3.21.15. Withholding on Foreign Partners

(1) Form 8804, Annual Return for Partnership Withholding Tax (Section 1446), is processed under:

• Tax Class 1

• Master File Tax (MFT) Code 08

• Doc. Code 29

• Document Locator Number (DLN) File Location Code 60 (Ogden)

• Blocking Series 000-999

• Program Code 11340

(2) Form 8804 is processed at the Ogden Submission Processing Campus (OSPC) as a "Non-Remittance" return.

(3) Form 8804 is due on or before the 15th day of the 3rd month after the close of the partnership's taxable year. However, if the partnership keeps its books and records outside of the United States and Puerto Rico (this is indicated by a checkbox in the upper right corner of Form 8804), the Return Due Date (RDD) is the 15th day of the 6th month after the close of the partnership's taxable year.

(4) For taxable years beginning in 2016 and later, the due date for the return of a partnership, including a Form 8804, moved from the 15th day of the 4th month (April 15 for calendar-year filers) to the 15th day of the 3rd month (March 15 for calendar-year filers). In Notice 2017-47, the IRS provided relief from the failure to timely file penalty for taxpayers who, ostensibly unaware of the changed due date, filed their 2016 returns or requested extensions of time to file by the former due date.

(1) Treas. Reg. 1446 provides the authority for processing information returns for withholding tax on foreign partners’ share of effectively connected income.

(2) Policy statements for Submission Processing are contained in IRM 1.2.1.4, Service Wide Policies and Authorities, Policy Statements for Submission Processing Activities.

(1) The Director, SP Office is responsible for monitoring operational performance for the Submission Processing campus.

(2) The Operations Manager is responsible for monitoring operational performance for their operation.

(3) The team manager/lead is responsible for monitoring performance and ensuring employees have the tools to perform their duties.

(4) The team employees are responsible for following the instructions contained in this IRM and maintaining updated IRM procedures.

(1) Program Reports: The Monitoring Section under Submission Processing Program Management/Process Assurance monitors the Code and Edit reports.

(2) Program Effectiveness: The program goals are measured by the following reviews:

• Embedded Quality Submission Processing (EQSP)

• Balanced Measures

• Managerial Reviews

(3) Annual Review: This IRM is updated and published annually, after review by affected offices, according to the clearance process established in IRM 1.11.9, Internal Management Documents, Clearing and Approving Internal Management Documents (IMDs).

(1) A list of terms and acronyms are available in the glossary. See Exhibit 3.21.15-7.

(1) The following table lists related resources to assist tax examiners in their work.Related Resources

(1) The National Taxpayer Advocate has reached agreements with the Commissioners or Chiefs of the Taxpayer Services (TS) Division, Small Business/Self-Employed (SB/SE) Division, Tax Exempt and Government Entities (TEGE) Division, Criminal Investigation (CI), Independent Office of Appeals and Large Business and International (LB&I), that outline the procedures and responsibilities for the processing of Taxpayer Advocate Service (TAS) casework when either the statutory or delegated authority to complete case transactions rests outside of TAS. These agreements are known as Service Level Agreements (SLAs).

(2) The SLAs are found at https://irsgov.sharepoint.com/sites/TAS/SitePages/SLA.aspx.

(1) Edit marks are edited on the return for transcription to the Automated Data Processing (ADP) System through the Integrated Submission and Remittance Processing (ISRP) system. Enter edit marks in brown, red, orange, purple, or green pencil or pen.

(2) Only edit items on the return that are for transcription except where specific instructions require editing of a non-transcribed item. Leave lines blank if the entry would be a zero amount unless otherwise instructed.

(3) Don’t obliterate, alter, or erase the original entry on a return when deleting or correcting an entry. Always exercise care to ensure that the original entry remains legible. Perfected entries provide a legible "edit trail" for anyone who may work with the return later.

(4) Don’t re-edit edit marks entered buy other areas, such as Collections, Entity or Accounts Management, except to place the marks in the correct area or perfect for legibility.

(5) Photocopied Returns - Re-edit or underline any valid, black edit marks. See IRM 3.21.15.13.3, Correspondence Imaging Inventory (CII) Returns, and IRM 3.21.15.16 Re-Entry Document Procedures.

(6) For a description of specific edit marks, see the table below:

(1) Action Codes are used to indicate whether correspondence, research or some other action is needed. The Action Code sets suspense period for the return and places the return in the workable or unworkable suspense inventory.

(1) Correspondence is all written communications from a taxpayer or their representative, excluding tax returns, whether solicited or unsolicited. This includes:

1. Written communications in response to the IRS requests for information or data.

2. Written communications, including annotated notice responses, that provide more information or dispute a notice.

3. A telephone call that results in a written referral or research (Form 4442, Inquiry Referral).

(2) The key to identifying taxpayer correspondence is to ask the following questions:

1. Is taxpayer waiting for a response from the IRS?

2. Is taxpayer waiting for the IRS to take action?

3. Is taxpayer asking a question?

(1) Issue correspondence to resolve any conditions causing the return to be unworkable or unprocessable.

