651113 Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 2014 Part III Partner’s Share of Current Year Income, (Form 1065) Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning , 2014 ending , 20 2 Net rental real estate income (loss) Partner’s Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. a See back of form and separate instructions.
Part I Information About the Partnership 4 Guaranteed payments A Partnership’s employer identification number 5 Interest income
B Partnership’s name, address, city, state, and ZIP code 6a Ordinary dividends
6b Qualified dividends
C IRS Center where partnership filed return 7 Royalties
D Check if this is a publicly traded partnership (PTP) 8 Net short-term capital gain (loss)
Part II Information About the Partner 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items E Partner’s identifying number 9b Collectibles (28%) gain (loss)
F Partner’s name, address, city, state, and ZIP code 9c Unrecaptured section 1250 gain
10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses
G General partner or LLC Limited partner or other LLC 11 Other income (loss) member-manager member
H Domestic partner Foreign partner
I1 What type of entity is this partner? I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc.), check here 19 Distributions ...... 12 Section 179 deduction
J Partner’s share of profit, loss, and capital (see instructions): Beginning Ending 13 Other deductions
Profit % % 20 Other information Loss % % Capital % %
K Partner’s share of liabilities at year end: Nonrecourse ...... $ 14 Self-employment earnings (loss) Qualified nonrecourse financing . $ Recourse ...... $
L Partner’s capital account analysis: *See attached statement for additional information. Beginning capital account ... $ Capital contributed during the year $ Current year increase (decrease) . $ Withdrawals & distributions . . $ ( ) Ending capital account .... $
Tax basis GAAP Section 704(b) book Other (explain) For IRS Use Only M Did the partner contribute property with a built-in gain or loss? Yes No If “Yes,” attach statement (see instructions)
For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.gov/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities See the Partner’s Instructions Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes } 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a Gross income sourced at } C 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category } Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category } Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) See the Partner’s A Post-1986 depreciation adjustment E Capital gain property to a 50% Instructions B Adjusted gain or loss See the Partner’s organization (30%) } C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income } the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 } See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer’s Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit L Dispositions of property with (section 42(j)(5)) from pre-2008 section 179 deductions buildings M Recapture of section 179 deduction B Low-income housing credit N Interest expense for corporate (other) from pre-2008 buildings partners C Low-income housing credit O Section 453(l)(3) information (section 42(j)(5)) from P Section 453A(c) information post-2007 buildings See the Partner’s Instructions Q Section 1260(b) information D Low-income housing credit R Interest allocable to production See the Partner’s (other) from post-2007 expenditures Instructions buildings S CCF nonqualified withdrawals } T Depletion information—oil and gas E Qualified rehabilitation expenditures (rental real estate) U Reserved F Other rental real estate credits V Unrelated business taxable income } G Other rental credits W Precontribution gain (loss) H Undistributed capital gains credit Form 1040, line 73; check box a X Section 108(i) information I Biofuel producer credit Y Net investment income J Work opportunity credit Z Other information } See the Partner's Instructions K Disabled access credit Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #1
Part II, Item J - Partner's share of profit, loss, and capital:
Beginning and ending capital percentages are based on partners' beginning and ending capital accounts as reflected in Part II, Item L as a percentage of total partnership capital.
Beginning profit and loss percentages reflect beginning of year book capital percentages.
Ending profit percentages are based on partners' allocation of distributive share of income and gains on a tax basis as a percentage of total partnership amounts. Ending loss percentages are based on partners' allocation of distributive share of deductions and losses on a tax basis as a percentage of total partnership amounts. These percentages may differ significantly from your ending capital percentage due to the timing of contributions and withdrawals during the year, the timing of when income and losses occurred during the year, and tax allocations of gains and losses pursuant to IRC §704(c).
Part II, Item L - Current year increase (decrease) reconciliation:
Partner's Distributive Share of Taxable Income 36,640 Less: Line 15 - Credits (2,650) Plus: Line 18A - Tax-Exempt Interest Income 11,000 Plus: Line 18B - Other Tax-Exempt Income 1,800 Less: Line 18C - Nondeductible Expenses (1,100) Unrealized Appreciation (Depreciation) and Other Timing Differences 104,310 Subtotal: Book Income 150,000 Net Partnership Transfers -
Total Current Year Increase (Decrease) 150,000
Line 1 - Ordinary business income (loss) detail:
Interest Income From Trading Activities 1,000 Qualified Dividends From Trading Activities 2,000 Other Dividends From Trading Activities 500 Net Section 475(f) Ordinary Income (Loss) From Trading Activities 200 Net Section 987 Gain (Loss) From Trading Activities 300 Net Section 988 Gain (Loss) From Trading Activities (600) Other Income (Loss) From Trading Activities 1,000 Other Expenses From Trading Activities (3,000) Net Income (Loss) From Passive Activities 20,000
Total Ordinary Business Income (Loss) 21,400
Line 8 - Net short-term capital gain (loss) detail:
Net Short-Term Capital Gain (Loss) From Investing Activities 2,500 Net Short-Term Capital Gain (Loss) From Trading Activities 8,000
Total Net Short-Term Capital Gain (Loss) 10,500
Net Short-Term Capital Gain (Loss) Attributed to Disposition of Passive Activities 500
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #2
Line 9a - Net long-term capital gain (loss) detail:
Net Long-Term Capital Gain (Loss) From Investing Activities 6,000 Net Long-Term Capital Gain (Loss) From Trading Activities (2,200)
Total Net Long-Term Capital Gain (Loss) 3,800
Net Long-Term Capital Gain (Loss) Attributed to Disposition of Passive Activities (200)
Line 11(A) - Other portfolio income (loss) detail:
Net Section 988 Gain (Loss) From Investing Activities 900 Other Portfolio Income (Loss) 100
Total Other Portfolio Income (Loss) 1,000
Line 11(C) - Section 1256 contracts and straddles detail:
Net Section 1256 Gain (Loss) From Investing Activities 200 Net Section 1256 Gain (Loss) From Trading Activities 1,300
Total Section 1256 Gain (Loss) 1,500
Line 11(E) - Cancellation of debt detail:
Cancellation of Debt 200
Total Cancellation of Debt 200
Line 11(F) - Other income (loss) detail:
Other Income (Loss) 100
Total Other Income (Loss) 100
Line 13(A) - Cash contributions (50%) detail:
Cash Contributions Subject To 50% Limitation 100
Total Cash Contributions (50%) 100
Line 13(B) - Cash contributions (30%) detail:
Cash Contributions Subject To 30% Limitation 6
Total Cash Contributions (30%) 6
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #3
Line 13(C) - Noncash contributions (50%) detail:
Noncash Contributions Subject To 50% Limitation 4
Total Noncash Contributions (50%) 4
Line 13(H) - Investment interest expense detail:
Investment Interest Expense From Investing Activities 2,000 Investment Interest Expense From Trading Activities 6,000
Total Investment Interest Expense 8,000
Line 13(I) - Deductions - royalty income detail:
Deductions - Royalty Income 200
Total Deductions - Royalty Income 200
Line 13(J) - Section 59(e)(2) expenditures detail:
Section 59(e)(2) Expenditures 300
Total Section 59(e)(2) Expenditures 300
Line 13(K) - Deductions - portfolio (2% floor) detail:
Deductions - Portfolio (2% Floor) 5,000
Total Deductions - Portfolio (2% Floor) 5,000
Line 13(L) - Deductions - portfolio (other) detail:
Deductions - Portfolio (Other) 100
Total Deductions - Portfolio (Other) 100
Line 13(S) - Reforestation expense deduction detail:
Reforestation Expense Deduction 50
Total Reforestation Expense Deduction 50
Line 13(T) - Domestic production activities information:
The following information is required to be provided to you under IRC Section 199. The information may be necessary for the calculation of the domestic production activities deduction. Gross income from all sources has been reported on Line 16B. The tax rules relating to Section 199 are complex. Please consult your tax advisor. Oil-Related All Activities Gross receipts information Domestic Production Gross Receipts (DPGR) 2,000 8,000 Non-Domestic Production Gross Receipts 500 2,000
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #4
Line 13(T) - Domestic production activities information (continued): Oil-Related All Activities Cost of goods sold information Cost of Goods Sold Allocable to DPGR 1,000 4,000 Cost of Goods Sold Allocable to Non-DPGR 200 800 Deduction, expense, and loss information Total Deductions, Expenses and Losses Directly Allocable to DPGR 250 1,000 Total Deductions Directly Allocable To A Non-DPGR Class of Income 300 1,200 Other Deductions Not Directly Allocable to DPGR 350 1,400 Other Deductions Not Directly Allocable to A Non-DPGR Class of Income 400 1,600 Other Supporting Information Assets Allocable to QPA 100 400 Interest Expense 50 200 W-2 Wage Receipts 125 500
Additional information, if needed, is available upon request.
Line 13(U) - Qualified production activities income detail:
Qualified Production Activities Income 500
Total Qualified Production Activities Income 500
Line 13(V) - Employer's Form W-2 wages detail:
Employer's Form W-2 Wages 500
Total Employer's Form W-2 Wages 500
Line 13(W) - Other deductions detail:
Other Deductions 100
Total Other Deductions 100
Line 15(J) - Work opportunity credit detail:
Work Opportunity Credit 50
Total Work Opportunity Credit 50
Line 15(M) - Credit for increasing research activities detail:
Credit for Increasing Research Activities 100
Total Credit for Increasing Research Activities 100
Line 15(N) - Credit for employer social security and Medicare taxes detail:
Credit for Employer Social Security and Medicare Taxes 150
Total Credit for Employer Social Security and Medicare Taxes 150
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #5
Line 15(O) - Backup withholding detail:
Backup Withholding 200
Total Backup Withholding 200
Line 15(P) - Other credits detail:
U.S. Taxes Withheld 100 Alabama Taxes Withheld 50 Arizona Taxes Withheld 50 Arkansas Taxes Withheld 50 California Taxes Withheld 50 Colorado Taxes Withheld 50 Connecticut Taxes Withheld 50 Delaware Taxes Withheld 50 Georgia Taxes Withheld 50 Hawaii Taxes Withheld 50 Idaho Taxes Withheld 50 Illinois Taxes Withheld 50 Indiana Taxes Withheld 50 Iowa Taxes Withheld 50 Kansas Taxes Withheld 50 Kentucky Taxes Withheld 50 Louisiana Taxes Withheld 50 Maine Taxes Withheld 50 Maryland Taxes Withheld 50 Massachusetts Taxes Withheld 50 Michigan Taxes Withheld 50 Minnesota Taxes Withheld 50 Mississippi Taxes Withheld 50 Missouri Taxes Withheld 50 Montana Taxes Withheld 50 Nebraska Taxes Withheld 50 New Jersey Taxes Withheld 50 New Mexico Taxes Withheld 50 New York Taxes Withheld 50 North Carolina Taxes Withheld 50 North Dakota Taxes Withheld 50 Ohio Taxes Withheld 50 Oklahoma Taxes Withheld 50 Oregon Taxes Withheld 50 Pennsylvania Taxes Withheld 50 Rhode Island Taxes Withheld 50 South Carolina Taxes Withheld 50 Utah Taxes Withheld 50 Vermont Taxes Withheld 50 Virginia Taxes Withheld 50 West Virginia Taxes Withheld 50 Wisconsin Taxes Withheld 50
Total Other Credits 2,150
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #6
Line 16 - Foreign transactions:
A. Name of country or U.S. possession Various B. Gross income from all sources 70,500 C. Gross income sourced at partner level 20,200 Foreign gross income sourced at partnership level D. Passive category 5,000 E. General category 1,000 F. Other 1,500 Deductions allocated and apportioned at partner level G. Interest expense 8,000 H. Other 11,510 Deductions allocated and apportioned at partnership level to foreign source income I. Passive category 200 J. General category 100 K. Other 50 Other information L. Total foreign taxes paid 1,000 M. Total foreign taxes accrued 200
Line 16(L) - Total foreign taxes paid detail:
Type of Income
Passive Category 500 General Category 300 Other 200
Total Foreign Taxes Paid 1,000
Line 16(M) - Total foreign taxes accrued detail:
Type of Income
Passive Category 100 General Category 50 Other 50
Total Foreign Taxes Accrued 200
Line 17 - Alternative minimum tax (AMT) items:
A. Post-1986 Depreciation Adjustment 600 B. Adjusted Gain or Loss 500 C. Depletion (other than oil & gas) 400 D. Oil, Gas, & Geothermal - Gross Income 300 E. Oil, Gas, & Geothermal - Deductions 200 F. Other AMT Items - Excess Intangible Drilling Costs 100
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #7
Line 18(A) - Tax-exempt interest income detail:
States To Which Municipal Interest Income Relates
Alabama 200 Alaska 200 Arizona 200 Arkansas 200 California 200 Colorado 200 Connecticut 200 Delaware 200 District of Columbia 200 Florida 200 Georgia 200 Hawaii 200 Idaho 200 Illinois 200 Indiana 200 Iowa 200 Kansas 200 Kentucky 200 Louisiana 200 Maine 200 Maryland 200 Massachusetts 200 Michigan 200 Minnesota 200 Mississippi 200 Missouri 200 Montana 200 Nebraska 200 Nevada 200 New Hampshire 200 New Jersey 200 New Mexico 200 New York 200 North Carolina 200 North Dakota 200 Ohio 200 Oklahoma 200 Oregon 200 Pennsylvania 200 Rhode Island 200 South Carolina 200 South Dakota 200 Tennessee 200 Texas 200 Utah 200 Vermont 200 Virginia 200
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #8
Line 18(A) - Tax-exempt interest income detail (continued):
States To Which Municipal Interest Income Relates
Washington 200 West Virginia 200 Wisconsin 200 Wyoming 200 Guam 200 Puerto Rico 200 U.S. Virgin Islands 200 Other 200
Total Tax-Exempt Interest Income 11,000
Line 18(B) - Other tax-exempt income detail:
Other Tax-Exempt Income 1,800
Total Other Tax-Exempt Income 1,800
Line 18(C) - Nondeductible expenses detail:
Expenses Attributable to Tax-Exempt Income 1,000 Nondeductible Meals and Entertainment 50 Other Nondeductible Expenses 50
Total Nondeductible Expenses 1,100
Line 20(C) - Fuel tax credit information detail:
Credit For Federal Tax Paid On Fuels 100
Total Fuel Tax Credit Information 100
Line 20(J) - Look-back interest - completed long-term contracts detail:
Look-Back Interest - Completed Long-Term Contracts
Form 8697 - 2012 20 Form 8697 - 2013 50 Form 8697 - 2014 100
Total Look-Back Interest - Completed Long-Term Contracts 170
Line 20(N) - Interest expense for corporate partners detail:
For corporate partners, your distributive share of the partnership's interest expense has been reported on Line 13(H) of your Schedule K-1. A corporate partner's distributive share of interest income, interest expense and partnership liabilities are treated as income, expense and liabilities of the corporation for purposes of the limitation on the deduction for interest under IRC §163(j). The interest expense limitation rules for corporations are complex. Please consult your tax advisor.
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #9
Line 20(T) - Information needed to figure depletion - oil and gas detail:
Cost Depletion Not Deducted From Line 1 100 Gross Income Subject To Percentage Depletion 10,000 Rate of Depletion - 10% Tentative Percentage Depletion Deduction 1,000
Line 20(V) - Unrelated business taxable income detail:
Ordinary Income (Loss) Considered Unrelated Business Taxable Income 20,000 Short-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income 5,000 Long-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income 10,000
Total Unrelated Business Taxable Income 35,000
Qualified Dividends in Ordinary Income (Loss) Considered Unrelated Business Taxable Income 1,000 Foreign Source Income On Line 16D That Is Considered Unrelated Business Taxable Income 100 Foreign Source Income On Line 16E That Is Considered Unrelated Business Taxable Income 200 Foreign Source Income On Line 16F That Is Considered Unrelated Business Taxable Income 150 Foreign Source Deductions On Line 16I That Is Considered Unrelated Business Taxable Income 50 Foreign Source Deductions On Line 16J That Is Considered Unrelated Business Taxable Income 40 Foreign Source Deductions On Line 16K That Is Considered Unrelated Business Taxable Income 30 Foreign Taxes Paid On Line 16L Attributed To Unrelated Business Taxable Income 50 Foreign Taxes Accrued On Line 16M Attributed To Unrelated Business Taxable Income 50
Line 20(Y) - Net investment income detail:
Pursuant to Internal Revenue Code Section 1411, unless otherwise noted, all of the distributive share items reported on this Schedule K-1 are subject to the net investment income tax.
