---
kind: "section"
citation: "26 U.S.C. § 6046A"
title: "26"
title_heading: "Internal Revenue Code"
number: "6046A"
heading: "Returns as to interests in foreign partnerships"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/6046A"
units:
  - "Subtitle F — Procedure and Administration"
  - "Chapter 61 — Information and Returns"
  - "Subchapter A — Returns and Records"
  - "Part III — Information Returns"
  - "Subpart B — Information Concerning Transactions With Other Persons"
---

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

- (a) **Requirement of return—** Any [United States person](/usc/26/7701.md?p=a-30), except to the extent otherwise provided by regulations—
  - (1) who acquires any interest in a [foreign](/usc/26/7701.md?p=a-5) [partnership](/usc/26/7701.md?p=a-2),
  - (2) who disposes of any portion of his interest in a [foreign](/usc/26/7701.md?p=a-5) [partnership](/usc/26/7701.md?p=a-2), or
  - (3) whose proportional interest in a [foreign](/usc/26/7701.md?p=a-5) [partnership](/usc/26/7701.md?p=a-2) changes substantially,

  shall file a return. Paragraphs [(1)](#a-1) and [(2)](#a-2) shall apply to any acquisition or disposition only if the [United States person](/usc/26/7701.md?p=a-30) directly or [indirectly](/usc/26/101.md?p=a-3-B) holds at least a 10-percent interest in such [partnership](/usc/26/7701.md?p=a-2) either before or after such acquisition or disposition, and [paragraph (3)](#a-3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such [partnership](/usc/26/7701.md?p=a-2).

- (b) **Form and contents of return—** Any return required by [subsection (a)](#a) shall be in such form and set forth such information as the [Secretary](/usc/26/7701.md?p=a-11-B) shall by regulations prescribe.
- (c) **Time for filing return—** Any return required by [subsection (a)](#a) shall be filed on or before the 90th day (or on or before such later day as the [Secretary](/usc/26/7701.md?p=a-11-B) may by regulations prescribe) after the day on which the [United States person](/usc/26/7701.md?p=a-30) becomes liable to file such return.
- (d) **10-percent interest—** For purposes of [subsection (a)](#a), a 10-percent interest in a [partnership](/usc/26/7701.md?p=a-2) is an interest described in [section 6038(e)(3)(C)](/usc/26/6038.md?p=e-3-C).
- (e) **Cross reference—** For provisions relating to penalties for violations of this section, see sections [6679](/usc/26/6679.md) 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.)

## Notes

### 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).

### Statutory Notes and Related Subsidiaries

### 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.