(2) If the return is incomplete and doesn't appear to be a return meant for filing or is a conduit for providing information (e.g., indicates "payment only”), give the return to the lead. The lead must determine the correct course of action. The lead researches for a Transaction Code (TC) 150 and any other information necessary to determine if the return will continue processing, is an amended return, or must be routed to another function. An incomplete return could include any of the following:

• A one-page return, with or without a signature.

• Incomplete returns indicating "Payment Only".

• Incomplete returns showing they have previously e-filed.

(3) Examine the return for all unprocessable conditions before initiating correspondence.

(1) Correspondence Imaging Inventory (CII) is an inventory system for scanning all Account Management (AM) receipts into digital images and working the cases from those images.

(2) "CII" returns are shown with "CII Image-Do not correspond for Signature" stamped below the signature line or "CII" annotated on the front of the return.

(3) Verify all edit marks on a "CII" return.

(4) Follow the instructions below for processing "CII" returns:

(1) For returns completed in other than U.S. currency, process as filed. However, if corresponding for missing/incomplete item(s), include in Letter 3104C to resubmit in U.S. currency.

(1) Taxpayer inquiry requests an adjustment to another return:

1. Remove any attachment requesting an adjustment (ADP or non-ADP).

2. Forward to the BMF International Accounts Management Department for action.

(2) If the attachment doesn't include the taxpayer's name, address or Taxpayer Identification Number (TIN), enter this information on the attachment.

(3) If a tax authorization (Form 2848, Power of Attorney and Declaration of Representative, or Form 8821, Tax Information Authorization) is attached to correspondence, review the correspondence to determine if other requests are involved:

1. If other requests are involved, photocopy the correspondence and send the copy, along with the authorization to the CAF (Centralized Authorization File) function for processing.

2. If other requests aren't involved, send the original correspondence and the authorization to the Campus CAF function for processing.

(4) Other Unrelated Attachments:

1. Remove other unrelated attachments (such as other returns, requests for tax forms, etc.) from the document being processed, and

2. Route to the proper function for necessary action.

(5) Always include the following information when forwarding documents to other functions:

• Name and address of the taxpayer

• Taxpayer Identification Number

• Received Date or the words "TIMELY FILED"

• Tax Period and type of document from which detached

• Action required to be taken

(6) If an attachment is removed because the majority of the information is unrelated to the Form 8804 being processed:

1. Leave an "Action Trail."

2. Route the attachment to the appropriate function.

(1) Review all attachments on the return before considering it processable.

1. Attachments may only be detached when specifically instructed.

2. Edit Action Trail(s) (e.g., 2848 DETACHED) in the lower left corner going vertically up the side of the return.

(2) Follow the general guidelines below for each attachment. The table contains routing instructions for specific forms and/or documents attached to Form 8804:

(1) A return is considered Amended based on the following:

• The word Amended in the top margin of the form.

  Note: Form 8804 instructions indicate to write "Amended" in the top right margin of the form, and "Corrected" on any Forms 8805 attached to the Form 8804

  .

• Words such as "Supplemental", "Corrected", or "Additional" are present.

• Any indication from the taxpayer that a previous return was filed.

Note: Words such as Copy or Duplicate aren't sufficient indicators and must be accompanied by a statement from the taxpayer that a previous return was filed.

• The return appears to be a duplicate and IDRS research shows a Transaction Code (TC) 150.

(2) Examine the return for attachments:

• Don’t separate any related attachments submitted to explain the reason for the Amended Return. Accounts Management may use the information.

• Detach any unrelated documents and route them to the correct function using Form 4227, Intra-SC Reject or Routing Slip, and edit the Action Trail on the return.

(3) If you have an amended Form 8804, edit CCC "G" and DO NOT detach any Form 8805 statements from the Form 8804 return.

(4) Follow the instructions in the chart below when there is an indication of an amended return:

(5) The following data must be edited on all amended returns:

1. Name control: IRM 3.21.15.21.1, Entity Perfection - Name Control -- Line 1a.

2. EIN, see IRM 3.21.15.21.2, Entity Perfection - Employer Identification Number (EIN).

3. Tax period, see IRM 3.21.15.17, Editing the Tax Period.

4. CCC "G."

5. Received Date: IRM 3.21.15.19, Received Date.

6. Signature: IRM 3.21.15.23, Signature.

(1) A return is normally delinquent if it is not received on or before the Return Due Date (RDD). See IRM 3.21.15.1.1(4), Background for taxable years beginning in 2016 and later. However, accept the return as timely filed if the received date is within the ≡ ≡ ≡ ≡ ≡ ≡ ≡. See IRM 3.10.72, Receiving, Extracting, and Sorting or IRM 3.10.73 Batching and Numbering.