Amount of guaranteed payment for use of capital treated as net investment income under Proposed Reg. §1.1411-4(g)(10) 150
Amount of guaranteed payment for services not treated as net investment income under Proposed Reg. §1.1411-4(g)(10) 50
During the 2014 tax year, the partnership made the election with respect to Controlled Foreign Corporations ("CFCs") and Qualified Electing Funds ("QEFs") under Treasury Regulation §1.1411-10(g). As such, all subpart F income and QEF income has been reported as part of net investment income and no adjustments to the amounts included and reported on Schedule K-1 under IRC §951(a) and §1293(a)(1) are required for purposes of determining net investment income under §1411 of the Internal Revenue Code.
The tax rules related to net investment income tax are complex. Please consult your tax advisor.
Line 20(Z) - Other information detail:
Interest Income From U.S. Government Obligations Reported On Line 1 100 Cost To Carry U.S. Government Obligations 50 Dividends Qualifying For The 70% Corporate Dividends Received Deduction 4,000 Foreign Qualifying Dividend Income Reflected on Line 16D 1,000
Besides amounts identified as from passive activities elsewhere on your K-1, the amounts on lines 2, 3, 10, and 12 are from passive activities.
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #10
Line 20(Z) - Other information detail (continued):
INFORMATION REPORTING UNDER IRC §6038B
The partnership was deemed to have contributed cash into foreign corporations during the year ended December 31, 2014. Because you were a partner of the partnership during the year, you may be required to file a Form 926, "Return by a U.S. Transferor of Property to a Foreign Corporation."
Generally, a U.S. citizen or resident, a domestic corporation, and any estate or trust that is not foreign may be required to file Form 926. If the transferor is a partnership, the partners of the partnership (not the partnership itself) are required to comply with IRC section 6038B and file Form 926. You should not be required to file Form 926 unless the amount of cash you contributed into a foreign corporation exceeds $100,000 during the 12-month period ending on the date of the transfer. For purposes of this determination, you should aggregate all of your contributions to the foreign corporations from whatever source.
In the event you are required to file Form 926, the following information is being provided to you:
The following information pertains to each of the Transferees listed below:
Type of non-recognition transfer: IRC §351 Cash/Capital Contribution The transfer is not subject to any of the provisions described in Form 926, Part IV, Line 11a-11d. The transfer did not result from a change in the classification of the transferee to that of a foreign corporation. The transferor is not required to recognize income under final & temporary Reg. §1.367(a)-4 through §1.367(a)-6. The transferor did not transfer assets which qualify for the trade or business exception under section 367(a)(3). There was no transfer of foreign goodwill or going concern value as defined in Temp. Reg. §1.367(a) - 1T(d)(5)(iii). The transfer did not include intangible property within the meaning of IRC §936(h)(3)(B). The transferor's interest in the foreign transferee corporation before and after the transfer was less than 1%.
Is the Country of Date of Transferee a Name, Address and Tax ID# of Transferee Contribution Amount Incorporation Contribution CFC?
Foreign Corporation #1 2014 Rue Main 700 France 2/1/2014 No Paris France Tax ID #: N/A
Foreign Corporation #2 2014 Am Main 500 Germany 4/1/2014 Yes Berlin 800 6/1/2014 Germany Tax ID #: 98-1234567
Foreign Corporation #3 2014 Main Street 600Cayman Various Yes George Town, Grand Cayman Islands Cayman Islands Tax ID #: N/A
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #11
Line 20(Z) - Other information detail (continued):
PASSIVE FOREIGN INVESTMENT COMPANY INFORMATION
The partnership has direct and/or indirect investments in passive foreign investment companies ("PFICs"). These investments require separate reporting by the partnership and its partners. A Form 8621, Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund, should be completed by each partner for each separate PFIC investment listed below and attached to their return. Any income reported below from PFICs has already been included in your distributive share of taxable income reported elsewhere on your Schedule K-1 (as indicated below). The tax rules relating to PFICs are complex. Please consult your tax advisor.
IRC §1291 Fund Information
The PFICs listed below are not QEFs within the meaning of IRC §1295. Furthermore, the shares of the PFICs are not marketable stock within the meaning of IRC §1296(e). These PFICs are IRC §1291 funds for which shareholders are subject to certain rules upon the receipt of excess distributions and/or the disposition of stock. The gains and losses from the disposition of the §1291 funds reported below have been included on Line 9a of your Schedule K-1, provided that the holding period below is greater than one year. If the holding period is one year or less, gains and losses have been included on Line 8 of your Schedule K-1. The information necessary to complete Form 8621 is presented below. The net gain or loss from the disposition of each PFIC should be reported on Line 15f of Form 8621, Part V. To the extent a net gain was reported to you related to one of the PFICs below, Line 16a of Form 8621, Part V should be completed with the information below. Any distributions received from these PFICs are detailed below and should be reported on Line 15a of Form 8621, Part V.
Acquisition Date of PFIC Sale Date of Basis of Proceeds of Stock PFIC Stock PFIC Stock PFIC Stock
Taxable Form 8621 Form 8621 Form 8621 Form 8621 Name, Address & Tax ID# of PFIC Year Line 16a Line 16a Line 16a Line 16a
PFIC #1 2014 Main Street 1/1/2014 London, England through 1/1/2008 6/30/2014 100 150 United Kingdom 12/31/2014 Tax ID #: N/A
PFIC #2 1/1/2014 2014 Rue Main through - - - - Paris, France 12/31/2014 Tax ID #: 98-7654321
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #12
Line 20(Z) - Other information detail (continued):
PASSIVE FOREIGN INVESTMENT COMPANY INFORMATION (CONTINUED)
IRC §1298(f) Reporting
Form 8621, Part I has been completed by the first U.S. person in the chain of ownership for each PFIC held directly and/or indirectly by the partnership. Except for the PFICs identified below, no further reporting is required on Form 8621, Part I. For the PFICs listed below, all information necessary to allow a partner to comply with their IRC §1298(f) reporting requirement on Form 8621, Part I is provided.
Fair Market Date of Number of Value of Description Shares Shares Held Shares Held Excess Name, Address & Taxable of Class of Acquired at End of at End of Type of Distribution Tax ID# of PFIC Year Shares During Year Year Year PFIC Amount
PFIC #1 2014 Main Street 1/1/2014 London, England through Common 6/30/2014 1,000 10,000 §1291 Fund 100 United Kingdom 12/31/2014 Class A Tax ID #: N/A
Trader Status Information:
The partnership has invested in various pass-through entities. Certain of these pass-through entities have taken the position that they are engaged in the active conduct of a business as a trader in securities. The income/loss from these partnerships' trading activities is neither passive income nor is it portfolio income for purposes of the passive activity loss rules pursuant to Temp. Reg. Sections 1.469-1T(e)(6) and 1.469-2T(c)(3)(ii)(D). Items of gain, loss, income and deduction associated with trading activities have been specifically identified on your K-1. Qualified dividend income reported on line 1 and line 6b should be reported on line 9b of Form 1040 by individuals unless they elect to include part or all of the amounts in investment income for purposes of computing the investment interest expense deduction on Form 4952. Other trading activity amounts reported on line 1 should be reported on Schedule E, part II, column (h) or (j) by 1040 filers.
The K-1 has been prepared on the assumption that the partner does not materially participate in the operations of the partnership. Interest expense reported on line 13(H) should be reported on Form 4952 by 1040 filers and, unless disallowed, entered on Schedule E, part II, column (h) if related to trading activities or on Schedule A of Form 1040 if not related to trading activities. Investment income and expense amounts on line 1 have been separately reported to you, and along with investment income and expenses reported on lines 20(A) and 20(B) should be considered when determining if there is an investment interest expense limitation on Form 4952. Additionally, amounts reported on lines 8, 9a, and 11 have not been included on lines 20(A) and 20(B) and should be considered for investment interest expense limitation purposes.
The capital gain or loss amounts reported on lines 8 and 9a should be reported on schedule D. Section 1256 gain or loss amounts reported on line 11(C) should be reported on Form 6781. Section 1231 gain or loss should be reported on Form 4797.
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #13
Line 20(Z) - Other information detail (continued):
PUBLICLY TRADED PARTNERSHIPS INFORMATION
The partnership invested indirectly in Publicly Traded Partnerships ("PTPs"). The partnership has prepared schedules which include income and loss items from each PTP. All income and loss items from PTP investments have been included in your Schedule K-1 amounts.
Passive activity limitations are applied separately for items from each PTP. Thus, a net passive loss from a PTP may not be deducted from other passive income. Instead, a passive loss from a PTP is suspended and carried forward to be applied against passive income from the same PTP in later years. If a partner's entire interest in a PTP is completely disposed of, any unused losses are allowed in full in the year of disposition.
The tax rules relating to PTPs are complex. Please consult your tax advisor.
Texas Oil and Gas PTP PTP EIN: 23-4560001
Line 1Ordinary business income (loss) 500 Line 13T Other deductions not directly Line 5Interest income 490 (continued) allocable to DPGR 290 Line 6aOrdinary dividends 480 Other deductions not directly Line 6bQualified dividends 470 allocable to non-DPGR 280 Line 8Net short-term capital gain (loss) 460 Line 13U Qualified production activities Line 9aNet long-term capital gain (loss) 450 income 270 Line 10Net section 1231 gain (loss) 440 Line 13V Employer's Form W-2 wages 250 Line 11AOther portfolio income (loss) 430 Line 16B Gross income from all sources 3,390 Line 11ECancellation of debt 100 Line 16C Gross income sourced at partner Line 11FOther income (loss) 40 level 1,350 Line 13ACash contributions (50%) 50 Line 16D Passive category 230 Line 13BCash contributions (30%) 6 Line 16L Total foreign taxes paid 220 Line 13HInvestment interest expense 380 Line 17A Post-1986 depreciation Line 13JSection 59(e)(2) expenditures 200 adjustment 210 Line 13KDeductions - portfolio (2% floor) 360 Line 17B Adjusted gain or loss 200 Line 13TDPGR 350 Line 17D Oil, gas, & geothermal - 100 Non-DPGR 340 gross income COGS allocable to DPGR 330 Line 17E Oil, gas, & geothermal-deductions 100 COGS allocable to non-DPGR 320 Line 17F Other AMT items 50 Deductions, expenses, and losses Line 18ATax-exempt interest income 160 directly allocable to DPGR 310 Line 18CNondeductible expenses 150 Deductions directly allocable Line 20VUBTI ordinary income (loss) 140 to non-DPGR 300 UBTI short-term capital gain(loss) 130 UBTI long-term capital gain(loss) 120 State Sourced Income (Loss) From Texas Oil and Gas PTP
Alabama 25 Florida 48 Kentucky 68 Alaska 28 Georgia 50 Massachusetts 78 Arizona 30 Hawaii 53 New Hampshire 98 Arkansas 33 Idaho 55 New York 108 California 35 Illinois 58 North Carolina 108 Colorado 38 Indiana 60 South Carolina 128 Connecticut 40 Iowa 63 Texas 135 Delaware 43 Kansas 65 West Virginia 148 DC 45
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #14
Line 20(Z) - Other information detail (continued):
PUBLICLY TRADED PARTNERSHIPS INFORMATION (CONTINUED)
Oklahoma Oil and Gas PTP PTP EIN: 23-4560002
Line 1Ordinary business income (loss) 400 Line 13V Employer's Form W-2 wages 250 Line 6aOrdinary dividends 390 Line 16B Gross income from all sources 1,580 Line 8Net short-term capital gain (loss) 380 Line 16C Gross income sourced at partner Line 10Net section 1231 gain (loss) 360 level 740 Line 11ECancellation of debt 50 Line 16D Passive category 250 Line 13ACash contributions (50%) 50 Line 16L Total foreign taxes paid 240 Line 13HInvestment interest expense 340 Line 17A Post-1986 depreciation Line 13KDeductions - portfolio (2% floor) 330 adjustment 230 Line 13TNon-DPGR 320 Line 17D Oil, gas, & geothermal - COGS allocable to non-DPGR 310 gross income 100 Deductions directly allocable Line 17FOther AMT items 50 to non-DPGR 300 Line 18CNondeductible expenses 50 Other deductions not directly Line 20VUBTI ordinary income (loss) 200 allocable to non-DPGR 290 UBTI short-term capital gain(loss) 190 UBTI long-term capital gain(loss) 180 State Sourced Income (Loss) From Oklahoma Oil and Gas PTP
Alabama 20 Florida 30 Kansas 38 Arizona 22 Georgia 32 Massachusetts 40 California 24 Idaho 34 New York 42 Connecticut 26 Indiana 36 South Carolina 44 Delaware 28
Alaska Oil and Gas PTP Fully Disposed of in 2013 PTP EIN: 23-4560003
Line 5Interest income 300 Line 13T Other deductions not directly Line 6aOrdinary dividends 290 (continued) allocable to DPGR 200 Line 9aNet long-term capital gain (loss) 280 Line 13U Qualified production activities Line 11A Other portfolio income (loss) 270 income 190 Line 11FOther income (loss) 20 Line 16B Gross income from all sources 1,160 Line 13JSection 59(e)(2) expenditures 100 Line 16C Gross income sourced at partner Line 13TDPGR 230 level 280 COGS allocable to DPGR 220 Line 17B Adjusted gain or loss 160 Deductions, expenses, and losses Line 17D Oil, gas, & geothermal - directly allocable to DPGR 210 gross income 100 Line 17EOil, gas, & geothermal - deduction 100
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #15
Line 20(Z) - Other information detail (continued):
State Sourced Income/(Loss):
The partnership received pass-through income from other partnerships that engage in trade or business activities in various states. Each partner should assess their state filing requirements in each state. For certain states, we have included state K-1s which may provide more detail than that shown below. State source income (loss) amounts from PTPs that are disclosed elsewhere on the K-1 are included in the amounts shown below. Your proportionate share of the state sourced income/(loss) by state is as follows:
Alabama 1,000 Alaska 1,000 Arizona 1,000 Arkansas 1,000 California 1,000 Colorado 1,000 Connecticut 1,000 Delaware 1,000 District of Columbia 1,000 Florida 1,000 Georgia 1,000 Hawaii 1,000 Idaho 1,000 Illinois 1,000 Indiana 1,000 Iowa 1,000 Kansas 1,000 Kentucky 1,000 Louisiana 1,000 Maine 1,000 Maryland 1,000 Massachusetts 1,000 Michigan 1,000 Minnesota 1,000 Mississippi 1,000 Missouri 1,000 Montana 1,000 Nebraska 1,000 Nevada 1,000 New Hampshire 1,000 New Jersey 1,000 New Mexico 1,000 New York 1,000 New York City (Included in New York State Amount) 1,000 North Carolina 1,000 North Dakota 1,000 Ohio 1,000 Oklahoma 1,000 Oregon 1,000 Pennsylvania 1,000 Rhode Island 1,000
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #16
Line 20(Z) - Other information detail (continued):
State Sourced Income/(Loss) (continued):
South Carolina 1,000 South Dakota 1,000 Tennessee 1,000 Texas 1,000 Utah 1,000 Vermont 1,000 Virginia 1,000 Washington 1,000 West Virginia 1,000 Wisconsin 1,000 Wyoming 1,000
New York City Unincorporated Business Tax Credit 100
Reportable Transaction Information:
Disclosure Acknowledgement Pursuant to IRS Notice 2006-16
The partnership hereby acknowledges, pursuant to Internal Revenue Service (IRS) Notice 2006-16, that it has direct or indirect investments in the following entities, each of which has acknowledged they have or will comply with their separate disclosure obligations under Treasury Regulation Section 1.6011-4 with respect to transactions described in IRS Notice 2002-35 by filing a protective Form 8886 (Reportable Transaction Disclosure Statement) under Treasury Regulation Section 1.6011-4(f)(2).
Partnership I, L.P. Partnership II, L.P. Partnership III, L.P.
In accordance with Notice 2006-16, Section 3.02, by timely receipt of this acknowledgement, you should not be required to file a disclosure statement for these transactions, provided your only disclosure obligation with respect to these transactions under Treasury Regulation Section 1.6011-4(b) arises from your direct or indirect interest in the partnership or the entities listed above.
