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Where in the code does it require entities to file k2/k3 if they are owned by a partnership even though they have no foreign activity?

Where in the code does it require entities to file k2/k3 if they are owned by a partnership even though they have no foreign activity? I know this is a requirement but I cant find where on the IRS website or code that states this?
who is required to file k2/k3?

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