(2) Accept a return as timely if the return was mailed in time to reach the IRS through normal handling within the legal period but, through no fault of the taxpayer, it wasn't delivered.

(3) Consider a return timely if it appears that the Post Office might have sent it to another government agency in error, or if the original envelope bears a timely postmark or a timely date stamp by that agency. However, if the return was erroneously addressed to another agency, it will be date stamped with the current date when the IRS received it.

(4) See IRM 3.21.15.1.1, Background, for information on the due date of Form 8804, Annual Return for Partnership Withholding Tax (Section 1446).

(5) If a return is delivered to the IRS after the date prescribed for filing, consider the following:

• The postmark date stamped on the envelope as the date of delivery.

  Note: If the postmark date falls on or before the prescribed date for filing the return, consider the return timely and edit the timely postmark date in MMDDYYYY format.

(6) If the return (Form 8804) is truly delinquent, check the return for an explanation of late filing. If the taxpayer attaches correspondence with a reasonable cause explanation for failure to file a timely return, take the following action:

1. Detach the reasonable cause explanation correspondence from the return.

2. Complete Form 3499, Informational Transmittal, and forward to Accounts Management, BMF International unit. In the remarks area write "Process attached Reasonable Cause Correspondence TC 150 to post in 4 weeks."

3. Prepare Correspondence Action Sheet for IDRS Letter 1382C (use paragraphs "A and S") and assign it to a clerk for input to IDRS or follow local procedures. It may or may not include the Rejects function.

   Note: Don't edit CCC "U, R, or 7" on the return. OAMC will address the taxpayer’s reasonable cause letter.

4. Continue processing Form 8804. Don't attach the Correspondence Action Sheet Letter 1382C to the return.

(1) Compliance functions (Collections and Examination) secure returns from the taxpayer and prepare returns if the taxpayer doesn't provide them.

(2) Compliance notates:

1. Prepared tax returns with "6020(b)" or "SFR" (Substitute for Return).

2. Secured tax returns with "TC 59X" or "ICS" or "Process as Original" with a Form 13133, Expedite Processing Cycle, attached with the "Delinquent Return" box checked.

(1) Criminal Investigation (CI) investigates potential criminal violations of the Internal Revenue Code (IRC) and related financial crimes. Criminal violations of the IRC include willful attempts to evade or defeat the income tax. Criminal tax violations also include the willful failure to collect or pay over tax and false claims for refunds based on bogus return information.

(2) If CI has stamped the return, don't send for further CI action.

(3) For returns with refund claims ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡, do the following:

(4) Because of the repetitive nature of the Code and Edit (C&E) function, C&E Tax Examining technicians often recognize income tax return data which is outside of the norm for data found on similar returns for each income tax return type. If C&E finds return characteristics not meeting Audit Code or Exam referral criteria it deems suspicious, CI is available to review the referral.

(5) If a suspicious return is found, do the following:

1. Make a copy of the first two pages of the tax return along with any page of the return that appears suspicious.

2. Attach Form 4227, Intra-SC Reject or Routing Slip, to the copy.

3. Route the copy as shown in the table below.

Ogden	Kansas City
Mail Stop 9001, Criminal Investigation (CI)	Mail Stop S2 9000, Criminal Investigation (CI)

4. Edit an action trail "Copy to CI", or "CI Referral", or similar language in the lower left corner going vertically up the side of the return.

5. Continue processing the return.

(6) If the return fits other criteria (e.g., Frivolous Argument), take proper action.

(1) The primary goal in identifying tax returns for examination is to promote the highest degree of voluntary compliance. Examination gives support and helps Submission Processing (SP) with any questionable return found during processing. Exam has a vast multitude of programs and tolerance criteria already found in various IRM sections. SP can refer any questionable return to Exam, unless prohibited by instructions currently found in several IRMs.

(1) Form 3893, Re-entry Document Control, is used to reinput a return that hasn't posted to an account or module.

(2) If more than one return is in the batch and only the top Form 3893 has an entry in Box 1 (Alpha/Numeric block control no.), edit all returns using current processing instructions and keep all returns clipped together.

(3) Circle the CCC "G" if present.

(4) Don’t edit CCC "G" on amended returns.

(5) Don’t send Letter 1382C, Penalty Removal Request Incomplete, if a request for reasonable cause is attached.

(6) If the return is not edited according to current processing instructions, circle any Action Codes, Computer Condition Codes and any other edit marks that are no longer applicable. Re-edit according to current processing instructions.

(7) If the return is edited according to current processing instruction, ensure that the information from Form 3893 is edited on the return.

(8) Examine returns that have any color other than red editing in the tax data section to determine if the corrections are the result of improper perfection or taxpayer error.

