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Regulations section 1.6655-2(f)(3)(ii)(C))

average of 69%, 74%, and 67% is 70%,

Annualization Periods for Corporate

is treated as an extraordinary item

the base period percentage for May

Estimated Tax, on or before the due date

occurring on the first day of the tax year in

through October 2014 is 70%. Therefore,

of the first required installment payment.

which the item is taken into account in

the amusement park qualifies for the

Once made, the election is irrevocable for

determining ECTI.

adjusted seasonal installment method.

the particular tax year.

For more information regarding

Line 15

extraordinary items, see Regulations

1st

2nd

3rd

4th

If the partnership has certain extraordinary

section 1.6655-2(f)(3)(ii) and the

Install-

items, special rules apply. Do not include

examples in Regulations section

ment

on line 15 the de minimis extraordinary

1.6655-2(f)(3)(vii). Also see Regulations

Standard

items that the partnership chooses to

section 1.6655-3(d)(3).

Option

include on line 22b. See Extraordinary

Option 1

De minimis rule. Extraordinary items

items, earlier.

identified above resulting from a particular

Option 2

Line 22b

transaction that total less than $1 million

(other than a section 481(a) adjustment)

If the partnership has certain extraordinary

Line 31—ECTI Allocable to All

may be annualized using the general rules

items of $1 million or more from a

Foreign Partners

of Regulations section 1.6655-2(f), or, if

transaction, or a section 481(a)

the partnership chooses, may be taken

adjustment, special rules apply. Include

Enter on lines 31a through 31e the ECTI

into account after annualizing the ECTI for

these amounts on line 22b for the

allocable to all foreign partners for the

the annualization period.

appropriate period. Also, include on

months entered for each annualization

line 22b the de minimis extraordinary

period in columns (a) through (d) on

Part II—Adjusted Seasonal

items that the partnership chooses to

line 30. To determine the allocable share

Installment Method

exclude from line 15. See Extraordinary

of ECTI for all foreign partners, see

items, earlier.

Effectively Connected Taxable Income in

Note. Part II does not reflect the lower

the Instructions for Forms 8804, 8805, and

Line 23

preferential rates permitted under

8813.

Regulations section 1.1446-3(a)(2). These

Enter the reduction to the line 22c amount

were omitted because, for most taxpayers,

for state and local taxes under

If the partnership has certain

the income reported in Part II will be

Regulations section 1.1446-6(c)(1)(iii) and

extraordinary items, special rules apply.

predominantly (or exclusively) ordinary

for certified foreign partner-level items

Do not include on line 31a, 31b, 31c, 31d,

income. If the partnership wishes to

submitted under Regulations section

or 31e the de minimis extraordinary items

consider lower preferential rates for Part II

1.1446-6. See Certification of Deductions

that the partnership chooses to include on

(and if the requirements outlined in the

and Losses in the Instructions for Forms

line 33a, 33e, 33i, 33m, or 33q,

Note in the line 31 instructions are met), it

8804, 8805, and 8813 for additional

respectively. See Extraordinary items,

must attach a schedule which

information.

earlier.

appropriately expands lines 15 and 22

Line 25

Note. Enter on lines 31c through 31e the

through 25 to show the applicable special

specified types of ECTI (a) allocable to

types of income or gain and the applicable

The section 1446 applicable percentage is

those partners who would be entitled to

percentages (see, for example, lines 33

35% for all corporate partners, and the

use a preferential rate on such income or

and 34 of this schedule).

section 1446 applicable percentage is,

gain (see Regulations section 1.1446-3(a)

generally, 39.6% for all non-corporate

(2)) and (b) for whom the partnership has

Complete this part only if the

partners. However, if the partnership

sufficient documentation to meet the

partnership's base period percentage for

wishes to consider lower preferential rates

requirements of Regulations section

any 6 consecutive months of the tax year

for non-corporate partners, it must attach

1.1446-3(a)(2)(ii).

equals or exceeds 70%. Figure the base

a schedule which appropriately expands

period percentage using the 6-month

A partner may be entitled to use a

line 25a to show the applicable special

period in which the partnership normally

preferential rate on the following types of

types of income or gain and the applicable

receives the largest part of its ECTI. The

percentages (see, for example, lines 33

income or gain.

base period percentage for any period of 6

and 34 of this Form 8804-W).

1. Line 31c—See section 1(h)(4) and

consecutive months is the average of the

the instructions for line 18, Schedule D

Part III—Annualized

three percentages figured by dividing the

(Form 1040), for more information

ECTI for the corresponding

Income Installment

regarding 28% rate gain.

6-consecutive-month period in each of the

Method

2. Line 31d—See section 1(h)(6) and

3 preceding tax years by the ECTI for

the instructions for line 19, Schedule D

each of their respective tax years.

Line 30—Annualization Periods

(Form 1040), for more information

Example. An amusement park with a

regarding unrecaptured section 1250 gain.

Enter in the space on line 30, columns (a)

calendar year as its tax year receives the

3. Line 31e—Adjusted net capital gain

through (d), respectively, the annualization

largest part of its ECTI during a 6-month

is net capital gain, as defined in section

periods that the partnership is using,

period, May through October. To compute

1222(11), reduced (but not below zero) by

based on the options listed below. For

its base period percentage for this

the sum of (a) unrecaptured section 1250

example, if the partnership elects Option

6-month period, the amusement park

1, enter on line 30 the annualization

gain and (b) 28% rate gain, plus qualified

figures its ECTI for each May–October

dividend income. See section 1(h)(3).

periods 2, 4, 7, and 10, in columns (a)

period in 2011, 2012, and 2013. It then

through (d), respectively.

divides the ECTI for each May–October

If the partnership has net ordinary loss,

period by the total ECTI for that particular

net short-term capital loss, or net 28% rate

Use Option 1 or Option 2 only if

tax year. The resulting percentages are

loss, each net loss should be netted

the partnership elected to use

69% (.69) for May–October 2011, 74%

against the appropriate categories of

one of these options by filing

CAUTION

(.74) for May–October 2012, and 67%

income and gain to determine the

Form 8842, Election To Use Different

(.67) for May–October 2013. Because the

amounts of income and gain to be entered

Instructions for Form 8804-W (2014)

-3-

Instructions For Form 8804-W (Worksheet) - Installment Payments Of Section 1446 Tax For Partnerships - 2014 Page 3

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