Pass-through entities receiving this acknowledgement must timely provide a copy of it to taxpayers holding an interest in the pass-through entity, under Notice 2006-16, Section 3.02, in order for such taxpayers to be relieved of the requirement to file a disclosure statement for these transactions, provided their only disclosure obligation with respect to these transactions under Treasury Regulation Section 1.6011-4(b) arises from their indirect interest in the partnership or the entities listed above.
Please consult your tax advisor with regard to this acknowledgement and IRS Notice 2006-16.
Partner # 106 Hedge Fund of Funds 12-3450000 Schedule K-1 Supporting Schedules - Statement #17
Line 20(Z) - Other information detail (continued):
Reportable Transaction Information (continued):
Protective Form 8886 - Reportable Transaction Disclosure Statement
The partnership is a partner in the following partnerships (collectively the "Funds"):
Partnership I, L.P. (EIN: 11-1111111) Partnership II, L.P. (EIN: 22-2222222)
The Funds have engaged in IRC section 988 transactions that may be reportable transactions. A protective Form 8886 disclosure has been made for the Funds at the partnership level. The partnership's share of the section 988 loss was not provided. As a result, it is not possible for the partnership to provide each partner's share of the section 988 loss.
The realized loss on IRC section 988 transactions is in connection with the Funds' regular trading activities and was not carried out as part of any plan to achieve tax benefits. It is not anticipated that there will be any expected tax benefits. The partner's share of the section 988 loss is netted with the overall section 988 gain or loss reported on the 2012 schedule K-1 which is available to be claimed on 2012 tax returns. It is not expected that these section 988 transactions will generate any prior or future tax benefits.
Please consult your tax advisor regarding Form 8886 federal and state reporting obligations.
Protective Form 8886 - Reportable Transaction Disclosure Statement
The partnership is a partner in the following partnerships (collectively the "Funds"):
Partnership III, L.P. (EIN: 33-3333333) Partnership IV, L.P. (EIN: 44-4444444)
The Funds have engaged in Internal Revenue Code ("IRC") Section 988 transactions which may be reportable transactions. Generally, in the case of a partner holding an indirect investment in the Funds who is an individual or a trust, the partner will have a reportable IRC Section 988 loss transaction if the partner's share of the IRC Section 988 loss transaction from the Fund was at least $50,000. Each IRC Section 988 loss transaction in which the partner's share of the loss was at least $50,000 has been reported to the partner below. Acquisition Disposal DescriptionDate Date Loss Section 988 Reportable Loss Transactions - Partnership III 2/1/2007 9/30/2014 50,000 Section 988 Reportable Loss Transactions - Partnership IV 6/1/2008 10/31/2014 55,000
Please see Form 8886 and the form instructions for further details on when you are required to file Form 8886 and specific details on how to complete Form 8886, if necessary, and consult your tax advisor.
Partner # 106 651113 Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 2014 Part III Partner’s Share of Current Year Income, (Form 1065) Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning , 2014 ending , 20 2 Net rental real estate income (loss) Partner’s Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. a See back of form and separate instructions.
Part I Information About the Partnership 4 Guaranteed payments A Partnership’s employer identification number 5 Interest income
B Partnership’s name, address, city, state, and ZIP code 6a Ordinary dividends
6b Qualified dividends
C IRS Center where partnership filed return 7 Royalties
D Check if this is a publicly traded partnership (PTP) 8 Net short-term capital gain (loss)
Part II Information About the Partner 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items E Partner’s identifying number 9b Collectibles (28%) gain (loss)
F Partner’s name, address, city, state, and ZIP code 9c Unrecaptured section 1250 gain
10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses
G General partner or LLC Limited partner or other LLC 11 Other income (loss) member-manager member
H Domestic partner Foreign partner
I1 What type of entity is this partner? I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc.), check here 19 Distributions ...... 12 Section 179 deduction
J Partner’s share of profit, loss, and capital (see instructions): Beginning Ending 13 Other deductions
Profit % % 20 Other information Loss % % Capital % %
K Partner’s share of liabilities at year end: Nonrecourse ...... $ 14 Self-employment earnings (loss) Qualified nonrecourse financing . $ Recourse ...... $
L Partner’s capital account analysis: *See attached statement for additional information. Beginning capital account ... $ Capital contributed during the year $ Current year increase (decrease) . $ Withdrawals & distributions . . $ ( ) Ending capital account .... $
Tax basis GAAP Section 704(b) book Other (explain) For IRS Use Only M Did the partner contribute property with a built-in gain or loss? Yes No If “Yes,” attach statement (see instructions)
For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.gov/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities See the Partner’s Instructions Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes } 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a Gross income sourced at } C 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category } Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category } Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) See the Partner’s A Post-1986 depreciation adjustment E Capital gain property to a 50% Instructions B Adjusted gain or loss See the Partner’s organization (30%) } C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income } the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 } See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer’s Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit L Dispositions of property with (section 42(j)(5)) from pre-2008 section 179 deductions buildings M Recapture of section 179 deduction B Low-income housing credit N Interest expense for corporate (other) from pre-2008 buildings partners C Low-income housing credit O Section 453(l)(3) information (section 42(j)(5)) from P Section 453A(c) information post-2007 buildings See the Partner’s Instructions Q Section 1260(b) information D Low-income housing credit R Interest allocable to production See the Partner’s (other) from post-2007 expenditures Instructions buildings S CCF nonqualified withdrawals } T Depletion information—oil and gas E Qualified rehabilitation expenditures (rental real estate) U Reserved F Other rental real estate credits V Unrelated business taxable income } G Other rental credits W Precontribution gain (loss) H Undistributed capital gains credit Form 1040, line 73; check box a X Section 108(i) information I Biofuel producer credit Y Net investment income J Work opportunity credit Z Other information } See the Partner's Instructions K Disabled access credit Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #1
Part II, Item J - Partner's share of profit, loss, and capital:
Beginning and ending capital percentages are based on partners' beginning and ending capital accounts as reflected in Part II, Item L as a percentage of total partnership capital.
Beginning profit and loss percentages reflect beginning of year book capital percentages.
Ending profit percentages are based on partners' allocation of distributive share of income and gains on a tax basis as a percentage of total partnership amounts. Ending loss percentages are based on partners' allocation of distributive share of deductions and losses on a tax basis as a percentage of total partnership amounts. These percentages may differ significantly from your ending capital percentage due to the timing of contributions and withdrawals during the year, the timing of when income and losses occurred during the year, and tax allocations of gains and losses pursuant to IRC §704(c).
Part II, Item L - Current year increase (decrease) reconciliation:
Partner's Distributive Share of Taxable Income 29,100 Less: Line 15 - Credits (100) Unrealized Appreciation (Depreciation) and Other Timing Differences 121,000 Subtotal: Book Income 150,000 Net Partnership Transfers -
Total Current Year Increase (Decrease) 150,000
Line 1 - Ordinary business income (loss) detail:
Interest Income From Trading Activities 5,000 Qualified Dividends From Trading Activities 6,100 Other Dividends From Trading Activities 100 Net Section 988 Gain (Loss) From Trading Activities 1,000 Other Income (Loss) From Trading Activities 21,400 Other Expenses From Trading Activities (5,000)
Total Ordinary Business Income (Loss) 28,600
Line 8 - Net short-term capital gain (loss) detail:
Net Short-Term Capital Gain (Loss) From Trading Activities 8,000
Total Net Short-Term Capital Gain (Loss) 8,000
Line 9a - Net long-term capital gain (loss) detail:
Net Long-Term Capital Gain (Loss) From Trading Activities (2,000)
Total Net Long-Term Capital Gain (Loss) (2,000)
Line 11(C) - Section 1256 contracts and straddles detail:
Net Section 1256 Gain (Loss) From Trading Activities 1,500
Total Section 1256 Gain (Loss) 1,500
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #2
Line 13(H) - Investment interest expense detail:
Investment Interest Expense From Trading Activities 6,000
Total Investment Interest Expense 6,000
Line 13(T) - Domestic production activities information:
None of the partnership's items relate to domestic production activities. If you otherwise have Internal Revenue Code Section 199 activities, gross income from all sources has been reported on Line 16B. Additional information, if needed, is available upon request.
Line 15(P) - Other credits detail:
U.S. Taxes Withheld 100
Total Other Credits 100
Line 16 - Foreign transactions:
A. Name of country or U.S. possession Various B. Gross income from all sources 49,400 C. Gross income sourced at partner level 16,800 Foreign gross income sourced at partnership level D. Passive category 5,000 E. General category - F. Other - Deductions allocated and apportioned at partner level G. Interest expense 6,000 H. Other 13,300 Deductions allocated and apportioned at partnership level to foreign source income I. Passive category - J. General category - K. Other - Other information L. Total foreign taxes paid 1,000
Line 20(N) - Interest expense for corporate partners detail:
For corporate partners, your distributive share of the partnership's interest expense has been reported on Line 13(H) of your Schedule K-1. A corporate partner's distributive share of interest income, interest expense and partnership liabilities are treated as income, expense and liabilities of the corporation for purposes of the limitation on the deduction for interest under IRC §163(j). The interest expense limitation rules for corporations are complex. Please consult your tax advisor.
Line 20(V) - Unrelated business taxable income detail:
Ordinary Income (Loss) Considered Unrelated Business Taxable Income - Short-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income - Long-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income -
Total Unrelated Business Taxable Income -
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #3
Line 20(Y) - Net Investment Income Detail
Pursuant to Internal Revenue Code §1411, unless otherwise noted, all of the distributive share items reported on this Schedule K- 1 are subject to the net investment income tax.
The partnership is a foreign partnership and, as such, is not eligible to make the Treasury Regulation §1.1411-10(g) election with respect to Controlled Foreign Corporations ("CFCs") and Qualified Electing Funds ("QEFs") held by the partnership. Eligible partners of the partnership nonetheless may make a Treasury Regulation §1.1411-10(g) election themselves for indirect holdings of CFCs and QEFs held through their interest in the partnership.
The tax rules related to net investment income tax are complex. Please consult your tax advisor.
Line 20(Z) - Other information detail:
Dividends Qualifying For The 70% Corporate Dividends Received Deduction 4,000 Foreign Qualifying Dividend Income Reflected on Line 16D 1,000
Trader Status Information:
The partnership has taken the position that it is engaged in the active conduct of a business as a trader in securities. The income/loss from the partnership's trading activities is neither passive income nor is it portfolio income for purposes of the passive activity loss rules pursuant to Temp. Reg. Sections 1.469-1T(e)(6) and 1.469-2T(c)(3)(ii)(D). Items of gain, loss, income and deduction associated with trading activities have been specifically identified on your K-1. Qualified dividend income reported on line 1 should be reported on line 9b of Form 1040 by individuals unless they elect to include part or all of the amounts in investment income for purposes of computing the investment interest expense deduction on Form 4952. Other trading activity reported on line 1 should be reported on Schedule E, Part II, column (h) or (j) by 1040 filers.
The K-1 has been prepared on the assumption that the partner does not materially participate in the operations of the partnership. Interest expense reported on line 13(H) should be reported on Form 4952 by 1040 filers and, unless disallowed, entered on Schedule E, part II, column (h). Investment income and expense amounts on line 1 have been separately reported to you and should be considered when determining if there is an investment interest expense limitation on Form 4952.
The capital gain or loss amounts reported on lines 8 and 9a should be reported on schedule D. Section 1256 gain or loss amounts reported on line 11(C) should be reported on Form 6781.
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #4
Line 20(Z) - Other information detail (continued):
INFORMATION REPORTING UNDER IRC §6038
Foreign Hedge Fund Trader in Securities is classified as a foreign partnership. Because of contributions made to the partnership during the year and/or because of your ownership percentage of the partnership, you may be required to file Form 8865, “Return of U.S. Persons With Respect to Certain Foreign Partnerships.”
Generally, a U.S. citizen or resident, a domestic partnership, a domestic corporation, and any estate or trust that is not foreign may be required to file Form 8865. You should not be required to file Form 8865 unless the amount of cash you contributed into a foreign partnership exceeds $100,000 during the 12-month period ending on the date of the transfer, or unless the ownership percentage in a foreign partnership exceeds 10% during the tax year. For purposes of this determination, you should aggregate all of your contributions to the foreign partnership from whatever source.
The date, amount of the cash contribution, and your deemed ownership percentage for Foreign Hedge Fund Trader in Securities are as follows:
Foreign Hedge Fund Trader in Securities 1/1/2014 100,000 14.285714%
In the event you are required to file Form 8865, the following information is being provided to you:
Foreign Hedge Fund Trader in Securities is organized under the laws of the Cayman Islands as an Exempted Limited Partnership. The partnership's address is 2014 Mary Street, George Town, Grand Cayman, Cayman Islands. The partnership was organized on January 1, 2014 and its principal place of business is the Cayman Islands. The principal business activity of the partnership is investments (code number 523900). The name and address of the partnership’s agent in the Cayman Islands is Walkers SPV Limited, Walker House, Mary Street, P.O. Box 256GT, George Town, Grand Cayman, Cayman Islands. The books of the partnership are in care of Andy Prunier, Massachusetts Partnership, 2014 Main Street, Boston, MA 02110. The partnership did not make any special allocations. Total receipts for the tax year were less than $250,000 and total assets at the end of the year were in excess of $1,000,000. The partnership’s functional currency is the U.S. dollar. The partnership’s EIN is 98-1234500 and the partnership filed Form 1065 in Ogden, Utah. The partnership did not own any separate units within the meaning of Regulations §1.1503-2(c)(3), (4), or 1.1503(d)-1(b)(4).
The information reporting requirements under IRC §6038 are complex. Please consult your tax advisor.
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #5
Line 20(Z) - Other information detail (continued):
INFORMATION REPORTING UNDER IRC §6038B
The partnership was deemed to have contributed cash into foreign corporations during the year ended December 31, 2014. Because you were a partner of the partnership during the year, you may be required to file a Form 926, "Return by a U.S. Transferor of Property to a Foreign Corporation."
Generally, a U.S. citizen or resident, a domestic corporation, and any estate or trust that is not foreign may be required to file Form 926. If the transferor is a partnership, the partners of the partnership (not the partnership itself) are required to comply with IRC section 6038B and file Form 926. You should not be required to file Form 926 unless the amount of cash you contributed into a foreign corporation exceeds $100,000 during the 12-month period ending on the date of the transfer. For purposes of this determination, you should aggregate all of your contributions to the foreign corporations from whatever source.
In the event you are required to file Form 926, the following information is being provided to you:
Unless otherwise indicated, the following information pertains to each of the Transferees listed below:
Type of non-recognition transfer: IRC §351 Cash/Capital Contribution The transfer is not subject to any of the provisions described in Form 926, Part IV, Line 11a-11d. The transfer did not result from a change in the classification of the transferee to that of a foreign corporation. The transferor is not required to recognize income under final & temporary Reg. §1.367(a)-4 through §1.367(a)-6. The transferor did not transfer assets which qualify for the trade or business exception under section 367(a)(3). There was no transfer of foreign goodwill or going concern value as defined in Temp. Reg. §1.367(a) - 1T(d)(5)(iii). The transfer did not include intangible property within the meaning of IRC §936(h)(3)(B). The transferor's interest in the foreign transferee corporation before and after the transfer was less than 1%.
Is the Country of Date of Transferee a Name, Address and Tax ID# of Transferee Contribution Amount Incorporation Contribution CFC?
Foreign Corporation #1 2012 Rue Main 600,000 France 1/1/2014 No Paris France Tax ID #: N/A
Foreign Corporation #2 2012 Am Main 50,000 Germany 4/1/2014 Yes Berlin Germany Tax ID #: 98-1234567
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #6
Line 20(Z) - Other information detail (continued):
INFORMATION REPORTING UNDER IRC §6038B (CONTINUED)
Is the Contribution Amount Country of Date of Transferee a Name, Address and Tax ID# of Transferee FMV Basis Gain Incorporation Contribution CFC?
Foreign Corporation #3 2014 Main Street CashUnited 2/1/2014 Yes London, England 500 N/A - Kingdom United Kingdom Accounts Receivable Tax ID #: N/A 1,000 1,000 - Fixed Assets 10,000 10,000 -
Part IV of Form 926, Lines 11, 12, 13b-d, 15a, 16, 17a should be answered No. Lines 13a and 14 should be answered Yes.
Country of Date of Property Name, Address and Tax ID# of Transferee Type of Property FMV Incorporation Contribution Description
Foreign Corporation #1 Accounts Receivable 500 France Various Trade/Other 2014 Rue Main Inventory 400 France Various Inventory Paris Property used in TOB 300 France Various Fixed Assets France Intangible Property 200 France Various Goodwill Tax ID #: N/A
Part IV of Form 926, Lines 11, 12, 13b-d, 16, and 17a should be answered No. Lines 13a, 14, and 15a should be answered Yes.