(9) A received date must be present on all Re-input returns:

(10) When more information is needed to make the return processable, prepare approved Correspondence Action Sheet or Form 4227, Intra-SC Reject or Routing Slip, for the proper action (e.g., correspondence, research).

(11) When perfection is not possible, attach Form 4227 noting, "PERFECTION NOT POSSIBLE" and return to initiator.

(1) Form 13596, Reprocessing Returns, is used to reprocess a return to the correct account or module that had previously posted to the wrong account or module.

(2) Circle CCC "G" if present.

(3) Don’t edit CCC "G" on amended returns.

(4) Do not send Letter 1382C if a request for reasonable cause is attached, because this responsibility belongs to the customer service representative initiating the re-entry document.

(5) If the return is not edited according to current processing instructions circle any Action Codes, Computer Condition Codes and any other edit marks that are no longer applicable. Re-edit according to current processing instructions.

(6) If the return is edited according to current processing instructions, ensure that the information from Form 13596 is edited on the return.

(7) Examine returns that have any color other than red editing in the tax data section to determine if the corrections are the result of improper perfection or taxpayer error.

(8) A received date must be present on all reprocessed returns:

(9) Circle out the green rocker or green check and edit marks that may indicate a receipt of remittance.

(10) When more information is needed to make the return processable prepare an approved Correspondence Action Sheet or Form 4227, Intra-SC Reject or Routing Slip, for the proper action (e.g., correspondence, research).

(1) An early-filed Form 8804 for tax period 202512 (that is, filed before January 1, 2026) must be held for processing in 2026.

(2) An early-filed Form 8804 return is to be held for processing until the beginning of the appropriate processing year.

1. Edit CCC "U" on Form 8804.

2. Prepare Form 4227, by placing an "X" in the Rejects Correction box and stapling Form 4227 to the front of the document. Write, "Early filed return - hold for processing" in the remarks area, and leave the early filed return in the pack of work.

3. Return will be routed to Rejects by ERS after ISRP processing.

(1) Any return with a received date that is two years and nine months or more after the Return Due Date is a potential statute control return.

(2) Route Statute returns to the Statute Control Unit daily or more often if needed.

(3) Do not route to the Statute Control Unit for clearance, edit CCC "W" and continue processing if any of the following conditions are present:

• Compliance IRC 6020(b) returns.

• Secured by Examination/Collections, Secured by TE/GE, Secured by TE/GE Employee Plan (EP) Exam.

• Returns with Transaction Code (TC) 59X or "ICS" (Integrated Collections System) notated on the face of the return.

• Returns showing "substitute returns prepared by Examination (SFR)" in top margin of the return.

• Returns with a stamp indicating a previous clearance by Statute Control within the last 90 days.

• Return is a 2020 and prior year original. Due to the COVID-19 pandemic and subsequent Submission Processing (SP) and Accounts Management (AM) site closures, SP and AM developed procedures to bypass AM statute clearance and be processed. In addition, any 2020 and prior year returns previously cleared by AM statute won't be returned by SP to AM to be cleared again if the 90 calendar day statute stamp has expired.

(4) If a return is received with a Form 12412, Operations Assistance Request (OAR), from TAS and is a potential statute control return but is not stamped "Cleared by Statute", give it to the lead. The lead will contact the TAS employee listed on the OAR for rejection of the return and send it back to TAS for clearance by the Statute Control Unit.

(5) Statute returns are unprocessable until they are cleared by Statute Control.

(6) Edit CCC "W" if the return was cleared by the Statute Control Unit. Statute will stamp or indicate clearance on the front of the return. See IRM 3.21.15.19 Received Date.

(7) Statute stamps "No Statute Issue" or shows clearance on the front of the return. Follow the chart below to determine if a CCC "W" is needed:

(8) The different periods of limitations expiration dates that are tracked are:

• Assessment Statute Expiration Date (ASED): Return filed early - three years from the later of (1) the date the Form 8804 is filed or (2) April 15 if the Form 8804 is filed before April 15 of the calendar year following the calendar year that the tax was incurred. No return filed - assessment may occur at anytime. See IRC 6501(a), IRC 6501(b)(2), IRC 6501(c)(3), and IRC 6235(c)(3).

• Refund Statute Expiration Date (RSED): three years from the time the return was filed or, if later, two years from the date after the tax was paid. See IRC 6511(a) and IRC 6511 (b)(2)(A).

• Collection Statute Expiration Date (CSED) is generally 10 years from the 23-C date or 10 years from the date of the TC 29X or 30X adjustment. See IRC 6502(a) and IRM 3.21.15.19.1(11).

