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Topic: Tax treatment of non-US partnership  (Read 1636 times)

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Tax treatment of non-US partnership
« on: May 20, 2023, 12:12:39 PM »
Hi, hope everyone is doing well.

As part of my employment, I have been required to co-invest into a non-US partnership as a limited partner. My share is less than 1%, with no voting rights or any form of control. The vehicle seems to be treated as a corporation for US tax purposes.

Over the past few years I have invested approx $20k in total of which $5k has been returned through a mix of return of capital, interest income, dividends and capital gains from the underlying investments.

So my question is, where do these streams of income go on the return?

I will most likely renounce early next year, so I don’t need to plan far ahead for the future. Just keen to get this filed in a way that minimises risk and headaches.


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Re: Tax treatment of non-US partnership
« Reply #1 on: May 20, 2023, 03:07:00 PM »
Forms that come to mind are 926, 8621, 8938 and and FBAR. Assuming the entity has not elected to be disregarded, because it's classified as a corporation it's a PFIC so you'd be filing an 8621 each year and might have a deemed disposition with some possible PFIC tax as at renouncing. You'll want check though that is not made a check the box election.


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