INFORMATION REPORTING UNDER IRC §6038D
Unless an exception applies, a specified individual that has an interest in specified foreign financial assets that exceeds the reportable threshold must complete and attach to their return Form 8938, Statement of Specified Foreign Financial Assets. Your investment in the partnership may give rise to a Form 8938 filing obligation. Please refer to the instructions for Form 8938 for detailed information and consult your tax advisor.
If you are required to file Form 8938, most of the information necessary to complete the form is included on the Schedule K-1. You should be able to obtain the maximum fair market value of the foreign financial asset from your monthly capital statements.
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #7
Line 20(Z) - Other information detail (continued):
PASSIVE FOREIGN INVESTMENT COMPANY INFORMATION
The partnership has direct and/or indirect investments in passive foreign investment companies ("PFICs"). These investments require separate reporting by the partnership and its partners. A Form 8621, Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund, should be completed by each partner for each separate PFIC investment listed below and attached to their return. Certain income items reported below from PFICs have already been included in your distributive share of taxable income reported elsewhere on your Schedule K-1 (as indicated below). The tax rules relating to PFICs are complex. Please consult your tax advisor.
PFIC Annual Intermediary Statement
For the PFICs listed below, the partnership has received a PFIC Annual Information Statement (for direct investments) and/or a PFIC Annual Intermediary Statement (for indirect investments) containing the required information and statements pursuant to Reg. §§ 1.1295-1(g)(1) and 1.1295-1(g)(3) for its direct and/or indirect investments, respectively. The information below is provided to enable you to make a section 1295 Qualified Electing Fund ("QEF") election with respect to your indirect interest in these PFICs. The partnership cannot make this election at the fund level as it is not the initial U.S. shareholder. The following income items have NOT been included in your distributive share of taxable income on your K-1. Should you qualify for QEF treatment, your pro-rata share of ordinary earnings reported below should be added to Ordinary Income on your K-1. Your pro- rata share of capital gains reported below should be added to capital gains included on Line 9 of your K-1. If you choose not to make the QEF election, or if you are not eligible to make the election, none of the income items reported below should be added to your taxable share of income from this partnership.
The PFICs marked with an asterisk have been partially or fully disposed of during the year. Please consult your tax advisor regarding any potential adjustments to the gain/(loss) on disposition of these QEF investments. The information necessary to complete Form 8621 is presented below, as well as the corresponding lines where the information should be entered on Part III of Form 8621.
Pro-Rata Pro-Rata Share of Share of Pro-Rata Ordinary Capital Share of Earnings Gains Distributions
Taxable Form 8621 Form 8621 Form 8621 Name, Address & Tax ID# of PFIC Year Line 6a Line 7a Line 8b
PFIC #1 2012 Main Street 1/1/2013 London, England through - - - United Kingdom 12/31/2013 Tax ID #: N/A
PFIC #2* 2012 Rue Main 1/1/2013 Paris, France through 1,000 500 - Tax ID #: 98-7654321 12/31/2013
Partner # 1 Foreign Hedge Fund Trader in Securities Schedule K-1 Supporting Schedules - Statement #8
Line 20(Z) - Other information detail (continued):
PFIC Mark-to-Market Election Information
The PFICs listed below meet the definition of "marketable stock" within the meaning of IRC Section 1296(e). The partnership cannot make this election at the fund level as it is not the initial U.S. shareholder. The information below is provided to enable you to make the Section 1296 Mark-to-Market election with respect to your indirect interest in these PFICs. The amount shown below has been included in dividend income reported on Line 6a of your K-1.
Fair Market Adjusted Value Basis Excess @12/31/2014 @12/31/2014 @12/31/2014
Form 8621 Form 8621 Form 8621 Name and Address of PFIC Tax ID# Taxable Year Line 10a Line 10b Line 10c
PFIC #4 1/1/2014 2014 Church Street N/Athrough - - 4,000 George Town, Grand Cayman 12/31/2014 Cayman Islands
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #9
Line 20(Z) - Other information detail (continued):
IRC §1291 Fund Information
The PFICs listed below are not QEFs within the meaning of IRC §1295. Furthermore, the shares of the PFICs are not marketable stock within the meaning of IRC §1296(e). These PFICs are IRC §1291 funds for which shareholders are subject to certain rules upon the receipt of excess distributions and/or the disposition of stock. The gains and losses from the disposition of the §1291 funds reported below have been included on Line 9a of your Schedule K-1, provided that the holding period below is greater than one year. If the holding period is one year or less, gains and losses have been included on Line 8 of your Schedule K-1. The information necessary to complete Form 8621 is presented below. The net gain or loss from the disposition of each PFIC should be reported on Line 15f of Form 8621, Part V. To the extent a net gain was reported to you related to one of the PFICs below, Line 16a of Form 8621, Part V should be completed with the information below. Any distributions received from these PFICs are detailed below and should be reported on Line 15a of Form 8621, Part V.
Acquisition Date of PFIC Sale Date of Basis of Proceeds of Stock PFIC Stock PFIC Stock PFIC Stock
Taxable Form 8621 Form 8621 Form 8621 Form 8621 Name, Address & Tax ID# of PFIC Year Line 16a Line 16a Line 16a Line 16a
PFIC #3 2014 Main Street 1/1/2014 George Town, Grand Cayman through 3/1/2011 10/1/2014 100,000 150,000 Cayman Islands 12/31/2014 Tax ID #: N/A
If elections were not made to treat the following investments as QEFs, these entities would be treated as IRC §1291 funds. The gain/(loss) associated with the sale of these investments has already been included elsewhere on your schedule K-1.
PFIC #2 2014 Rue Main 1/1/2014 1/1/2014 7/1/2014 200,000 225,000 Paris, France through 1/1/2014 9/1/2014 250,000 225,000 Tax ID #: 98-7654321 12/31/2014
Partner # 1 Foreign Hedge Fund Trader in Securities 98-1234500 Schedule K-1 Supporting Schedules - Statement #10
Line 20(Z) - Other information detail (continued):
PASSIVE FOREIGN INVESTMENT COMPANY INFORMATION (CONTINUED)
IRC §1298(f) Reporting
Generally, Temporary Regulation §1.1298-1T requires shareholders that are the first U.S. person in the chain of ownership of a PFIC to complete Form 8621, Part I for each PFIC owned by the shareholder during the shareholder's taxable year. Certain exceptions to these filing requirements are discussed in the instructions to Form 8621 and Treasury Regulation §1.1298.
The partnership is a foreign partnership, and as such cannot satisfy the filing requirements of its U.S. partners. The information to enable U.S. persons to comply with their Form 8621, Part I filing requirements are provided for each PFIC held by the partnership during the tax year.
§1291 Excess Distribution Fair Market or Date of Number of Value of §1293/ Description Shares Shares Held Shares Held §1295 Name, Address & Taxable of Class of Acquired at End of at End of Type of Inclusion Tax ID# of PFIC Year Shares During Year Year Year PFIC Amount
PFIC #1 2012 Main Street 1/1/2014 Dependent Dependent London, England through Common 6/30/2014 1,000 10,000 on Partner on Partner United Kingdom 12/31/2014 Class A Election Election Tax ID #: N/A
PFIC #2 2012 Rue Main 1/1/2014 Dependent Dependent Paris, France through Common 2,000 20,000 on Partner on Partner Tax ID #: 98-7654321 12/31/2014 Class A Election Election
PFIC #4 2012 Church Street 1/1/2014 Dependent Dependent George Town, Grand Cayma through Common 3,000 30,000 on Partner on Partner Cayman Islands 12/31/2014 Class A Election Election
PFIC #5 111 Front Street 1/1/2014 Hamilton, HM11 through Preferred 4,000 40,000 §1291 Fund - Bermuda 12/31/2014 Class B
Partner # 1 651113 Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 2014 Part III Partner’s Share of Current Year Income, (Form 1065) Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning , 2014 ending , 20 2 Net rental real estate income (loss) Partner’s Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. a See back of form and separate instructions.
Part I Information About the Partnership 4 Guaranteed payments A Partnership’s employer identification number 5 Interest income
B Partnership’s name, address, city, state, and ZIP code 6a Ordinary dividends
6b Qualified dividends
C IRS Center where partnership filed return 7 Royalties
D Check if this is a publicly traded partnership (PTP) 8 Net short-term capital gain (loss)
Part II Information About the Partner 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items E Partner’s identifying number 9b Collectibles (28%) gain (loss)
F Partner’s name, address, city, state, and ZIP code 9c Unrecaptured section 1250 gain
10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses
G General partner or LLC Limited partner or other LLC 11 Other income (loss) member-manager member
H Domestic partner Foreign partner
I1 What type of entity is this partner? I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc.), check here 19 Distributions ...... 12 Section 179 deduction
J Partner’s share of profit, loss, and capital (see instructions): Beginning Ending 13 Other deductions
Profit % % 20 Other information Loss % % Capital % %
K Partner’s share of liabilities at year end: Nonrecourse ...... $ 14 Self-employment earnings (loss) Qualified nonrecourse financing . $ Recourse ...... $
L Partner’s capital account analysis: *See attached statement for additional information. Beginning capital account ... $ Capital contributed during the year $ Current year increase (decrease) . $ Withdrawals & distributions . . $ ( ) Ending capital account .... $
Tax basis GAAP Section 704(b) book Other (explain) For IRS Use Only M Did the partner contribute property with a built-in gain or loss? Yes No If “Yes,” attach statement (see instructions)
For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.gov/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities See the Partner’s Instructions Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes } 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a Gross income sourced at } C 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category } Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category } Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) See the Partner’s A Post-1986 depreciation adjustment E Capital gain property to a 50% Instructions B Adjusted gain or loss See the Partner’s organization (30%) } C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income } the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 } See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer’s Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit L Dispositions of property with (section 42(j)(5)) from pre-2008 section 179 deductions buildings M Recapture of section 179 deduction B Low-income housing credit N Interest expense for corporate (other) from pre-2008 buildings partners C Low-income housing credit O Section 453(l)(3) information (section 42(j)(5)) from P Section 453A(c) information post-2007 buildings See the Partner’s Instructions Q Section 1260(b) information D Low-income housing credit R Interest allocable to production See the Partner’s (other) from post-2007 expenditures Instructions buildings S CCF nonqualified withdrawals } T Depletion information—oil and gas E Qualified rehabilitation expenditures (rental real estate) U Reserved F Other rental real estate credits V Unrelated business taxable income } G Other rental credits W Precontribution gain (loss) H Undistributed capital gains credit Form 1040, line 73; check box a X Section 108(i) information I Biofuel producer credit Y Net investment income J Work opportunity credit Z Other information } See the Partner's Instructions K Disabled access credit Domestic Hedge Fund Investor in Securities 12-3450000 Schedule K-1 Supporting Schedules - Statement #1
Part II, Item J - Partner's share of profit, loss, and capital:
Beginning and ending capital percentages are based on partners' beginning and ending capital accounts as reflected in Part II, Item L as a percentage of total partnership capital.
Beginning profit and loss percentages reflect beginning of year book capital percentages.
Ending profit percentages are based on partners' allocation of distributive share of income and gains on a tax basis as a percentage of total partnership amounts. Ending loss percentages are based on partners' allocation of distributive share of deductions and losses on a tax basis as a percentage of total partnership amounts. These percentages may differ significantly from your ending capital percentage due to the timing of contributions and withdrawals during the year, the timing of when income and losses occurred during the year, and tax allocations of gains and losses pursuant to IRC §704(c).
Part II, Item L - Current year increase (decrease) reconciliation:
Partner's Distributive Share of Taxable Income 187,500 Unrealized Appreciation (Depreciation) and Other Timing Differences 1,312,500 Subtotal: Book Income 1,500,000 Net Partnership Transfers -
Total Current Year Increase (Decrease) 1,500,000
Part II, Item M - Contributed property with a built-in gain or loss:
Contribution Fair Market Adjusted Built-in Built-in # of Properties ContributedDate Value Basis Gain Loss
20 3/1/2014 945,000 960,000 30,000 (45,000)
Line 6(a) - Ordinary dividends detail:
Foreign Dividends 42,000 U.S. Dividends 20,000
Total Ordinary Dividends 62,000
Line 6(b) - Qualified dividends detail:
Foreign Qualified Dividends 40,000 U.S. Qualified Dividends 19,000
Total Qualified Dividends 59,000
Line 11(A) - Other portfolio income (loss) detail:
Net Section 988 Gain (Loss) 9,000 Other Portfolio Income (Loss) 1,000
Total Other Portfolio Income (Loss) 10,000
Partner # 1 Domestic Hedge Fund Investor in Securities 12-3450000 Schedule K-1 Supporting Schedules - Statement #2
Line 11(C) - Section 1256 contracts and straddles detail:
Net Section 1256 Gain (Loss) 2,000
Total Section 1256 Gain (Loss) 2,000
Line 13(H) - Investment interest expense detail:
Investment Interest Expense 20,000
Total Investment Interest Expense 20,000
Line 13(K) - Deductions - portfolio (2% floor) detail:
Deductions - Portfolio (2% Floor) 50,000
Total Deductions - Portfolio (2% Floor) 50,000
Line 13(T) - Domestic production activities information:
None of the partnership's items relate to domestic production activities. If you otherwise have Internal Revenue Code Section 199 activities, gross income from all sources has been reported on Line 16B. Additional information, if needed, is available upon request.
Line 16 - Foreign transactions:
A. Name of country or U.S. possession Various B. Gross income from all sources 262,500 C. Gross income sourced at partner level 140,500 Foreign gross income sourced at partnership level D. Passive category 50,000 E. General category - F. Other - Deductions allocated and apportioned at partner level G. Interest expense 20,000 H. Other 40,476 Deductions allocated and apportioned at partnership level to foreign source income I. Passive category 9,524 J. General category - K. Other - Other information L. Total foreign taxes paid 5,000
Partner # 1 Domestic Hedge Fund Investor in Securities 12-3450000 Schedule K-1 Supporting Schedules - Statement #3
Line 19(C) - Other property distributions detail:
Distribution Shares Acquisition Fair Market Stock Distributed Date Distributed Date Cost Value
Corporation #1 7/1/2014 100 6/1/2011 10,000 15,000 Corporation #2 7/1/2014 200 6/1/2011 30,000 25,000 Corporation #2 7/1/2014 300 6/1/2011 32,000 30,000 Corporation #3 7/1/2014 400 6/1/2011 45,000 50,000 Corporation #3 7/1/2014 500 6/1/2011 45,000 60,000 Corporation #3 7/1/2014 600 6/1/2011 73,000 70,000
Total 235,000 250,000
Line 20(A) & 20(B) - Investment income/expenses:
Amounts reported on line 11 have not been included on lines 20(A) and 20(B) and should be considered for investment interest expense limitation purposes.
Line 20(N) - Interest expense for corporate partners detail:
For corporate partners, your distributive share of the partnership's interest expense has been reported on Line 13(H) of your Schedule K-1. A corporate partner's distributive share of interest income, interest expense and partnership liabilities are treated as income, expense and liabilities of the corporation for purposes of the limitation on the deduction for interest under IRC §163(j). The interest expense limitation rules for corporations are complex. Please consult your tax advisor.
Line 20(V) - Unrelated business taxable income detail:
Ordinary Income (Loss) Considered Unrelated Business Taxable Income - Short-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income - Long-Term Capital Gain (Loss) Considered Unrelated Business Taxable Income -
Total Unrelated Business Taxable Income -
Line 20(W) - Precontribution gain (loss) detail:
Short-Term Capital Gain (Loss) Attributable to Precontribution Gain (Loss) 10,000 Long-Term Capital Gain (Loss) Attributable to Precontribution Gain (Loss) (5,000)
Total Precontribution Gain (Loss) 5,000
The amounts reflected on Line 20(W) have been included on Lines 8 and 9a of your K-1.
Partner # 1 Domestic Hedge Fund Investor in Securities 12-3450000 Schedule K-1 Supporting Schedules - Statement #4
Line 20(X) - Section 108(i) information:
Domestic Hedge Fund Investor in Securities invested indirectly in Investment, LLC which has made an election to defer recognizing discharge of indebtedness income under IRC Section 108(i). The information below has been provided by Investment, LLC and is required to be provided to each partner pursuant to Revenue Procedure 2009-37. Please consult your tax advisor.
