EFTA02490219

From: jeffrey E. <[email protected]> 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 The information contained in this communic=tion is confidential, may be attorney-client privileged, may constit=te inside information, and is intended only for the use of the addresser. It is the property of JEE Unauthorized use, disclosure or copying =f this communication or any part thereof is strictly prohibited and =ay be unlawful. If you have received this communication in error, pleas= notify us immediately by return e-mail or by e-mail to [email protected], andar>destroy this communication and all copies thereof, including all atta=hments. copyright -all rights reserved EFTA_R1_01611101 EFTA02490219 2 EFTA_R1_01611102 EFTA02490220