2 Questions Regarding "Final" K-1 - Spidell

2 Questions Regarding "Final" K-1

Log in to Post

Message Board 2 Questions Regarding "Final" K-1

This topic contains 0 replies, has 1 voice, and was last updated by Herbert Mosberg 3 weeks, 2 days ago.

  • Author
    Posts
  • #182629
    Herbert Mosberg
    Participant

    The taxpayer, a limited partner in a Publicly Traded Partnership (PTP), received a “final” K-1
    because the PTP made an election to be treated as a non-U.S. entity corporation for U.S. tax purposes.

    Question 1:
    The taxpayer is being treated as having made an indirect transfer of cash, securities, and other property totaling > $10,000 (1 partnership unit = 1 share of stock). Is taxpayer required to file FinCEN Form 114 (FBAR)?

    Question 2:
    The PTP says this was an exchange – not a sale. Are the suspended losses from the PTP released?