Form 8275-R is used by a taxpayer and a tax return preparer to disclose positions taken on a tax return that are contrary to Treasury regulations. (Form 8275 is filed to disclose positions taken on a tax return for reasons other than Treasury regulations.)
Form 8275-R 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. It can also be used for disclosures relating to the economic substance penalty and the preparer penalties for tax understatements due to positions taken contrary to regulations.
Note that filing Form 8275-R won't relieve the preparer of accuracy-related penalties if the position taken amounts to misconduct. Be sure to read the form instructions before attempting to complete it.
For items attributable to a pass-through entity, disclosure should be made on the tax return of the entity. However, if the entity doesn’t make the disclosure, the partner (or shareholder, etc.) can make adequate disclosure of these items.
Additional Information:
Instructions for Form 8275-R, Regulation Disclosure Statement