Section 108(i) income deferral 100 Section 108(i) OID deferral None Decrease in share of section 752 liabilities None Deferred amount of section 752 liabilities remaining at year end None
Section 108(i) election information statement for partners
The partner's COD income amount: 100 The partner's deferred amount: 100 The partner's included amount: None The partner's deferred amount that the partner must include in income in the current taxable year under Section 108(i)(5)(D)(i) or (ii): None
The partner's share of the partnership's OID deduction deferred under Section 108(i)(2)(A)(i) in the current taxable year: None
The partner's share of the partnership's OID deduction deferred under Section 108(i)(2)(A)(i) that is allowable as a deduction in the current taxable year under Section 108 (i)(5)(D)(i) or (ii): None
The partner's share of each liability of the partnership described in Section 4.05(2)(g) of the Revenue Procedure: None
The partner's share of the decrease in the partnership liability that results from the reacquisition of the applicable debt instrument: None
The partner's share of the decrease in the partnership liability that results from the reacquisition of the applicable debt instrument that is treated as a distribution of money to the partner under Section 752 in the current taxable year: None
The partner's deferred Section 752 amount as described in Section 2.09 of the Revenue Procedure: None
The partner's additional deferred amount as described in Section 4.06 of the Revenue Procedure: None
The date of the reacquisition transaction generating the COD income. 4/30/2014
Partner # 1 Domestic Hedge Fund Investor in Securities 12-3450000 Schedule K-1 Supporting Schedules - Statement #5
Line 20(Y) - Net investment income detail:
Pursuant to Internal Revenue Code Section 1411, all of the distributive share items reported on this Schedule K-1 are subject to the net investment income tax. The rules related to net investment income tax are complex. Please consult your tax advisor.
Line 20(Z) - Other information detail:
Foreign Qualifying Dividend Income Reflected on Line 16D 40,000
Reportable Transaction Information:
Protective Form 8886 - Reportable Transaction Disclosure Statement
The partnership has completed and will attach Forms 8886 to its tax return for the tax year ended December 31, 2014. Attached are completed Forms 8886 for your use. Please consult your tax advisor regarding your Form 8886 federal and state reporting obligations.
Partner # 1 OMB No. 1545-1800 Form 8886 Reportable Transaction Disclosure Statement (Rev. March 2011) ▲ Attach to your tax return. Attachment Department of the Treasury ▲ Sequence No. 137 Internal Revenue Service See separate instructions. Name(s) shown on return (individuals enter last name, first name, middle initial) Identifying number
Number, street, and room or suite no. City or town State ZIP code
A If you are filing more than one Form 8886 with your tax return, sequentially number ▲ each Form 8886 and enter the statement number for this Form 8886 ...... Statement number of ▲ B Enter the form number of the tax return to which this form is attached or related ...... Enter the year of the tax return identified above ...... ▲ ▲ Is this Form 8886 being filed with an amended tax return? ...... Yes No C Check the box(es) that apply (see instructions). Initial year filer Protective disclosure 1 a Name of reportable transaction
1 b Initial year participated in transaction 1 c Reportable transaction or tax shelter registration number (see instructions)
2 Identify the type of reportable transaction. Check all boxes that apply (see instructions). a Listed c Contractual protection e Transaction of interest b Confidential d Loss
3 If you checked box 2a or 2e, enter the published guidance number for the listed transaction or transaction of interest ...... ▲ ▲ 4 Enter the number of “same as or substantially similar” transactions reported on this form ...... 5 If you participated in this reportable transaction through a partnership, S corporation, trust, and foreign entity, check the applicable boxes and provide the information below for the entity(s) (see instructions). (Attach additional sheets, if necessary.) ▲ a Type of entity ...... Partnership Trust Partnership Trust S corporation Foreign S corporation Foreign ▲ b Name ...... ▲ c Employer identification number (EIN), if known . . . .
d Date Schedule K-1 received from entity ▲ (enter “none” if Schedule K-1 not received) ......
6 Enter below the name and address of each individual or entity to whom you paid a fee with regard to the transaction if that individual or entity promoted, solicited, or recommended your participation in the transaction, or provided tax advice related to the transaction. (Attach additional sheets, if necessary.) a Name Identifying number (if known) Fees paid $ Number, street, and room or suite no. City or town State ZIP code
b Name Identifying number (if known) Fees paid $ Number, street, and room or suite no. City or town State ZIP code
For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 34654G Form 8886 (Rev. 3-2011) Form 8886 (Rev. 3-2011) Page 2 7 Facts a Identify the type of tax benefit generated by the transaction. Check all the boxes that apply (see instructions). Deductions Exclusions from gross income Absence of adjustments to basis Tax Credits Capital loss Nonrecognition of gain Deferral Ordinary loss Adjustments to basis Other b Further describe the amount and nature of the expected tax treatment and expected tax benefits generated by the transaction for all affected years. Include facts of each step of the transaction that relate to the expected tax benefits including the amount and nature of your investment. Include in your description your participation in the transaction and all related transactions regardless of the year in which they were entered into. Also, include a description of any tax result protection with respect to the transaction.
8 Identify all individuals and entities involved in the transaction that are tax-exempt, foreign, or related. Check the appropriate box(es) (see instructions). Include their name(s), identifying number(s), address(es), and a brief description of their involvement. For each foreign entity, identify its country of incorporation or existence. For each individual or related entity, explain how the individual or entity is related. Attach additional sheets, if necessary. a Type of individual or entity: Tax-exempt Foreign Related Name Identifying number
Address
Description
b Type of individual or entity: Tax-exempt Foreign Related Name Identifying number
Address
Description
Form 8886 (Rev. 3-2011) Massachusetts Individual 123-45-0001 Form 8886 Supporting Schedules - Statement #1
Part 7b - Transactions as reported by Domestic Hedge Fund Investor in Securities
Massachusetts Individual ("Taxpayer") is a partner in Domestic Hedge Fund Investor in Securities (the "Fund"). The Fund has IRC Section 165 reportable losses that were larger than $2 million due to sales of investments. The Fund did not have qualifying basis in regards to these investments because the bases of the securities were not solely determined by the cash paid. The Fund has an IRC Section 754 election in effect. The bases of securities have been adjusted as a result of the 754 election pursuant to IRC Sections 734 and/or 743. Additionally, in certain cases the amount of realized loss may have been adjusted due to wash sales under IRC Section 1091, constructive sales under IRC Section 1259 and straddles under IRC Section 1092. The realized losses on IRC Section 165 reportable transactions are in connection with the Fund's regular business activity and therefore are not intended as part of any plan to achieve tax benefits. All losses were recognized for book purposes (economic purposes) either prior to or at the same time that the losses were recognized for tax purposes. The Taxpayer’s IRC Section 165 losses referred to above have been netted with all capital gains and losses on the 2014 Schedule K-1 received from the Fund. It is not expected that these IRC Section 165 loss transactions will generate any prior or future benefits. The Taxpayer's share of the reportable losses from the Fund are in excess of $2,000,000, and as such the Taxpayer is reporting these transactions on Form 8886.
Disposition Sale Description Date Quantity Cost Basis Proceeds Tax Loss Microsoft Corporation 7/7/2014 50,000 5,000,000 950,000 (4,050,000) Berkshire Hathaway Inc. 7/8/2014 150 3,000,000 500,000 (2,500,000) Google Inc. 7/8/2014 50,000 5,000,000 - (5,000,000)
Partner # 1 Reportable Transaction Disclosure Statement OMB No. 1545-1800 Form 8886 (Rev. March 2011) F Attach to your tax return. Attachment Department of the Treasury F Sequence No. 137 Internal Revenue Service See separate instructions. Name(s) shown on return (individuals enter last name, first name, middle initial) Identifying number Domestic Hedge Fund Investor in Securities 12-3450000 Number, street, and room or suite no. City or town State ZIP code 2013 Main Street Boston MA 02110 A If you are filing more than one Form 8886 with your tax return, sequentially number F each Form 8886 and enter the statement number for this Form 8886 ...... Statement number 2 of 2 F B Enter the form number of the tax return to which this form is attached or related ...... 1040 F Enter the year of the tax return identified above ...... 2013 F Is this Form 8886 being filed with an amended tax return? ...... Yes ✔ No C Check the box(es) that apply (see instructions). Initial year filer Protective disclosure 1a Name of reportable transaction Section 988 Reportable Loss Transaction 1b Initial year participated in transaction 1c Reportable transaction or tax shelter registration number (see instructions) 2009 2 Identify the type of reportable transaction. Check all boxes that apply (see instructions). a Listed c Contractual protection e Transaction of interest b Confidential d ✔ Loss
3 If you checked box 2a or 2e, enter the published guidance number for the listed transaction or transaction of interest ...... F F 4 Enter the number of “same as or substantially similar” transactions reported on this form ...... 2 5 If you participated in this reportable transaction through a partnership, S corporation, trust, and foreign entity, check the applicable boxes and provide the information below for the entity(s) (see instructions). (Attach additional sheets, if necessary.) F a Type of entity ...... ✔ Partnership Trust Partnership Trust S corporation Foreign S corporation Foreign F b Name ...... Domestic Hedge Fund Investor in Se F c Employer identification number (EIN), if known . . . . 12-3450000 d Date Schedule K-1 received from entity F (enter “none” if Schedule K-1 not received) ...... 2/24/2015
6 Enter below the name and address of each individual or entity to whom you paid a fee with regard to the transaction if that individual or entity promoted, solicited, or recommended your participation in the transaction, or provided tax advice related to the transaction. (Attach additional sheets, if necessary.) a Name Identifying number (if known) Fees paid $ Number, street, and room or suite no. City or town State ZIP code
b Name Identifying number (if known) Fees paid $ Number, street, and room or suite no. City or town State ZIP code
For Paperwork Reduction Act Notice, see separate instructions. Cat. No. 34654G Form 8886 (Rev. 3-2011) Form 8886 (Rev. 3-2011) Page 2 7 Facts a Identify the type of tax benefit generated by the transaction. Check all the boxes that apply (see instructions). Deductions Exclusions from gross income Absence of adjustments to basis Tax Credits Capital loss Nonrecognition of gain Deferral ✔ Ordinary loss Adjustments to basis Other b Further describe the amount and nature of the expected tax treatment and expected tax benefits generated by the transaction for all affected years. Include facts of each step of the transaction that relate to the expected tax benefits including the amount and nature of your investment. Include in your description your participation in the transaction and all related transactions regardless of the year in which they were entered into. Also, include a description of any tax result protection with respect to the transaction. See Attached Statement
8 Identify all individuals and entities involved in the transaction that are tax-exempt, foreign, or related. Check the appropriate box(es) (see instructions). Include their name(s), identifying number(s), address(es), and a brief description of their involvement. For each foreign entity, identify its country of incorporation or existence. For each individual or related entity, explain how the individual or entity is related. Attach additional sheets, if necessary. a Type of individual or entity: Tax-exempt Foreign Related Name Identifying number
Address
Description
b Type of individual or entity: Tax-exempt Foreign Related Name Identifying number
Address
Description
Form 8886 (Rev. 3-2011) Massachusetts Individual 123-45-0001 Form 8886 Supporting Schedules - Statement #2
Part 7b - Transactions as reported by Domestic Hedge Fund Investor in Securities
Massachusetts Individual ("Taxpayer") is a partner in Domestic Hedge Fund Investor in Securities (the "Fund"). The Fund has IRC Section 988 reportable losses that were larger than $2 million due to sales of investments in securities denominated in foreign currency. The realized losses on IRC Section 988 reportable transactions are in connection with the Fund's regular business activity and therefore are not intended as part of any plan to achieve tax benefits. All losses were recognized for book purposes (economic purposes) either prior to or at the same time that the losses were recognized for tax purposes. The Taxpayer's IRC Section 988 losses referred to above have been included as ordinary losses on the 2014 Schedule K-1 received from the Fund. Additionally, in certain cases the amount of realized loss may have been adjusted due to wash sales under IRC Section 1091, constructive sales under IRC Section 1259 and straddles under IRC Section 1092. It is not expected that these IRC Section 988 loss transactions will generate any prior or future benefits. The Taxpayer's share of the reportable losses from the Fund are in excess of $50,000, and as such the Taxpayer is reporting these transactions on Form 8886.
Disposition Sale Description Date Cost Basis Proceeds Tax Loss Japanese Yen Forward Currency Contract 7/7/2014 80,000 20,000 (60,000) Chinese Renminbi Forward Currency Contract 7/8/2014 120,000 50,000 (70,000)
Partner # 1
Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 Part III Partner's Share of Current Year Income, (Form 1065) 2014 Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning January 1, 2014 2 Net rental real estate income (loss) ending December 31, 2014
Partner's Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. See back of form and separate instructions. A Various Part I Information About the Partnership 4 Guaranteed payments A Partnership's employer identification number B 3,509,459 98-1111111 5 Interest income
B Partnership's name, address, city, state, and ZIP code C 1,946,321 NEW YORK 475 FUND 6a Ordinary dividends AVENUE OF AMERICAS, D 1,342,032 3RD FLOOR 6b Qualified dividends NEW YORK NY 10000, G 51,116 7 Royalties
C IRS Center where partnership filed return I 61,412 Ogden, UT 8 Net short-term capital gain (loss)
D Check if this is a publicly traded partnership (PTP) L 13,378 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items
Part II Information About the Partner Collectibles (28%) gain (loss) E Partner's identifying number 9b FOREIGN 9c Unrecaptured section 1250 gain F Partner's name, address, city, state, and ZIP code Partner #44 CUSTODIAN LIMITED FUND 10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses TEE TEE NETHERLANDS ANTILLES 11 Other income (loss) AMSTERDAM, NETHERLANDS F* 415,737
X G General partner or LLC Limited partner or other LLC member-manager member X 19 Distributions H Domestic partner Foreign partner 12 Section 179 deduction I1 What type of entity is this partner? NOMINEE - IRA A
I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc), check here X J Partner's share of profit, loss, and capital (see instructions): 13 Other deductions 20 Other information Beginning Ending H* 51,116 Profit 15.63% 6.12% Loss 15.63% 6.12% V* 13,916 Capital 15.63% 6.12% Y* STMT 14 Self-employment earnings (loss) K Partner's share of liabilities at year end:
Nonrecourse ...... $ 8,557,404
Qualified nonrecourse financing . $ Recourse ...... $ *See attached statement for additional information.
L Partner's capital account analysis: Beginning capital account . . . $ 19,516,254
Capital contributed during the year $
Current year increase (decrease) . $ 366,714 Withdrawals & distributions . . $ ()
Ending capital account . . . . $ 19,882,968
Tax basis X GAAP Section 704(b) book For IRS Use Only Other (explain)
M Did the partner contribute property with a built-in gain or loss?
Yes X No
If "Yes", attach statement (see instructions) For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.GOV/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 3/17/15 2:38 PM Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social See the Partner’s Instructions Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a C Gross income sourced at 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) See the Partner's 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) Instructions A Post-1986 depreciation adjustment E Capital gain property to a 50% B Adjusted gain or loss See the Partner’s organization (30%) C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer's Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit (section L Dispositions of property with 42(j)(5)) from pre-2008 buildings section 179 deductions B Low-income housing credit (other) M Recapture of section 179 deduction from pre-2008 buildings N Interest expense for corporate C Low-income housing credit (section partners 42(j)(5)) from post-2007 buildings See the Partner’s Instructions O Section 453(l)(3) information D Low-income housing credit (other) P Section 453A(c) information from post-2007 buildings Q Section 1260(b) information E Qualified rehabilitation R Interest allocable to production See the Partner’s expenditures (rental real estate) expenditures Instructions F Other rental real estate credits S CCF nonqualified withdrawals G Other rental credits T Depletion information—oil and gas H Undistributed capital gains credit Form 1040, line 73; check box a U Reserved I Biofuel producer credit V Unrelated business taxable income J Work opportunity credit See the Partner’s Instructions W Precontribution gain (loss) K Disabled access credit X Section 108(i) information Y Net investment income Z Other information FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: FOREIGN Partner #: 44 Partnership's ID #: 98-1111111 CUSTODIAN LIMITED NEW YORK 475 FUND
Part II, Item L, Current Year Increase (Decrease):
Income (Loss) From Sch. K-1, Boxes 1 - 11 415,737 Less: Deductions From Sch. K-1, Box 12, 13, 16L & 16M 64,494 Total Income (Loss) Per Schedule K-1 351,243
Book-Tax Differences 15,471 Guaranteed Payments - Transfer/Assignment of Partnership Interest - Transfer/Assignment of Partnership Interest -
Current Year Increase (Decrease) 366,714
Part III, Box 11 Other Income (Loss), Code F -- Other Income (Loss) from Trading Activities:
Ordinary Income: Securities Trader MTM Election per IRC Sec. 475(f) (1,026,776) Nonqualified Dividends 91,369 Qualified Dividends 20,955 Other Interest Income 1,244,110 Trade or Business Interest Expense - Other Trade or Business Expenses (427,412) Other Ordinary Income 513,491 Total Ordinary Income (Loss) 415,737
Part III, Box 13 Other Deductions, Code H -- Investment Interest Expense:
Investment Interest Expense related to Trading Activities 51,116 Total Investment Interest Expense 51,116 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: FOREIGN Partner #: 44 Partnership's ID #: 98-1111111 CUSTODIAN LIMITED NEW YORK 475 FUND Please note that, except for the amounts reported, if any, on Boxes 1, 2, 3, 7, 10, 12 & 13J, none of the distributive share items reported on Schedule K-1 are considered as derived from a passive activity under treasury regulation section 1.469-1t(e)(6).
