8804

Penalty for Underpayment of Estimated Section 1446 Tax by Partnerships

Agency
IRS
Revision
2025
Fillable fields
405
Pages
5
Official source
IRS form page
Checked
October 21, 2026
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Page 1 of form 8804

Schedule A (Form 8804): Penalty for Underpayment of Estimated Section 1446 Tax

Schedule A (Form 8804), Penalty for Underpayment of Estimated Section 1446 Tax by Partnerships, is a schedule for Form 8804, Annual Return for Partnership Withholding Tax (Section 1446). The IRS About page says partnerships that have effectively connected taxable income (ECTI) allocable to foreign partners use it to determine whether they are subject to the penalty for underpayment of estimated tax and, if so, the amount of the penalty.

The schedule notes that generally the partnership isn't required to file it, because the IRS will figure any penalty owed and bill the partnership. It is attached when the partnership uses the adjusted seasonal installment method or the annualized income installment method. A partnership may also use it only to figure the penalty, enter the result on Form 8804, line 8, and not attach it.

This page has the 2025 schedule. You can fill out Schedule A (Form 8804) free in your browser on this page and download it without an account.

What's on Schedule A (Form 8804)

Part I: reasons for filing

Two boxes, one for the adjusted seasonal installment method and one for the annualized income installment method.

Parts II and III: safe harbors and underpayment

The current-year and prior-year safe harbor amounts, then four installment columns with due dates, required installments, payments, underpayments and overpayments.

Part IV: adjusted seasonal method

ECTI allocable to foreign partners for the 3 prior tax years and the current year by period, base period percentages, and tax at 37% and 21% rates.

Parts V and VI: annualized method and installments

Annualized ECTI by type of partner and gain, tax at the printed rates, the applicable percentage, and the required installments carried to line 5.

Part VII: figuring the penalty

Days late in each rate period, the underpayment times the rate, and the total penalty on line 65 that goes to Form 8804, line 8.

How to fill out Schedule A (Form 8804)

  1. 1

    Header and Part I

    Enter the partnership's name and EIN. Check one or both Part I boxes that apply. The instructions say to also check the box on Form 8804, line 8.

  2. 2

    Part II

    Enter the 2025 Form 8804, line 5f tax on line 1 and the 2024 amount on line 2 if its conditions are met. Line 3 is the smaller, or line 1 when line 2 is skipped.

  3. 3

    Part III

    Enter the 15th day of the 4th, 6th, 9th and 12th months of the tax year on line 4, then complete lines 7 through 13 of one column before going to the next.

  4. 4

    Parts IV to VI

    Only for partnerships using an alternative method. The instructions say once Parts IV through VI are used for any due date, they are used for all later due dates.

  5. 5

    Part VII

    Go to Part VII only if line 12 shows an underpayment. Count days in each period, apply the rate shown or the quarterly rate marked with an asterisk, and total on line 65.

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Where it goes and what to know

Attach to Form 8804

The schedule says "Attach to Form 8804." The penalty from line 65 is entered on Form 8804, line 8.

Often not filed

The instructions say the partnership generally doesn't have to file the schedule because the IRS will figure the penalty and notify the partnership of any amount due.

Each installment counts

The instructions say the penalty is figured separately for each installment due date, so a penalty can apply to an earlier date even if enough tax was paid later.

Penalty period

The instructions say it runs from the installment due date to the earlier of the payment date or the 15th day of the 3rd month after the 2025 tax year closes (6th month for books kept outside the United States and Puerto Rico).

Quarterly rates

The schedule prints 7% for its first rate periods and an asterisk for later ones. It says the IRS publishes those quarterly rates in a news release and a revenue ruling in the Internal Revenue Bulletin.

Related forms

Who files Schedule A (Form 8804)?

  • Partnerships with foreign partners

    Partnerships that have effectively connected taxable income allocable to foreign partners and file Form 8804 use the schedule to check for an underpayment penalty.

  • Seasonal installment users

    A partnership using the adjusted seasonal installment method checks the Part I box and completes Parts IV and VI. The instructions give a ski shop as an example of seasonal income.

  • Annualized income installment users

    A partnership using the annualized income installment method checks the Part I box and completes Parts V and VI. Using both methods means checking both boxes and completing Parts IV through VI.

  • Partnerships figuring the penalty themselves

    The schedule says a partnership may use it to figure the penalty, enter line 65 on Form 8804, line 8, and not attach it.

  • Small totals

    The schedule says that if the total section 1446 tax on Form 8804, line 5f, is less than $500, the form is not completed or filed and no penalty is owed.

It is a partnership's schedule, not an individual's. The instructions say the partnership attaches it to Form 8804 when Part II, line 1, is $500 or more and it uses the adjusted seasonal or annualized income installment method, even if no penalty is owed.

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Questions about Form 8804

Does every partnership filing Form 8804 attach Schedule A?

No. The schedule says that generally the partnership isn't required to file it, because the IRS will figure any penalty owed and bill the partnership. It is attached when a Part I box is checked.

Is there a minimum amount?

The schedule says that if the total section 1446 tax on Form 8804, line 5f, is less than $500, the form is not completed or filed and the partnership doesn't owe the penalty.

When can the prior-year safe harbor on line 2 be used?

The instructions list conditions, including that the prior tax year was 12 months, a partnership return was timely filed for it, and prior-year ECTI isn't less than 50% of the ECTI on the current-year Form 8804.

Who can use the adjusted seasonal installment method?

The schedule and instructions say it is used only if the base period percentage for any 6 consecutive months of the tax year is 70% or more.

What are the Option 1 and Option 2 annualization periods?

The instructions say Option 1 or Option 2 is used only if the partnership elected it by filing Form 8842 by the due date of the first required installment payment.

What payments go on line 6?

Estimated section 1446 tax paid or credited for each period, including a credited prior-year overpayment and certain section 1446, 1445 and 1446(f)(1) amounts withheld, as the instructions describe.