(9) There are several conditions that may change the general Assessment Statute Expiration Date (ASED). They include:

• IRC 6501(c)(1) - False Return

• IRC 6501(c)(4) - Extensions by Agreement

• IRC 6501(b)(3) - Substitute for Return by Authority of IRC 6020(b)

  Caution: IRC 6020(b) is not a tax return that triggers the period of limitations on assessment under IRC 6501(a). If the taxpayer subsequently files a return reporting an additional liability, that return constitutes an original tax return allowing for the assessment of any additional amount not already assessed under the Substitute for Return program and triggering the running of the period of limitations on assessment for the tax year.

• IRC 6501(d) - Is request for Prompt Assessments, which shortens the Assessment Period

• IRC 6501(e) - Substantial Understatement (in excess of 25%) Omission of Income provides for a six -year period of limitations

• IRC 6503(a) - Issuance of Statutory Notice of Deficiency (90-day Letter, which suspends the running of the period of limitations)

• IRC 6503(h) - Bankruptcy

• IRC 6229(a) through (h)- Partnership Items (effective for tax years beginning before January 1, 2018)

• IRC 6232(b) – Partnership imputed underpayments

• IRC 6235 - Period of limitation on making assessments (effective for taxable year beginning after December 31, 2017).

(10) In the case of a partnership subject to the unified partnership audit and litigation procedures of IRC 6221 - IRC 6234, the issuance of a notice of final partnership administrative adjustment suspends the statute under IRC 6229(d). The partnership can also extend its statute through a Form 872, Consent to Extend the Time to Assess Tax, signed by a general partner on behalf of the partnership, or through a Form 872-P, Consent to Extend the Time to Assess Tax Attributable to Partnership Items, signed by the tax matters partner.

(11) Once a partnership issues Form 8805 to its partners, the partnership may not claim a refund for any amount of tax shown on the Form 8805 as paid on behalf of the partners. Treas. Regs. 1.1446-3(d)(2)(iv).

(12) If a partnership that is subject to the unified partnership audit and litigation procedures of IRC 6221 - IRC 6234 is entitled to a refund, it must file a refund request (Request for Administrative Adjustment - (RAA)) within three years of the filing of the partnership return. Under IRC 6227(a), the RAA must be filed using a Form 8082. If a Form 872-P or Form 872 statute extension is secured from the partnership, the RAA can be filed within this extended period according to IRC 6227.

(13) See IRM 25.6, Statute of Limitations, for more statute instructions.

(14) Section 1101 of the Bipartisan Budget Act of 2015 (BBA) repeals the TEFRA partnership audit rules for partnership tax years beginning after December 31, 2017. See revised IRC 6221 through IRC 6241. While the new rules generally go into effect for partnership taxable years beginning after December 31, 2017, partnerships may elect in to these rules for tax years beginning after November 2, 2015, and before January 1, 2018. See Treas. Reg. 301.9100-22.

(1) Remove returns marked as "Protective Claim," "Protective Refund," "Protective Claim for Refund," or similar statement from the batch and route to Accounts Management (AM). Notate "Protective Claim" in the remarks box of Form 4227, Intra-SC Reject or Routing Slip.

(1) The name control consists of the first four characters of the filer's partnership name.

1. Valid characters are alpha, numeric, ampersand (&), hyphen (-) and blank. However, blanks are only valid in the last three positions at the end of the name control.

2. Disregard the word "THE" in the name control only when followed by more than one word.

Example: The partnership name is The Green Parrot, underline the name control Gree. However, if the Partnership name is The Flamingo, underline the name control TheF because the word THE was followed by one word and not more than one word. See Document 7071-A, BMF Name Control Job Aid for more instructions.

(2) See Job Aid Document 7071-A, BMF Name Control Job Aid, to determine the Name Control.

(3) Underline all Name Controls.

(4) Edit the Name Control as follows:

(1) The Employer Identification Number (EIN) is a nine-digit number (XX-XXXXXXX) assigned to identify the foreign partnership.

(2) The EIN is located on Line 1b or 2b.

(3) Determine the EIN as follows:

(1) Both domestic (U.S.) and foreign addresses must include:

• The street number.

• The street name.

• Any appropriate room or suite designation (i.e., "Suite 2000").

• The City or Town, State, and Zip Code (for domestic addresses).

• The foreign city or province, country and foreign postal code (for foreign addresses).

(2) When editing either the mailing or location address information, remember the following guidelines:

1. Ensure that a house or building number is present. Don't accept a building name in place of the numeric designation. Research for the correct address.

2. Always edit the suite, apartment number, room number, etc. at the end of the street address line.

3. If present, edit the street suffix, such as street, drive, lane, terrace, etc.

4. If present, edit the directional information, such as North, South, East, West, etc.

   Note: Use the appropriate abbreviations when necessary. See Document 7475, State and Address Abbreviations, Major City Codes (MCCs), ZIP Codes and Countries.

5. If after research a street address or P.O. Box is not found, edit the word "Local" on the street address line.

   Note: This will only occur in very small towns.

