26 USC § 6046A - Returns as to interests in foreign partnerships

---
identifier: "/us/usc/t26/s6046A"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 6046A - Returns as to interests in foreign partnerships"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "6046A"
section_name: "Returns as to interests in foreign partnerships"
chapter_number: 61
chapter_name: "INFORMATION AND RETURNS"
subchapter_number: "A"
subchapter_name: "Returns and Records"
part_number: "III"
part_name: "INFORMATION RETURNS"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(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.)"
---


# § 6046A. Returns as to interests in foreign partnerships

**(a)** **Requirement of return** Any United States person, except to the extent otherwise provided by regulations—

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.

**(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,

**(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.

---

**Source Credit**: (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.)

## Editorial Notes

### Amendments

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.”

Subsecs. (d), (e). , added subsec. (d) and redesignated former subsec. (d) as (e).

## Statutory Notes and Related Subsidiaries

### Effective Date of 1997 Amendment

> “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

> “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

For provision that this section is not applicable to certain international satellite partnerships, see , set out as a note under .