The K-1 has been prepared on the basis of a partner who does not materially participate in the operations of the partnership. Therefore, interest expense has been included in Box 13, Code H as investment interest expense and is not included in Box 11, code F. 1040 filers should enter this amount on form 4952, Line 1. Any deductible interest expense should then be entered on Schedule E, Part II, Column (H).
Net capital gains/losses in Boxes 8 and 9A and investment income/expense items in Box 11, Code C and Box 11, Code F, if any, have not been included in Box 20, Code A and Box 20, Code B. These amounts should be considered when preparing Form 4952. Please consult your tax advisor.
Gain or Loss on Liquidation of Partnership Interest: If you made a complete withdrawal from the Partnership, you may have a gain or loss on disposition. Please consult your tax advisor.
Part III, Box 16 Foreign Transactions, Code D -- Foreign Gross Income: Foreign qualified dividends are included in Box 16, Code D (as well as in Boxes 6A and 6B and in Box 11, Code F, if applicable). Please consult your tax advisor regarding whether adjustments should be made to this amount or any other amounts appearing in Box 16 for purposes of calculating your foreign tax credits on Form 1116.
Your allocable share of foreign qualified dividends: 20,955
Part III, Box 19 Cash Distributions, Code A: If you were fully redeemed from the fund, the “Final K-1” check box will be marked and your ending capital balance in Part II, Box L will be zero. The “withdrawals and distributions” amount in Part II, Box L may not equal the actual cash or marketable securities you received on liquidation of your interest. The fund may have held back funds for distribution in the subsequent year. Please consult with your tax advisor to determine the appropriate reporting of your liquidating distributions.
Part III, Box 20 Other Information, Code V -- Unrelated Business Taxable Income: If you are a tax-exempt entity, your share of Unrelated Business Taxable Income (Loss) is reported below: Ordinary Income: 13,916 Qualified Dividend Income included in Ordinary Income above 830 Short-Term Capital Gain/(Loss) - Long-Term Capital Gain/(Loss) - Section 1231 Gain/(Loss) - Section 1256 Gain/(Loss) - Total Unrelated Business Taxable Income 13,916
For Foreign Partners: Your allocable share of Effectively Connected Income: - Your allocable share of US Source Dividends: - Your allocable share of US Source Interest: 14,402 Please consult your tax advisor. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: FOREIGN Partner #: 44 Partnership's ID #: 98-1111111 CUSTODIAN LIMITED NEW YORK 475 FUND
Part III, Box 20 Other Information, Code Y -- Net Investment Income: Unless otherwise noted, all income/(loss) items included on your Schedule K-1 are considered Net Investment Income under IRC section 1411. All income/(loss) described as "from Trading Activities" are derived from a trader trading in financial instruments or commodities for purposes of Net Investment Income pursuant to IRC section 1411. Please consult your tax advisor.
Guaranteed payment in Box 4 is not considered Net Investment Income.
The foreign taxes paid/accrued, if any, reported to you on Box 16, Codes L and M can only be used as an allocable expense against Net Investment Income to the extent they are taken as a deduction for regular tax purposes under Chapter 1 of the Internal Revenue Code. No foreign tax credit is allowed to be used as a credit against the Net Investment Income tax. Please consult your tax advisor.
Foreign Partnership Reporting:
New york 475 Fund is an open-ended investment fund incorporated in the Cayman Islands as an exempted company limited by shares, which has elected to be treated as a partnership for U.S. Income Tax purposes. US persons are required to file information returns with respect to their interest in foreign partnerships (Form 8865) under IRC section 6038 B, if certain thresholds are met. Please consult your tax advisor with regard to Form 8865 filing requirements.
The following information is provided to assist with your Form 8865 filing requirement (if applicable).
F1: New York 475 Fund, Avenue of Americas, New York, NY 10000 F2: 98-1111111 F3: Cayman Islands F4: 11/01/2009 F5: Cayman Islands F6: 523900 F7: Trader Securities F8A: U.S. Dollar F8B: N/A G1: N/A G2: 1065; Ogden, UT G3: N/A G4: Kaufman Rossin Fund Services - 2699 Bayshore Drive, 9th Floor, Miami, FL 33133 G5: No G6: None G7: Exempted Company Limited By Shares G8: No G9: No Sch A: Owns a direct interest A-1: N/A A-2: N/A
Information for Schedule O: Date of Transfer: Various Fair Market Value: - Post-Transfer Percentage: 6.12%
Final K-1 Amended K-1 OMB No. 1545-0099 Schedule K-1 Part III Partner's Share of Current Year Income, (Form 1065) 2013 Deductions, Credits, and Other Items Department of the Treasury For calendar year 2013, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning January 1, 2013 (2,884) * STMT 2 Net rental real estate income (loss) ending December 31, 2013 (341) Partner's Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. See back of form and separate instructions. * STMT Part I Information About the Partnership 4 Guaranteed payments A Partnership's employer identification number 90-1111111 5 Interest Income
B Partnership's name, address, city, state, and ZIP code * 45,696 FUND OF FUND, LLC 6a Ordinary dividends C/O 17,817 1 6/*5&%/"5*0/41-";" 6b Qualified dividends /&8:03,, /: 10,051 7 Royalties
C IRS Center where partnership filed return 343 Ogden, UT 8 Net short-term capital gain (loss)
D Check if this is a publicly traded partnership (PTP) * 58,409 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items
Part II Information About the Partner * 264,211 * STMT Collectibles (28%) gain (loss) E Partner's identifying number 9b 99999-00 (1,741) 9c Unrecaptured section 1250 gain F Partner's name, address, city, state, and ZIP code Partner #98 THE 0#"."$)"3*5"#-&5364T 58 11&//4:-7"/*""7&/6& 10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses 8"4)*/(50/, DC 20500 (7,544) 11 Other income (loss) A 735 * STMT
C 699 X G General partner or LLC Limited partner or other LLC member-manager member X 19 Distributions H Domestic partner Foreign partner 12 Section 179 deduction I1 What type of entity is this partner? DISREGARDED ENTITY A
I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc), check here J Partner's share of profit, loss, and capital (see instructions): 13 Other deductions 20 Other information Beginning Ending * STMT Profit 2.59% 1.95% Loss 2.59% 1.95% A 63,856 Capital 2.59% 1.95% B 129,343 14 Self-employment earnings (loss) K Partner's share of liabilities at year end:
Nonrecourse ...... $ 1,184,700 V* 61,867 Qualified nonrecourse financing . $ 786 Recourse ...... $ Y* STMT *See attached statement for additional information.
L Partner's capital account analysis: Beginning capital account . . . $ 4,773,884
Capital contributed during the year $
Current year increase (decrease) . $ 637,206 Withdrawals & distributions . . $ ()
Ending capital account . . . . $ 5,411,090
Tax basis X GAAP Section 704(b) book For IRS Use Only Other (explain)
M Did the partner contribute property with a built-in gain or loss?
Yes X No
If "Yes", attach statement (see instructions) For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.GOV/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2013 8/27/14 2:44 PM Schedule K-1 (Form 1065) 2013 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social See the Partner’s Instructions Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a C Gross income sourced at 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) See the Partner's 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) Instructions A Post-1986 depreciation adjustment E Capital gain property to a 50% B Adjusted gain or loss See the Partner’s organization (30%) C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer's Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit (section L Dispositions of property with 42(j)(5)) from pre-2008 buildings section 179 deductions B Low-income housing credit (other) M Recapture of section 179 deduction from pre-2008 buildings N Interest expense for corporate C Low-income housing credit (section partners 42(j)(5)) from post-2007 buildings See the Partner’s Instructions O Section 453(l)(3) information D Low-income housing credit (other) P Section 453A(c) information from post-2007 buildings Q Section 1260(b) information E Qualified rehabilitation R Interest allocable to production See the Partner’s expenditures (rental real estate) expenditures Instructions F Other rental real estate credits S CCF nonqualified withdrawals G Other rental credits T Depletion information—oil and gas H Undistributed capital gains credit Form 1040, line 71; check box a U Amortization of reforestation costs I Biofuel producer credit V Unrelated business taxable income J Work opportunity credit See the Partner’s Instructions W Precontribution gain (loss) K Disabled access credit X Section 108(i) information Y Net investment income Z Other information FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST FUND OF FUND, LLC
Part II, Item L, Current Year Increase (Decrease):
Income (Loss) From Sch. K-1, Boxes 1 - 11 529,296 Less: Deductions From Sch. K-1, Box 12, 13, 16L & 16M 189,392 Total Income (Loss) Per Schedule K-1 339,904
Unrealized Gain/(Loss) and Other Differences 297,549 Tax-Exempt Interest 735 Nondeductible Expenses (699) Guaranteed Payments - US Withholding Tax (283) Transfer/Assignment of Partnership Interest - Transfer/Assignment of Partnership Interest -
Current Year Increase (Decrease) 637,206
Part III, Box 5 Interest Income:
U.S. Government Interest Income 191 Other Interest Income 45,505 Total Interest Income 45,696
Part III, Box 8 Net Short-Term Capital Gain (Loss):
Net Short-Term Capital Gain / (Loss) from Trading Activities 43,715 Net Short-Term Capital Gain / (Loss) from Investment Activities 14,694 Total Short-Term Capital Gain / (Loss) 58,409
Part III, Box 9A Net Long-Term Capital Gain (Loss):
Net Long-Term Capital Gain / (Loss) from Trading Activities 158,530 Net Long-Term Capital Gain / (Loss) from Investment Activities 105,681 Total Long-Term Capital Gain / (Loss) 264,211
Part III, Box 11 Other Income (Loss), Code A -- Other Portfolio Income (Loss):
Section 988 Income / (Loss) (21,915) Other Portfolio Income 7,811 Total Other Portfolio Income (14,104)
Part III, Box 11 Other Income (Loss), Code C -- Section 1256 Contracts and Straddles:
Net 1256 Gain / (Loss) from Trading Activities 4,782 Net 1256 Gain / (Loss) from Investment Activities (1,778) Total Section 1256 Contracts 3,004
Part III, Box 11 Other Income (Loss), Code E -- Cancellation of debt:
Cancellation of debt 10,942 Total Cancellation of debt: 10,942 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST FUND OF FUND, LLC
Part III, Box 11 Other Income (Loss), Code F -- Other Income (Loss) from Trading Activities:
Ordinary Income: Securities Trader MTM Election per IRC Sec. 475(f) 95,066 Nonqualified Dividends 10,025 Qualified Dividends 14,441 US Governmental Interest Income 5,214 Other Interest Income 91,688 IRS Sec. 988 Income / (Loss) 4,039 Other Trade or Business Expenses (78,680) Other Ordinary Income/(Loss) 11,954 Total Ordinary Income (Loss) 153,747
Part III, Box 13 Other Deductions, Code A -- Cash contributions (50%):
Cash contributions (50%) 2 Total Cash contributions (50%) 2
Part III, Box 13 Other Deductions, Code H -- Investment Interest Expense:
Investment Interest Expense related to Investing Activities 10,175 Investment Interest Expense related to Trading Activities 46,622 Total Investment Interest Expense 56,797
Part III, Box 13 Other Deductions, Code J -- Section 59(e)(2) expenditures:
Section 59(e)(2) expenditures 771 Total Section 59(e)(2) expenditures 771
Part III, Box 13 Other Deductions, Code K -- Portfolio Deductions (2% Floor):
Other Portfolio Deductions 129,336 Total Portfolio Deductions 129,336
Part III, Box 13 Other Deductions, Code L -- Deductions - portfolio (other):
Deductions - portfolio (other): 7 Total Deductions - portfolio (other) 7
Part III, Box 13 Other Deductions, Code W -- Other deductions:
Other deductions 109 Total Other Deductions 109
Part III, Box 15 Credits, Code P -- Other Credits
US Withholding Tax 283 Total Other Credits 283 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST FUND OF FUND, LLC
Part III, Box 16 Foreign Transactions:
Code A - Name of Country or U.S. possession Various Code B - Gross Income From All Sources 721,532 Code C - Gross Income Sourced at Partner Level 536,644 Code D - Passive Category 30,609 Code E - General Category 630 Code F - Other - Code G - Interest Expense 56,654 Code H - Other 81,523 Code I - Passive Category 8,096 Code J - General Category 142 Code K - Other - Code L - Total Foreign Taxes Paid 2,370
Part III, Box 17 Alternative Minimum Tax (AMT) Items:
Code A - Post-1986 Depreciation Adjustment 85 Code B - Adjusted Gain or Loss 342 Code D - Oil, Gas, & Geothermal—Gross Income 1,927 Code E - Oil, Gas, & Geothermal—Deductions 1,482 Code F - Other Amt Items 19 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST .FUND OF FUND, LLC Please note that, except for the amounts reported, if any, on line 1, 2, 3, 7, 10, 11E, 12, 13J, & 13W (below), none of the distributive share items reported on schedule K-1 are considered as derived from a passive activity under treasury regulation section 1.469-1t(e)(6).
The K-1 has been prepared on the basis of a partner who does not materially participate in the operations of the partnership. Therefore, interest expense has been included in Box 13, Code H as investment interest expense and is not included in Box 11, code F. 1040 filers should enter this amount on form 4952, Line 1. Any deductible interest expense should then be entered on Schedule E, Part II, Column (H).
Net capital gains/losses in Boxes 8 and 9A and investment income/expense items in Box 11, Code C and Box 11, Code F, if any, have not been included in Box 20, Code A and Box 20, Code B. These amounts should be considered when preparing Form 4952. Please consult your tax advisor.
Gain or Loss on Liquidation of Partnership Interest: If you made a complete withdrawal from the Partnership, you may have a gain or loss on disposition. Please consult your tax advisor.
Part III, Box 16 Foreign Transactions, Code D -- Foreign Gross Income: Foreign qualified dividends are included in Box 16, Code D (as well as in Boxes 6A and 6B and in Box 11, Code F, if applicable). Please consult your tax advisor regarding whether adjustments should be made to this amount or any other amounts appearing in Box 16 for purposes of calculating your foreign tax credits on Form 1116.
Your allocable share of foreign qualified dividends are: 4,602
Part III, Box 19 Cash Distributions, Code A: If you were fully redeemed from the fund, the “Final K-1” check box will be marked and your ending capital balance in Part II, Box L will be zero. The “withdrawals and distributions” amount in Part II, Box L may not equal the actual cash or marketable securities you received on liquidation of your interest. The fund may have held back funds for distribution in the subsequent year. Please consult with your tax advisor to determine the appropriate reporting of your liquidating distributions.
Part III, Box 20 Other Information, Code V -- Unrelated Business Taxable Income: If you are a tax-exempt entity, your share of Unrelated Business Taxable Income (Loss) is reported below: Ordinary Income: 25,077 Qualified Dividend Income included in Ordinary Income above 1,606 Short-Term Capital Gain/(Loss) 6,520 Long-Term Capital Gain/(Loss) 28,736 Section 1231 Gain/(Loss) 349 Section 1256 Gain/(Loss) 3,916 Total Unrelated Business Taxable Income 64,598
Part III, Box 20 Other Information, Code Y -- Net Investment Income: All income/loss described as "from Trading Activities" are derived from a trader trading in financial instruments or commodities for purposes of Net Investment Income pursuant to IRC section 1411. Please consult your tax advisor.