(1) An "in-care-of" name can be identified by the words "in-care-of" or the symbols "c/o" or "%" (percent).

(2) Ensure the "in-care-of" name is in the proper location:

(3) Determine a change in the "in-care-of" name by any of the following:

• Taxpayer edits or added to the "in-care-of" name (e.g., original "in-care-of" name crossed out, new name added).

• Information is attached showing a change to the "in-care-of" name or address.

(1) Perfect the address when the mailing address (Street or P.O. Box) is not easily identified.

(2) A business may have two addresses. One is the mailing address and the other is the location address or physical location of the business.

(3) Perfect the address as follows:

(4) The USPS established new address requirements for Army Post Office (APO)/Diplomatic Post Office (DPO)/Fleet Post Office (FPO) addresses. If the old address appears, convert to the new State Code abbreviation based on the ZIP Code (e.g., APO New York, NY 091XX would be converted to APO AE 091XX). Consider APO/DPO/FPO addresses as domestic addresses. See APO/DPO/FPO conversion chart below:

(1) This is a 35-character field. Valid characters are alpha (a-z) and numeric (0-9).

(2) A foreign (international) address is any address that is not in the 50 states, the District of Columbia or any of the U.S. Territories.

(3) Consider returns with Army Post Office (APO)/Diplomatic Post Office (DPO)/Fleet Post Office (FPO) addresses as domestic addresses. See IRM 3.21.15.21.5, Entity Perfection -- Domestic Addresses- Line 1c.

(4) Route returns with a foreign address to Ogden Submission Processing Campus (OSPC) for processing. Prepare Letter 86C, Referring Taxpayer Inquire/Forms to Another Office, to inform the taxpayer the IRS sent the return to Ogden.

(5) Consider returns with addresses in the following U.S. Territories as foreign for processing purposes. Edit the same way as domestic addresses.

1. Edit a two-character alpha code on Line 1f for the territory name.

U.S. Territory	Abbreviation
American Samoa	AS
Federated States of Micronesia	FM
Guam	GU
Marshall Islands	MH
Northern Mariana Islands	MP
Palau	PW
Puerto Rico	PR
Virgin Islands (U.S.)	VI

2. A ZIP Code must be present for U.S. Territories. Edit the appropriate ZIP Code if one is not provided. See Exhibit 3.21.15-4, U.S. Territories ZIP Codes.

(6) All other foreign addresses are edited the same as a domestic address with the following exceptions:

1. Ensure the foreign country is the last entry in the address.

2. Circle the foreign country and edit the country code preceded by a "/" and followed by "/$"(e.g., "/GM/$" is edited for Germany). See Document 7475, State and Address Abbreviations, Major City Codes (MCCs), ZIP Codes and Countries, for official foreign Country Codes.

3. Edit a unique country code for returns filed with an address in Canada. See IRM 3.21.15.21.6.1, Country Code – Canada.

   Note: Coding and Editing BMF Tax Returns, Foreign Addresses Job Aid (Number 2324-002) provides examples for editing foreign addresses.

4. If the Foreign address is from Australia, Brazil, Canada, Cuba, Italy, Mexico or The Netherlands, check if the address has a province, state or territory.

   Note: There may be other countries with provinces, states, and territories not listed above, see Coding and Editing BMF Tax Returns, Foreign Addresses Job Aid (Number 2324-002) for more information.

If	Then
A foreign province, state or territory is present	Circle the foreign province, state or territory. Edit correct abbreviation. See Exhibit 3.21.15-5, Province, Foreign State, and Territory Abbreviations.
A province, state or territory is not present	Continue editing the return.
Province, state or territory is shown in abbreviated format	Continue editing the return.

(7) A ZIP Code is not required on a foreign address. Foreign addresses use a postal code that is entered before the foreign country and is part of the address.

(1) The city or town must be present for both domestic and foreign addresses.

(2) The valid characters are alpha (a-z) and blank.

(3) Research the ZIP Code directory to determine the city or town and/or state if:

• The address is a U.S. address.

• The city or town and/or state is missing or incomplete.

• The ZIP Code is present.

(4) If the city or town and/or state can't be determined from the Zip Code or other available information (i.e., envelope, if attached), edit the partnership address from Form 8805, Line 5c.

(5) If the city or town listed is a major U.S. city or town, it must be followed by the Zip Code.

(6) If the address is a foreign address which includes a Province designation:

• Circle out the name of the province.

• Edit the province abbreviation. See Exhibit 3.21.15-5.

• A province abbreviation must be present for Australian and Canadian addresses.

(1) A state must be present for all U.S. addresses.

(2) Valid characters are alpha (a-z).

(3) If the state name is spelled out, do not edit the two-digit state code. ISRP will enter the two digit state code.

(4) If the address is a foreign address ISRP will automatically enter a period blank in the state field.

