6th month
instead of 3rd month.

44

45 Number of days from due date of installment on line 4 to the
date shown on line 44 . . . . . . . . . . . .

45

46 Number of days on line 45 after 4/15/2023 and before 7/1/2023

46

47 Underpayment on line 12 ×

Number of days on line 46
× 7% (0.07)
365

48 Number of days on line 45 after 6/30/2023 and before 10/1/2023
49 Underpayment on line 12 ×

Number of days on line 48
× 7% (0.07)
365

50 Number of days on line 45 after 9/30/2023 and before 1/1/2024
51 Underpayment on line 12 ×

Number of days on line 50
x 8% (0.08)
365

52 Number of days on line 45 after 12/31/2023 and before 4/1/2024
53 Underpayment on line 12 ×

Number of days on line 52
× 8% (0.08)
366

54 Number of days on line 45 after 3/31/2024 and before 7/1/2024
55 Underpayment on line 12 ×

Number of days on line 54
× *%
366

Number of days on line 56
× *%
366

59 Underpayment on line 12 ×

Number of days on line 58
× *%
366

61 Underpayment on line 12 ×

Number of days on line 60
× *%
365

Number of days on line 62
× *%
365

64 Add lines 47, 49, 51, 53, 55, 57, 59, 61, and 63 .

.

.

.

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

63 $

$

$

$

64 $

$

$

$

48
49 $
50
51 $
52
53 $
54

56

58

60
61 $

62 Number of days on line 45 after 3/31/2025 and before 5/16/2025
63 Underpayment on line 12 ×

$

59 $

60 Number of days on line 45 after 12/31/2024 and before 4/1/2025

.

(d)

$

57 $

58 Number of days on line 45 after 9/30/2024 and before 1/1/2025

(c)

$

55 $

56 Number of days on line 45 after 6/30/2024 and before 10/1/2024
57 Underpayment on line 12 ×

47 $

(b)

62

65 Penalty. Add columns (a) through (d) of line 64. Enter the total here and on Form 8804, line 8 .

.

65 $

* Use the penalty interest rate for each calendar quarter, which the IRS will determine during the first month in the preceding quarter. These rates are
published quarterly in an IRS News Release and in a revenue ruling in the Internal Revenue Bulletin (IRB). Go to www.irs.gov/IRB for the IRBs. You can
subscribe to IRS Newswire to receive news releases of the quarterly interest rates, and IRS GuideWire to receive emails with a link to the revenue
rulings in which the quarterly interest rates are published by going to www.irs.gov/UAC/E-News-Subscriptions-2.
Schedule A (Form 8804) 2023