26 U.S.C. § 6046A — Returns as to interests in foreign partnerships

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