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