Dividends Received Deduction Information for Corporate Partners Corporate partners may take the following dividends reported on Schedule K-1 as qualifying for the dividends received deduction under IRC section 243: 18,421
U.S. Source Dividends: The amount of dividends from US sources included in Boxes 6a & 11, code F (if any) is: 31,229 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST .FUND OF FUND, LLC
Other Partner Footnotes:
The following amount included on Box 11, Code F, represents expenses related to U.S. Government Obligations: -
The following amount included on Box 13, Code H, represents interest expense related to U.S. Government Obligations: 3,576
The following amount included on Box 16, Code L, represents Foreign Taxes not eligible for credit: 51
As a trade or business activity, the MTM loan origination income reported on Line 11F may be considered passive for those partners that do not materially participate in the activity. There are specific rules which deal with passive income or loss from an equity-financed lending activity ("EFLA"), which this is deemed to be under Treas. Reg. 1.469-2T(F)(4). As described in the regulations, a taxpayer's income from an EFLA is treated as non-passive to the extent of the lesser of the equity-financed interest income or the net passive income from the activity (including any financing cost incurred at the partner's level) for such tax year. If there is a net loss for the year from the EFLA, the net loss continues to be treated as passive and remains subject to the loss limitations under the passive loss rules. Losses carried forward from prior years can be applied against net income from loan orgination in the current year before application of the EFLA recharacterization rules. The information below is provided only with respect to your share of income from an EFLA from underlying entities for the 2013 tax year. The appropriate treatment may vary depending upon the particular situation of each taxpayer and how the income or loss from this activity was recognized in prior years. All partners should consult their tax advisors with respect to the application of the passive activity and EFLA rules.
Your share of Equity-Financed Interest income is: 3,156 Your share of the Net Passive Income from this activity that is MTM Orgination Loan Income is: 7,254
The partnership also considers itself as engaged in a trade or business as a life settlement provider. Partners that do not materially participate in this activity should consider the income or loss derived from it as subject to the passive activity loss rules. Your share of net income/(loss) from this activity included on line 11F, other income/(loss) is: 909
Your share of the deductions on line 13W related to passive activities is: 9
For Foreign Partners
The following amounts included in your Schedule K-1 represent Effectively Connected Income ("ECI") derived from the active conduct of a US trade or business:
Effectively Connected Income - Ordinary 1,192 Effectively Connected Income - Qualified Dividends included in Ordinary - Effectively Connected Income - 28% Gain - Effectively Connected Income - Long-Term Capital Gain - Effectively Connected Income - Unrecaptured Section 1250 Gain - Effectively Connected Income - Section 1231 Gain 821 2,013
Please consult your tax advisor. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST .FUND OF FUND, LLC
Other Partner Footnotes (continued):
Domestic Production Activities Information:
Domestic Production Gross Receipts (DPGR) 2,746 Non-Domestic Production Gross Receipts 8,259 Gross Receipts From All Sources 11,002 Cost of Goods Sold Allocable to DPGR 948 Cost of Goods Sold From All Sources 1,138 Domestic production expenses directly allocable 2,159 Directly Allocated Other Expenses to Non-DPGR 1 Other Deductions, Expenses & Loss Not Directly Allocable to DPGR 376 Form W-2 Wages 701 Interest Expense 511 QPA Income - Assets Allocable to Non-QPA 5 Assets Allocable to QPA 1,502
Depletion Information:
Cost Depletion 144 Percentage Depletion 62 Tentative Depletion 206 Intangible Drilling Costs 642 Gross Income from Oil & Gas 2,215 Gross Deductions from Oil & Gas 1,446
Passive Income (Loss) Information:
Pursuant to IRC Section 469 the following items have been reclassified from passive to non-passive, following the complete disposition of the underlying pass-through entities. Please subtract out the amounts below from the corresponding line items on Sch K-1, page 1, to arrive at your net passive income (loss) amounts.
Line 1 Ordinary Business Income (Loss) - Line 2 Net Rental Real Estate Income (Loss) - Line 10 Net Section 1231 Gain (Loss) 4 Line 13J Section 59(e)(2) expenditures 2
Your share of gain/(loss) from disposition of the underlying pass-through entities included in line 9a: 28 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 THE OBAMA CHARITABLE TRUST Part.FUND1 OF FUND, LLC
New York State Modification Information:
Additions to income: - Federal Depreciation 52
Subrtractions to income: - New York State Depreciation 45
Passive Foreign Investment Company ("PFIC") Information:
For the tax year ended December 31, 2013, individual taxpayers who are subject to the Net Investment Income ("NII") Tax may elect under Reg. Section 1.1411-10(g) to recognize Qualified Electing Fund ("QEF") income inclusions under IRC Section 1293 (and/or Controlled Foreign Corporation ("CFC") Subpart F income inclusions under IRC Section 951(a)) in the same taxable year as they would be for regular income tax purposes.
This Schedule K-1 has therefore been prepared on the basis that you will make the election for 2013 (using the information below). Please note that in making the election, you must check the box for "Regulation Section 1.1411-10(g) Election" on the Form 8960 filed with your original or amended return.
.Fund of Fund, LLC ("the Fund") is a US partnership that indirectly invested in several passive foreign investment companies ("PFICs") for which the underlying fund(s) elected under IRC section 1295 to treat the following PFICs as Qualified Electing Funds ("QEFs"). All PFIC income below is already included in the Schedule K-1 taxable income. Ordinary Earnings amounts are included in Line 11F and Net Capital Gain amounts are included in Line 9A. The tax rules relating to PFICs/QEFs are complex. Please consult your tax advisor.
THE FOLLOWING INFORMATION IS PROVIDED TO COMPLETE FORM 926.
ANSWER QUESTION 9: SEE BELOW TYPE OF NON-RECOGNITION TRANSFER: IRC SECTION 351 CASH/CAPITAL CONTRIBUTION ANSWER TO QUESTIONS 11-15B: NO ANSWER TO QUESTIONS 16: YES ANSWER TO QUESTIONS 17: NO
YOUR OWNERSHIP PERCENTAGE AFTER TRANSFER WAS LESS THAN 10%. IF YOU REQUIRE ADDITIONAL DETAILS, PLEASE CONTACT THE GENERAL PARTNER.
NAME AND ADDRESS OF TRANSFEREE TAX ID# COUNTRY AMOUNT DATE CFC
.PFIC (BERMUDA) LTD N/A BERMUDA 1,087 VARIOUS YES CHURCH AVENUE W. HAMILTON, HM 12, BERMUDA TAX CLASSIFICATION: CORPORATION
FOREIGN LTD. N/A BERMUDA 193 3/27/2013 NO C/O LTD. THE CORPORATE BUILDING, HAMILTON HM 12, BERMUDA TAX CLASSIFICATION: CORPORATION FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 THE OBAMA CHARITABLE TRUST Pa.FURnership's ID #: 90-1111111
NAME AND ADDRESS OF TRANSFEREE TAX ID# COUNTRY AMOUNT DATE CFC
FOREIGN. .N/A CAYMAN ISLANDS - VARIOUS NO P.O. BOX 000, CAYMANHOUSE GEORGE TOWN, GRAND CAYMAN KY1-1104 TAX CLASSIFICATION: CORPORATION
MASTER FUND LTD. N/A BAHAMAS 5,604 VARIOUS NO C/O ONE BAHAMA ROAD, BOX 1000 NASSAU, BAHAMAS TAX CLASSIFICATION: CORPORATION
MASTER FUND 2 LTD. N/A BAHAMAS 1,317 VARIOUS NO PO BOX 1000 NASSAU, BAHAMAS TAX CLASSIFICATION: CORPORATION
REAL ESTATE FUND N/A NETHERLANDS 8,490 VARIOUS NO D 1 AMSTERDAM AVENUE THE NETHERLANDS TAX CLASSIFICATION: CORPORATION
The transfer amounts shown represent your proportionate share of contributions to foreign corporations. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2013 Partner ID#: XXX-XX-0000 Partner #: 98 Partnership's ID #: 90-1111111 THE OBAMA CHARITABLE TRUST .FUND OF FUND, LLC
State Source Information:
The partnership invests in partnerships that engage in trade or business activities in various states. Below is your proportionate share of state income/(loss) from the following states.
State Income Nonresident Withholding California 1,933 43 Connecticut 6,149 412 Georgia (226) - Illinois 188 8 Michigan 285 19 New Jersey 219 - New York (207) - Pennsylvania (4) - Vermont 22 2
Tax-exempt interest income: Your share of the tax-exempt interest income reported in Box 18, Code A is attributable to various states. If you require this detail, please contact the General Partner. FUND OF FUND, LLC LPARTNER # 98 90-1111111 SCHEDULE K-1 SUPPORTING SCHEDULES THE OBAMA CHARITABLE TRUST
15 CREDITS J* WORK OPPORTUNITY CREDIT 13 M* CREDIT FOR INCREASING RESEARCH ACTIVITIES 9 O* BACKUP WITHHOLDING - P* OTHER CREDITS 283
Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 Part III Partner's Share of Current Year Income, (Form 1065) 2014 Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning January 1, 2014 2 Net rental real estate income (loss) ending December 31, 2014
Partner's Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. See back of form and separate instructions. A Various Part I Information About the Partnership 4 Guaranteed payments A Partnership's employer identification number B 91,316 98-1111111 5 Interest income
B Partnership's name, address, city, state, and ZIP code D 91,316 FOREIGN PRIVATE EQUITY FUND 6a Ordinary dividends C/O USA CAPITAL LLC 91,316 F ONE GRAND CENTRAL PKWY 6b Qualified dividends ROOM 1 91,316 I 351,754 FOREST HILLS, NY 11355 7 Royalties C IRS Center where partnership filed return Ogden, UT 8 Net short-term capital gain (loss)
D Check if this is a publicly traded partnership (PTP) 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items
Part II Information About the Partner Collectibles (28%) gain (loss) E Partner's identifying number 9b XXX-XX-3333 9c Unrecaptured section 1250 gain F Partner's name, address, city, state, and ZIP code Partner #4 GEORGE WASHINGTON RANDALLS ISLAND 10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses NEW YORK, NY 10035 11 Other income (loss) A* (1,373)
X G General partner or LLC Limited partner or other LLC member-manager member X 19 Distributions H Domestic partner Foreign partner 12 Section 179 deduction I1 What type of entity is this partner? INDIVIDUAL
I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc), check here J Partner's share of profit, loss, and capital (see instructions): 13 Other deductions 20 Other information Beginning Ending K* 351,754 Profit 30.55% 30.41% Loss 30.55% 30.41% A 91,316 Capital 30.55% 30.41% B 351,754 14 Self-employment earnings (loss) K Partner's share of liabilities at year end:
Nonrecourse ...... $ 21,073 Y* STMT Qualified nonrecourse financing . $ Recourse ...... $ *See attached statement for additional information.
L Partner's capital account analysis: Beginning capital account . . . $ 9,252,312
Capital contributed during the year $
Current year increase (decrease) . $ 5,549,323 Withdrawals & distributions . . $ ()
Ending capital account . . . . $ 14,801,635
Tax basis GAAP Section 704(b) book For IRS Use Only X Other (explain) IFRS
M Did the partner contribute property with a built-in gain or loss?
Yes X No
If "Yes", attach statement (see instructions) For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.GOV/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 3/18/15 4:46 PM Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social See the Partner’s Instructions Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a C Gross income sourced at 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) See the Partner's 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) Instructions A Post-1986 depreciation adjustment E Capital gain property to a 50% B Adjusted gain or loss See the Partner’s organization (30%) C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer's Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit (section L Dispositions of property with 42(j)(5)) from pre-2008 buildings section 179 deductions B Low-income housing credit (other) M Recapture of section 179 deduction from pre-2008 buildings N Interest expense for corporate C Low-income housing credit (section partners 42(j)(5)) from post-2007 buildings See the Partner’s Instructions O Section 453(l)(3) information D Low-income housing credit (other) P Section 453A(c) information from post-2007 buildings Q Section 1260(b) information E Qualified rehabilitation R Interest allocable to production See the Partner’s expenditures (rental real estate) expenditures Instructions F Other rental real estate credits S CCF nonqualified withdrawals G Other rental credits T Depletion information—oil and gas H Undistributed capital gains credit Form 1040, line 73; check box a U Reserved I Biofuel producer credit V Unrelated business taxable income J Work opportunity credit See the Partner’s Instructions W Precontribution gain (loss) K Disabled access credit X Section 108(i) information Y Net investment income Z Other information FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XXX-XX-3333 Partner #: 4 Partnership's ID #: 98-1111111 GEORGE WASHINGTON FOREIGN PRIVATE EQUITY FUND
Part II, Item L, Current Year Increase (Decrease):
Income (Loss) From Sch. K-1, Boxes 1 - 11 89,943 Less: Deductions From Sch. K-1, Box 12, 13, 16L & 16M 351,754 Total Income (Loss) Per Schedule K-1 (261,811)
Unrealized Gain/(Loss) and Other Differences 5,811,134 Guaranteed Payments -
Current Year Increase (Decrease) 5,549,323
Part III, Box 11 Other Income (Loss), Code A -- Other Portfolio Income (Loss):
Section 988 Income / (Loss) (1,373) Total Other Portfolio Income (1,373)
Part III, Box 13 Other Deductions, Code K -- Portfolio Deductions (2% Floor):
Other Portfolio Deductions 351,754 Total Portfolio Deductions 351,754 FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XXX-XX-3333 Partner #: 4 Partnership's ID #: 98-1111111 GEORGE WASHINGTON .FOREIGN PRIVATE EQUITY FUND Please note that, except for the amounts reported, if any, on Boxes 1, 2, 3, 7, 10, 12 & 13J, none of the distributive share items reported on Schedule K-1 are considered as derived from a passive activity under treasury regulation section 1.469-1t(e)(6).
Net capital gains/losses in Boxes 8 and 9A and investment income/expense items in Box 11, Code C and Box 11, Code F, if any, have not been included in Box 20, Code A and Box 20, Code B. These amounts should be considered when preparing Form 4952. Please consult your tax advisor.
All income/expense items included on your Schedule K-1 are from non-U.S. sources.
Gain or Loss on Liquidation of Partnership Interest: If you made a complete withdrawal from the Partnership, you may have a gain or loss on disposition. Please consult your tax advisor.
Part III, Box 16 Foreign Transactions, Code D -- Foreign Gross Income: Foreign qualified dividends are included in Box 16, Code D (as well as in Boxes 6A and 6B and in Box 11, Code F, if applicable). Please consult your tax advisor regarding whether adjustments should be made to this amount or any other amounts appearing in Box 16 for purposes of calculating your foreign tax credits on Form 1116.
Your allocable share of foreign qualified dividends: 91,316
Part III, Box 19 Cash Distributions, Code A: If you were fully redeemed from the fund, the “Final K-1” check box will be marked and your ending capital balance in Part II, Box L will be zero. The “withdrawals and distributions” amount in Part II, Box L may not equal the actual cash or marketable securities you received on liquidation of your interest. The fund may have held back funds for distribution in the subsequent year. Please consult with your tax advisor to determine the appropriate reporting of your liquidating distributions.
Part III, Box 20 Other Information, Code V -- Unrelated Business Taxable Income: For tax-exempt entities, the Partnership did not generate Unrelated Business Taxable Income for the current tax year.
Part III, Box 20 Other Information, Code Y -- Net Investment Income: Unless otherwise noted, all income/(loss) items included on your Schedule K-1 are considered Net Investment Income under IRC section 1411. None of the income/(loss) reported on Schedule K-1 is derived from a trader trading in financial instruments or commodities for purposes of Net Investment Income pursuant to IRC section 1411. Please consult your tax advisor.
Guaranteed payment in Box 4 is not considered Net Investment Income.
The foreign taxes paid/accrued, if any, reported to you on Box 16, Codes L and M can only be used as an allocable expense against Net Investment Income to the extent they are taken as a deduction for regular tax purposes under Chapter 1 of the Internal Revenue Code. No foreign tax credit is allowed to be used as a credit against the Net Investment Income tax. Please consult your tax advisor. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XXX-XX-3333 Partner #: 4 Partnership's ID #: 98-1111111 GEORGE WASHINGTON .FOREIGN PRIVATE EQUITY FUND
Foreign Partnership Reporting:
The Partnership is a private company limited by shares, formed under the laws of Mauritius, which has elected to be treated as a partnership for US tax purposes. US persons are required to file information returns with respect to their interest in foreign partnerships (Form 8865) under IRC section 6038 B, if certain thresholds are met. Please consult your tax advisor with regard to Form 8865 filing requirements.
