From: jeffrey E. <jeevacation@gmail.com>
Sent: Tuesday, August 25, 2015 9:55 PM
To: Brad Wechsler
Subject: Re: Boat
Be10?
On Tuesday, August 25, 2015, Brad Wechsler rote:=br>
Je=frey,
Ju=t to be clear:
1. =AO The boat is owned by a foreign corporation.<=u>
2. =AO The boat is currently treated as a partnership for US =ax purposes.
3. =AO We intend to change that status to a foreign corporati=n for US tax purposes.
4. =A0 This will enable us to deduct our capital loss on sale=
5. =AO As per Rich J, we will file the following election and=disclosure forms: 8832 and 926 (reflecting our
conversion for tax purposes=from a partnership to a foreign corporation) and, then, until sale of boat= 926 and 5471
(which is an information return for US persons with respect to certain foreign corporations).
6. =AO If there are issues to discuss, particularly with resp=ct to the 2014 taxes and the 14-day issue, let's do it
quickly wit= Rich Joslin, Rick Bronstein and Glenn Stankee (maritime tax).</=>
=C2 please note
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