An indirect partner includes a
partner that owns the partnership through
a pass-through entity (for example, a
partnership, S corporation, or a trust (see
Regulations section 1.904-5(a)(4)(iv) for
the definition of pass-through entity).
A partnership that
does not have or receive sufficient
information or notice regarding a direct or
indirect partner must presume such
partner is eligible to claim a foreign tax
credit and such partner would have to file
a Form 1116 or Form 1118 to claim a
credit. As such, the partnership must
complete the Schedule K-2 and K-3,
accordingly