The following information is provided to assist with your Form 8865 filing requirement (if applicable). F1: Foriegn Private Equity Fund; One Grand Central Pkwy, Forest Hills, NY 11355 F2: 98-1111111 F3: Mauritius F4: 1/16/2005 F5: Mauritius F6: 523900 F7: Investments F8A: U.S. Dollar F8B: N/A G1: N/A G2: 1065; Ogden, UT G3: N/A G4: Kaufman Rossin Fund Services, 2699 S. Bayshore Drive, Miami, FL 33133 G5: No G6: None G7: Private company limited by shares G8: No G9: No A: Owns a direct interest A-1: N/A A-2: N/A
Other Foreign Reporting and Supporting Forms
The Partnership owned a foreign disregarded entity during the 2014 tax year. Accordingly, you may have a Form 8858 filing requirement if you are a Form 8865 category 1 or 2 filer with respect to your interest in the Partnership. If you determine that you meet this filing requirement, reference the pro forma Forms 8858 that have been included to provide the information required to complete the forms. Please consult your tax advisor regarding the above. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XXX-XX-3333 Partner #: 4 Partnership's ID #: 98-1111111 GEORGE WASHINGTON .FOREIGN PRIVATE EQUITY FUND
The partnership owns several foreign corporations. Each partner is deemed to own a pro-rata share of each foreign corporation. If, after combining your direct and indirect ownership totals of each foreign corporation, you own 10 percent or more of a foreign corporation, you may be required to file form 5471. Below is a list of the foreign corporations and the partnership's ownership percentages. Use your ownership percentage in the partnership to derive your pro-rata share of each foreign corporation. If you determine you are required to file form 5471, please contact the general partner for the necessary information.
Name of the Foreign Corporation Ownership %
Apple Retail Limited 15.90 Google Industries Limited 21.00 Ali Baba Ltd. 39.12 . . .
Final K-1 Amended K-1 OMB No. 1545-0123 Schedule K-1 Part III Partner's Share of Current Year Income, (Form 1065) 2014 Deductions, Credits, and Other Items Department of the Treasury For calendar year 2014, or tax 1 Ordinary business income (loss) 15 Credits Internal Revenue Service year beginning January 1, 2014 P* 2 Net rental real estate income (loss) ending December 31, 2014
Partner's Share of Income, Deductions, 3 Other net rental income (loss) 16 Foreign transactions Credits, etc. See back of form and separate instructions. A Various Part I Information About the Partnership 4 Guaranteed payments A Partnership's employer identification number B 2,172,914 22-1111111 5 Interest income
B Partnership's name, address, city, state, and ZIP code C 2,154,438 TRADER FUND, L.P. 6a Ordinary dividends 5000 AVENUE OF AMERICAS, SUITE 100 D 5,635 NEW YORK, NY 10000 6b Qualified dividends G 12,161 7 Royalties
C IRS Center where partnership filed return I 255 Ogden, UT 8 Net short-term capital gain (loss)
D Check if this is a publicly traded partnership (PTP) * 109,988 L 745 9a Net long-term capital gain (loss) 17 Alternative minimum tax (AMT) items
Part II Information About the Partner * 781,745 Collectibles (28%) gain (loss) E Partner's identifying number 9b XX-XXX1111 9c Unrecaptured section 1250 gain F Partner's name, address, city, state, and ZIP code Partner #1 INVESTOR SAMPLE 10 Net section 1231 gain (loss) 18 Tax-exempt income and nondeductible expenses ONE WORLD WIDE PLAZA SUITE 200 BROOKLYN, NY 11219 11 Other income (loss) F* (92,842)
X G General partner or LLC Limited partner or other LLC member-manager member X 19 Distributions H Domestic partner Foreign partner 12 Section 179 deduction I1 What type of entity is this partner? PARTNERSHIP A
I2 If this partner is a retirement plan (IRA/SEP/Keogh/etc), check here J Partner's share of profit, loss, and capital (see instructions): 13 Other deductions 20 Other information Beginning Ending H* 12,161 Profit 4.93% 3.47% Loss 4.93% 3.47% Y* STMT Capital 4.93% 3.47%
14 Self-employment earnings (loss) K Partner's share of liabilities at year end:
Nonrecourse ...... $
Qualified nonrecourse financing . $ Recourse ...... $ *See attached statement for additional information.
L Partner's capital account analysis: Beginning capital account . . . $ 6,860,122
Capital contributed during the year $
Current year increase (decrease) . $ 1,283,253 Withdrawals & distributions . . $ ()
Ending capital account . . . . $ 8,143,375
Tax basis X GAAP Section 704(b) book For IRS Use Only Other (explain)
M Did the partner contribute property with a built-in gain or loss?
Yes X No
If "Yes", attach statement (see instructions) For Paperwork Reduction Act Notice, see Instructions for Form 1065. IRS.GOV/form1065 Cat. No. 11394R Schedule K-1 (Form 1065) 2014 3/6/15 10:44 AM Schedule K-1 (Form 1065) 2014 Page 2 This list identifies the codes used on Schedule K-1 for all partners and provides summarized reporting information for partners who file Form 1040. For detailed reporting and filing information, see the separate Partner’s Instructions for Schedule K-1 and the instructions for your income tax return.
1. Ordinary business income (loss). Determine whether the income (loss) is Code Report on passive or nonpassive and enter on your return as follows. L Empowerment zone Report on employment credit Passive loss See the Partner’s Instructions M Credit for increasing research Passive income Schedule E, line 28, column (g) activities Nonpassive loss Schedule E, line 28, column (h) N Credit for employer social See the Partner’s Instructions Nonpassive income Schedule E, line 28, column (j) security and Medicare taxes 2. Net rental real estate income (loss) See the Partner’s Instructions O Backup withholding 3. Other net rental income (loss) P Other credits Net income Schedule E, line 28, column (g) 16. Foreign transactions Net loss See the Partner’s Instructions A Name of country or U.S. 4. Guaranteed payments Schedule E, line 28, column (j) possession 5. Interest income Form 1040, line 8a B Gross income from all sources Form 1116, Part I 6a. Ordinary dividends Form 1040, line 9a C Gross income sourced at 6b. Qualified dividends Form 1040, line 9b partner level 7. Royalties Schedule E, line 4 Foreign gross income sourced at partnership level 8. Net short-term capital gain (loss) Schedule D, line 5 D Passive category 9a. Net long-term capital gain (loss) Schedule D, line 12 E General category Form 1116, Part I 9b. Collectibles (28%) gain (loss) 28% Rate Gain Worksheet, line 4 F Other (Schedule D instructions) Deductions allocated and apportioned at partner level 9c. Unrecaptured section 1250 gain See the Partner’s Instructions G Interest expense Form 1116, Part I 10. Net section 1231 gain (loss) See the Partner’s Instructions H Other Form 1116, Part I 11. Other income (loss) Deductions allocated and apportioned at partnership level to foreign source Code income A Other portfolio income (loss) See the Partner’s Instructions I Passive category B Involuntary conversions See the Partner’s Instructions J General category Form 1116, Part I C Sec. 1256 contracts & straddles Form 6781, line 1 K Other D Mining exploration costs recapture See Pub. 535 Other information E Cancellation of debt Form 1040, line 21 or Form 982 L Total foreign taxes paid Form 1116, Part II F Other income (loss) See the Partner’s Instructions M Total foreign taxes accrued Form 1116, Part II 12. Section 179 deduction See the Partner’s Instructions N Reduction in taxes available for credit Form 1116, line 12 13. Other deductions O Foreign trading gross receipts Form 8873 A Cash contributions (50%) P Extraterritorial income exclusion Form 8873 B Cash contributions (30%) Q Other foreign transactions See the Partner’s Instructions C Noncash contributions (50%) See the Partner's 17. Alternative minimum tax (AMT) items D Noncash contributions (30%) Instructions A Post-1986 depreciation adjustment E Capital gain property to a 50% B Adjusted gain or loss See the Partner’s organization (30%) C Depletion (other than oil & gas) Instructions and F Capital gain property (20%) D Oil, gas, & geothermal—gross income the Instructions for G Contributions (100%) E Oil, gas, & geothermal—deductions Form 6251 H Investment interest expense Form 4952, line 1 F Other AMT items I Deductions—royalty income Schedule E, line 19 18. Tax-exempt income and nondeductible expenses J Section 59(e)(2) expenditures See the Partner’s Instructions A Tax-exempt interest income Form 1040, line 8b K Deductions—portfolio (2% floor) Schedule A, line 23 B Other tax-exempt income See the Partner’s Instructions L Deductions—portfolio (other) Schedule A, line 28 C Nondeductible expenses See the Partner’s Instructions M Amounts paid for medical insurance Schedule A, line 1 or Form 1040, line 29 19. Distributions N Educational assistance benefits See the Partner’s Instructions A Cash and marketable securities O Dependent care benefits Form 2441, line 12 B Distribution subject to section 737 See the Partner’s Instructions P Preproductive period expenses See the Partner’s Instructions C Other property Q Commercial revitalization deduction 20. Other information from rental real estate activities See Form 8582 instructions A Investment income Form 4952, line 4a R Pensions and IRAs See the Partner’s Instructions B Investment expenses Form 4952, line 5 S Reforestation expense deduction See the Partner’s Instructions C Fuel tax credit information Form 4136 T Domestic production activities D Qualified rehabilitation expenditures information See Form 8903 instructions (other than rental real estate) See the Partner’s Instructions U Qualified production activities income Form 8903, line 7b E Basis of energy property See the Partner’s Instructions V Employer's Form W-2 wages Form 8903, line 17 F Recapture of low-income housing W Other deductions See the Partner’s Instructions credit (section 42(j)(5)) Form 8611, line 8 14. Self-employment earnings (loss) G Recapture of low-income housing Note. If you have a section 179 deduction or any partner-level deductions, see the credit (other) Form 8611, line 8 Partner’s Instructions before completing Schedule SE. H Recapture of investment credit See Form 4255 A Net earnings (loss) from I Recapture of other credits See the Partner’s Instructions self-employment Schedule SE, Section A or B J Look-back interest—completed B Gross farming or fishing income See the Partner’s Instructions long-term contracts See Form 8697 C Gross non-farm income See the Partner’s Instructions K Look-back interest—income forecast 15. Credits method See Form 8866 A Low-income housing credit (section L Dispositions of property with 42(j)(5)) from pre-2008 buildings section 179 deductions B Low-income housing credit (other) M Recapture of section 179 deduction from pre-2008 buildings N Interest expense for corporate C Low-income housing credit (section partners 42(j)(5)) from post-2007 buildings See the Partner’s Instructions O Section 453(l)(3) information D Low-income housing credit (other) P Section 453A(c) information from post-2007 buildings Q Section 1260(b) information E Qualified rehabilitation R Interest allocable to production See the Partner’s expenditures (rental real estate) expenditures Instructions F Other rental real estate credits S CCF nonqualified withdrawals G Other rental credits T Depletion information—oil and gas H Undistributed capital gains credit Form 1040, line 73; check box a U Reserved I Biofuel producer credit V Unrelated business taxable income J Work opportunity credit See the Partner’s Instructions W Precontribution gain (loss) K Disabled access credit X Section 108(i) information Y Net investment income Z Other information FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XX-XXX1111 Partner #: 1 Partnership's ID #: 22-1111111 INVESTOR TRADER FUND, L.P.
Part II, Item L, Current Year Increase (Decrease):
Income (Loss) From Sch. K-1, Boxes 1 - 11 798,891 Less: Deductions From Sch. K-1, Box 12, 13, 16L & 16M 12,906 Total Income (Loss) Per Schedule K-1 785,985
Unrealized Gain/(Loss) and Other Differences 497,268 Guaranteed Payments - US Withholding Tax - Transfer/Assignment of Partnership Interest - Transfer/Assignment of Partnership Interest -
Current Year Increase (Decrease) 1,283,253
Part III, Box 8 Net Short-Term Capital Gain (Loss):
Net Short-Term Capital Gain / (Loss) from Trading Activities 109,988 Total Short-Term Capital Gain / (Loss) 109,988
Part III, Box 9A Net Long-Term Capital Gain (Loss):
Net Long-Term Capital Gain / (Loss) from Trading Activities 781,745 Total Long-Term Capital Gain / (Loss) 781,745
Part III, Box 11 Other Income (Loss), Code F -- Other Income (Loss) from Trading Activities:
Nonqualified Dividends 9,538 Qualified Dividends 9,709 IRS Sec. 988 Income / (Loss) (1,871) Trade or Business Interest Expense - Other Trade or Business Expenses (110,759) Other Ordinary Income/(Loss) 541 Total Ordinary Income (Loss) (92,842)
Part III, Box 13 Other Deductions, Code H -- Investment Interest Expense:
Investment Interest Expense related to Trading Activities 12,161 Total Investment Interest Expense 12,161
Part III, Box 15 Credits, Code P -- Other Credits
US Withholding Tax - Total Other Credits - FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XX-XXX1111 Partner #: 1 Partnership's ID #: 22-1111111 INVESTOR TRADER FUND, L.P. Please note that, except for the amounts reported, if any, on Boxes 1, 2, 3, 7, 10, 12 & 13J, none of the distributive share items reported on Schedule K-1 are considered as derived from a passive activity under treasury regulation section 1.469-1t(e)(6).
The K-1 has been prepared on the basis of a partner who does not materially participate in the operations of the partnership. Therefore, interest expense has been included in Box 13, Code H as investment interest expense and is not included in Box 11, code F. 1040 filers should enter this amount on form 4952, Line 1. Any deductible interest expense should then be entered on Schedule E, Part II, Column (H).
Net capital gains/losses in Boxes 8 and 9A and investment income/expense items in Box 11, Code C and Box 11, Code F, if any, have not been included in Box 20, Code A and Box 20, Code B. These amounts should be considered when preparing Form 4952. Please consult your tax advisor.
Gain or Loss on Liquidation of Partnership Interest: If you made a complete withdrawal from the Partnership, you may have a gain or loss on disposition. Please consult your tax advisor.
Part III, Box 16 Foreign Transactions, Code D -- Foreign Gross Income: Foreign qualified dividends are included in Box 16, Code D (as well as in Boxes 6A and 6B and in Box 11, Code F, if applicable). Please consult your tax advisor regarding whether adjustments should be made to this amount or any other amounts appearing in Box 16 for purposes of calculating your foreign tax credits on Form 1116.
Your allocable share of foreign qualified dividends: 4,133
Part III, Box 19 Cash Distributions, Code A: If you were fully redeemed from the fund, the “Final K-1” check box will be marked and your ending capital balance in Part II, Box L will be zero. The “withdrawals and distributions” amount in Part II, Box L may not equal the actual cash or marketable securities you received on liquidation of your interest. The fund may have held back funds for distribution in the subsequent year. Please consult with your tax advisor to determine the appropriate reporting of your liquidating distributions.
Part III, Box 20 Other Information, Code V -- Unrelated Business Taxable Income: The partnership did not generate Unrelated Business Taxable Income (UBTI) for the current tax year.
Part III, Box 20 Other Information, Code Y -- Net Investment Income: Unless otherwise noted, all income/(loss) items included on your Schedule K-1 are considered Net Investment Income under IRC section 1411. All income/(loss) items reported on Schedule K-1 is derived from a trader trading in financial instruments or commodities for purposes of Net Investment Income pursuant to IRC section 1411. Please consult your tax advisor.
The foreign taxes paid/accrued, if any, reported to you on Box 16, Codes L and M can only be used as an allocable expense against Net Investment Income to the extent they are taken as a deduction for regular tax purposes under Chapter 1 of the Internal Revenue Code. No foreign tax credit is allowed to be used as a credit against the Net Investment Income tax. Please consult your tax advisor. FORM 1065 - SCHEDULE K-1 SUPPLEMENTAL INFORMATION DETAIL - 2014 Partner ID#: XX-XXX1111 Partner #: 1 Partnership's ID #: 22-1111111 INVESTOR TRADER FUND, L.P.
Dividends Received Deduction Information for Corporate Partners Corporate partners may take the following dividends reported on Schedule K-1 as qualifying for the dividends received deduction under IRC section 243: 7,534
For Foreign Partners: Your allocable share of Effectively Connected Income: - Your allocable share of US Source Dividends: 13,612 Your allocable share of US Source Interest: - Please consult your tax advisor.