Be sure to supply all of the information requested in Parts I and II and, if applicable, Part III. Your disclosure will be
considered adequate if you file Form 8275-R and supply the information requested in detail.
Use Part IV on page 2 if you need more space for Part I or II. Indicate the corresponding part and line number from page 1.
You can use a continuation sheet(s) if you need additional space. Be sure to put your name and identifying number on each
Reference ID number.
If you are filing Form 8275-R to disclose a position related to a foreign entity for which an information return (such
as Form 5471) is filed, enter on Form 8275-R the same reference ID number for the foreign entity that is entered on the information
If you are filing Form 8275-R to report a position or positions related to multiple foreign entities, file a separate
Form 8275-R for each foreign entity.
Enter a detailed citation for each regulation for which you have taken a contrary position.
Identify the item by name.
If any item you disclose is from a pass-through entity, you must identify the item as such. If you disclose items
from more than one pass-through entity, you must complete a separate Form 8275-R for each entity. Also, see How To File
on page 1.
Enter a complete description of the item(s) you are disclosing.
If an entertainment expense was reported in column (b), then list in column (c) “theater tickets, catering expenses, and banquet hall rentals.”
If you claim the same tax treatment for a group of similar items in the same tax year, enter a description identifying
the group of items you are disclosing rather than a separate description of each item within the group.
Columns (d) through (f).
Enter the location of the item(s) by identifying the form number or schedule and the line number in columns (d) and
(e) and the amount of the item(s) in column (f).
Your disclosure must include:
A description of the relevant facts affecting the tax treatment of the item. To satisfy this requirement, you must include
information that reasonably can be expected to apprise the IRS of the identity of the item, its amount, and the nature of
the controversy or potential controversy. Information concerning the nature of the controversy can include a description of
the legal issues presented by the facts, and
A statement explaining why you believe this regulation to be invalid.
Unless provided otherwise in the General Instructions above, your disclosure will not be considered adequate unless (1) and
(2) above are provided using Form 8275-R. For example, your disclosure will not be considered adequate if you attach a copy
of an acquisition agreement to your tax return to disclose the issues involved in determining the basis of certain acquired
assets. If Form 8275-R is not completed and attached to the return, the disclosure will not be considered valid even if the
information in (1) and (2) above is provided using another method, such as a different form or an attached letter.
Contact your pass-through entity if you do not know where its return was filed. However, for partners and S corporation
shareholders, information for line 4 can be found on the Schedule K-1 that you received from the partnership or S corporation.
If the pass-through entity filed its return electronically using e-file
, enter “e-file
” on line 4.