Header and foreign entity lines
Name and identifying number shown on the return. If the form relates to an information return for a foreign entity, such as Form 5471, the entity's name, EIN and reference ID number.
8275-R
Regulation Disclosure Statement
- Agency
- IRS
- Revision
- Rev. November 2024
- Fillable fields
- 102
- Pages
- 2
- Official source
- IRS form page
- Checked
- October 21, 2026
Form 8275-R: Regulation Disclosure Statement
Form 8275-R is the Regulation Disclosure Statement. The About page says taxpayers and tax return preparers use it to disclose positions taken on a tax return that are contrary to Treasury regulations. The form itself says to use it only for that, and to use Form 8275, Disclosure Statement, for other disclosures.
The instructions say the form is filed to avoid the portions of the accuracy-related penalty due to disregard of regulations or to a substantial understatement of income tax for non-tax shelter items if the return position has a reasonable basis. They also list types of misconduct whose penalty portion cannot be avoided by disclosure, such as negligence.
The form is attached to the tax return. You can fill out Form 8275-R free in your browser on this page and download it without an account.
What's on Form 8275-R
Part I: General Information
Six rows with columns for (a) regulation section, (b) item or group of items, (c) detailed description, (d) form or schedule, (e) line number and (f) amount.
Part II: Detailed Explanation
Six numbered spaces for the explanation that goes with each row in Part I.
Part III: pass-through entity
Completed by partners, shareholders, beneficiaries, or residual interest holders only for a pass-through item: the entity's name and address, identifying number, tax year and the IRS service center where it filed.
Part IV: Explanations continued
Page 2 holds extra space for Parts I and II, with the matching part and line number from page 1.
How to fill out Form 8275-R
- 1
Reference ID number
For a position related to a foreign entity that has an information return such as Form 5471, the instructions say to enter the same reference ID number used on that return.
- 2
Part I, columns (a) to (c)
Give the full citation of each regulation, for example 1.482-7(d)(1)(iii) rather than 482 regs. Name the item, mark any pass-through item as such, and describe it in full.
- 3
Part I, columns (d) to (f)
Show where the item is on the return: the form or schedule, the line number and the amount.
- 4
Part II
The instructions ask for the relevant facts affecting the tax treatment of the item, and a statement explaining why the filer believes the regulation is invalid.
- 5
Part III, line 4
Enter where the pass-through entity filed. The instructions say partners and S corporation shareholders can find it on their Schedule K-1, and to enter e-file if the entity filed electronically.
- 6
Extra space
Use Part IV or continuation sheets if more room is needed, with the filer's name and identifying number on each sheet.
Why fill Form 8275-R on indox
You get the real form, filled in a browser tab, with nothing standing between you and the finished PDF.
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- The official blank straight from the IRS, not a copy someone retyped
- Works on a phone, tablet or computer
How to file it
Attach to the return
The form says to attach it to the tax return. The instructions say to file all Forms 8275-R with the original tax return and keep a copy. They say it may also be possible to file with an amended return.
Separate forms
The instructions call for a separate Form 8275-R for items reported by each pass-through entity, and for each foreign entity.
Carryovers and recurring items
Carryover and carryback items are disclosed in the tax year they originated. Recurring items such as depreciation expense are disclosed for each tax year in which they occur.
Reportable transactions
If the position relates to a reportable transaction, the instructions point to Form 8886 and Regulations section 1.6011-4(d) for the additional disclosure.
Disclosure by another method
The instructions say the disclosure is not valid if Form 8275-R is not completed and attached, even if the same information is given another way, such as an attached letter.
Related forms
Who files Form 8275-R?
The instructions say Form 8275-R is filed by individuals, corporations, pass-through entities, and tax return preparers.
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Questions about Form 8275-R
What is the difference between Form 8275 and Form 8275-R?
The form says Form 8275-R is only for items or positions that are contrary to Treasury regulations. Other disclosures use Form 8275, Disclosure Statement.
Who files Form 8275-R?
The instructions say it is filed by individuals, corporations, pass-through entities, and tax return preparers.
Is Form 8275-R mailed on its own?
No. The form says to attach it to the tax return, and the instructions say to file it with the original return.
Does a Schedule UTP replace Form 8275-R?
The instructions say a filer of Schedule UTP (Form 1120) may not need Form 8275-R to satisfy the disclosure requirements of section 6662(i), and point to the Schedule UTP instructions.
Can disclosure avoid every penalty?
No. The instructions list penalty portions that disclosure cannot avoid, such as negligence and any substantial understatement of income tax on a tax shelter item.
What goes in Part III?
The form says Part III is completed by partners, shareholders, beneficiaries, or residual interest holders only when making disclosure for a pass-through item.