(5) When the state is missing or illegible, research attachments and/or ZIP Code directory. If not found research IDRS.

(1) A ZIP Code must be present for U.S. addresses.

(2) Only numeric characters (0-9) and blank are valid.

(3) The U.S. ZIP Code must contain at least five and may contain up to twelve characters.

(4) If the address is a U.S. address and the ZIP Code is missing or incomplete,

1. Research attachments.

2. Research the ZIP Code Directory.

3. Edit the correct ZIP Code.

(5) If the address is located in a major city and the ZIP Code is missing or incorrect, perfect the ZIP Code from the ZIP Code chart. See Document 7475.

(6) If the address is a foreign address, edit or arrow the Foreign Postal Code to the correct position in the address. See Document 2324-002, Submission Processing BMF Foreign Address Job Aid.

(7) A ZIP Code is not required on a foreign address. Foreign addresses use a postal code that is entered before the foreign country and is part of the address.

(8) A foreign postal code may include both alpha and numeric characters.

(9) Australian addresses must include Numeric Postal Codes. See Figure 3.21.15-5.

(1) An entry must be present on Line 3a. If an entry is "0" or not present, but an entry is present on line 3b, edit the amount from Line 3b to line 3a. However, if unable to determine a count, edit a "1" as the default value on Line 3a. Correspond for Line 3a only if additional return information is being requested from the partnership.

(2) Only numeric (0-9) characters are valid.

(3) If Line 3a is written in text format (e.g., "twenty two,") convert the text to numeric format (e.g., "22").

1. Edit an "X" to the left of entry

2. Edit the numeric value to the left of the X.

(1) This subsection provides procedures for editing the entries on Lines 4a through 15.

(2) If the Form 8804 is a possible zero return, follow the procedures below.

3.21.15.22.2.23 (01-01-2021)

Form 8804 Section 1446 withholding on Tiered Partnership -- Line 6b

(1) Valid characters are numeric 0-9.

(2) Entry must be positive.

(3) If the amount is negative, "X" the entry.

(4) Verify the amount withheld on Line 6b (Form 8804) by making sure the substantiating document(s) (Form 8805, Line 10) are attached.

Note: The EINs on Form 8805 need to match the EIN on Form 8804.

If	Then
Line 6b has supporting documentation	Take no further action.
Line 6b has only partial supporting documentation	"X" out the incorrect amount on Line 6b. Edit the substantiated amount to the left of the "X" and recompute Line 7 (on the dotted lines). See Figure 3.21.15-6a. Note: Allow withholding credit amount ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
Line 6b has NO supporting documentation	Prepare Correspondence Action Sheet Letter 3104C for Form(s) 8805, then edit an "X" to the left of the unsubstantiated amount on Line 6b. See Figure 3.21.15-6b. Note: Allow withholding credit amount ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

3.21.15.22.2.24 (01-01-2020)

Form 1042-S Section 1446 withholding on Publicly Traded Partnership (PTP) -- Line 6c

(1) Valid characters are numeric 0-9.

(2) Entry must be positive.

(3) If the amount is negative, "X" the entry.

(4) Verify the amount withheld on Line 6c (Form 8804), by making sure the substantiating document(s) (Form 1042-S, Box 7a for the amount withheld and Box 1 with Income Code 27), are attached.

Exception: If a copy of Form 1042-S is not attached, look for a copy of a Competent Authority letter signed by a United States Competent Authority. This letter can be used as supporting documentation to support the amount of withholding taxes claimed on the return in lieu of Form 1042-S.

If	Then
Line 6c has supporting documentation	Take no further action. See Figure 3.21.15-7.
Line 6c has only partial supporting documentation	"X" out the incorrect amount on Line 6c. Edit the substantiated amount to the left of the "X" and recompute Line 7 (on the dotted lines). Note: Allow withholding credit amount ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡
Line 6c has NO supporting documentation	Prepare Correspondence Action Sheet Letter 3104C or Letter 1791C for Form(s) 1042-S, edit an "X" to the left of the unsubstantiated amount on Line 6c. See Note: Allow withholding credit amount ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

3.21.15.22.2.25 (01-01-2021)

Form 8288-A Section 1445(a) or (e)(1) withholding on USRPI Disposition -- Line 6d

(1) Valid characters are numeric 0-9.

(2) Entry must be positive.

(3) If the amount is negative, "X" the entry.

(4) Verify the amount withheld on Line 6d (Form 8804), by making sure the substantiating document(s) (Form 8288-A, Line 4) are attached. If missing, prepare Correspondence Action Sheet 3104C to request the document(s).

