EFTA02380822

From: Yvonne Berger on behalf of Brad Wechsler Sent: Tues ay, August 25, 2015 9:51 PM To: [email protected] Cc: ichard Joslin; Subject: Boat Je=frey, Ju=t to be clear: 1. The boat is owned by a foreign corporation. 3. We intend to change that status to a foreign corpor=tion for US tax purposes. ohn Castrucci 5. As per Rich J, we will file the following election =nd disclosure forms: 8832 and 926 (reflecting our conversion for tax purpo=es from a partnership to a foreign corporation) and, then, until sale of b=at, 926 and 5471 (which is an information return for US persons with respect to certain foreign corporations).<=o:p> 6. If there are issues to discuss, particularly with r=spect to the 2014 taxes and the 14-day issue, lees do it quickly wi=h Rich Joslin, Rick Bronstein and Glenn Stankee (maritime tax).=/p> 1 EFTA_R1_01395314 EFTA02380822