From: Richard Joslin C
To: jeffrey E. <jeevacation@gmail.com>, "Dlugash, Alan"
CC: Brad Wechsler a, John Castrucci ca
Subject: updated draft
Date: Thu, 08 Oct 2015 18:25:19 +0000
Attachments: FEDERAL_-_DRAFT -_10-7-15_-_626PM_to_JEE.pdf
Minor revisions. The largest change was to treat a PFIC mark to market ordinary income to NOT be an excess distribution.
Tom had confused the tax rules. This item originates from a foreign partnership and is not reported on the foreign
partnership Schedule K-1. The foreign partnership prepares a pro forma K-1 and does not actually file it with the IRS.
Same password as before
EFTA00650696