Note: Form 8288-A must always be credit verified by the FIRPTA Code and Edit unit with the Form 13698, International Credit Verification Slip, attached to Form 8804. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

If	And	Then
Form 8288-A is attached to Form 8804,	A completed Form 13698 is not attached to Form 8804.	Pull Form 8804 from batch and attach a blank Form 13698. Follow local procedures for Credit Verification. Note: FOR KCSPC ONLY: Forward Form 8804 to the OSPC FIRPTA Code and Edit unit.
Form 8288-A is attached to Form 8804,	A completed Form 13698 is attached to Form 8804 fully verifying the FIRPTA credit.	Take no further action.
Form 8288-A is attached to Form 8804,	A completed Form 13698 is attached to Form 8804, but the amount verified is less than the amount shown on Form 8288-A, Box 4. (For prior years see Box 2)	Edit an "X" to the left of Line 6d. Edit the correct substantiated amount to the left of the "X" and recompute Line 7 (on the dotted lines). See Figure 3.21.15-8a.
Form 8288-A is NOT attached to Form 8804,	Line 6d has an entry greater than "0".	Prepare Correspondence Action Sheet 3104C and ask the taxpayer for copies of Form 8288-A using the following sentence: "We need more information to process your Form 8804 return. Line 6d of Form 8804 shows a credit of $_______. However, there is no documentation to support the entry on Line 6d. Please provide us with a copy of Form(s) 8288-A to substantiate the entry on Line 6d." Note: Edit an "X" to the left of the unsubstantiated amount on Line 6d and re-compute line 7. See Figure 3.21.15-8b.

3.21.15.22.2.27 (01-01-2023)

Form 8288-A Section 1446(f)(1) Withholding on the Transfer of Non-Publicly Traded Partnership by a Foreign Person -- Line 6f

(1) Valid characters are numeric 0-9.

(2) Entry must be positive.

(3) If the amount is negative, "X" the entry.

(4) Verify the amount withheld on Line 6f by making sure the substantiating document(s) is attached (Counting total Line 4 Forms 8288-A with Line 5b checked).

(5) Form 8288-A, Box 4 Federal Income Tax Withheld). If missing, prepare Correspondence Action Sheet 3104C to request missing information.

Note: Form 8288-A must always be credit verified by the FIRPTA Code and Edit unit with the Form 13698 -- International Credit Verification Slip attached to Form 8804. ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡ ≡

If	And	Then
Form 8288-A is attached to Form 8804,	A completed Form 13698 is not attached to Form 8804.	Forward Form 8804 to the FIRPTA Code and Edit unit to verify the credit. Note: Attach a blank Form 13698 if none was attached.
Form 8288-A is attached to Form 8804,	A completed Form 13698 is attached to Form 8804 fully verifying the FIRPTA credit.	Take no further action.
Form 8288-A is attached to Form 8804,	A completed Form 13698 is attached to Form 8804, but the amount verified is less than the amount shown on Form 8288-A, Box 4.	Edit an "X" to the left of Line 6f. Edit the correct substantiated amount to the left of the "X" and recompute Line 7 (on the dotted lines). See Figure 3.21.15-9a.
Form 8288-A is NOT attached to Form 8804,	Line 6f has an entry greater than "0".	Prepare Correspondence Action Sheet 3104C and ask the taxpayer for copies of Form 8288-A using the following sentence: "We need more information to process your Form 8804 return. Line 6f of Form 8804 shows a credit of $_______. However, there is no documentation to support the entry on Line 6f. Please provide us with a copy of Form(s) 8288-A to substantiate the entry on Line 6f." Note: Edit an "X" to the left of the unsubstantiated amount on Line 6f and re-compute line 7. See Figure 3.21.15-9a.

(1) A signature may or may not be present; don't correspond if not present.

(2) Don’t correspond for a missing signature on any return prepared by a Compliance function.

(3) Don’t question any signature on the return. Treas. Reg. 301.6064-1 allows the IRS to presume that the signature on the return, statement or other document is the true signature of the person who actually signed the document.

(4) A constructive signature (that is, a signature on an accompanying check, letter, etc.) is not acceptable unless the signature follows a perjury statement containing the same language as the jurat of the tax return.

(1) The Preparer's PTIN is located to the right of the Preparer's Signature in the PTIN box at the bottom right corner of Form 8804, page 2.

(2) No action is required on amended returns.

(3) A valid PTIN begins with the alpha "P" followed by an eight-digit number (e.g., PXXXXXXXX).

(4) Circle the entry if:

• it does not begin with a "P",

• it is an SSN,

• it has all zeros, nines, or any repeating 9 digits, or

• it has invalid characters.

(1) If the Preparer's TIN is a PTIN, edit a "0" immediately to the right of the PTIN.

(1) The Firm's EIN is located below the Preparer's PTIN box at the bottom right corner of Form 8804, page 2.

(2) No action is required on amended returns.

(3) The Firm's EIN is a nine-digit number. Circle the EIN if all zeros or all nines.

(1) The Preparer's Phone Number is located below the Preparer's Firm’s EIN at the bottom right corner of Form 8804, page 2.