<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Tuesday, August 25, 2015 9:55 PM</td></tr><tr><td>To:</td><td>Brad Wechsler</td></tr><tr><td>Subject:</td><td>Re: Boat</td></tr></table>

Be10?

On Tuesday, August 25, 2015, Brad Wechsler

rote:=br>

Je=frey,

Ju=t to be clear:

	1. =AO The boat is owned by a foreign corporation.<=u>

	2. =AO The boat is currently treated as a partnership for US =ax purposes.

	3. =AO We intend to change that status to a foreign corporati=n for US tax purposes.

	4. =A0 This will enable us to deduct our capital loss on sale=

5. =AO As per Rich J, we will file the following election and=disclosure forms: 8832 and 926 (reflecting our conversion for tax purposes=from a partnership to a foreign corporation) and, then, until sale of boat= 926 and 5471 (which is an information return for US persons with respect to certain foreign corporations).

6. =AO If there are issues to discuss, particularly with resp=ct to the 2014 taxes and the 14-day issue, let's do it quickly wit= Rich Joslin, Rick Bronstein and Glenn Stankee (maritime tax).</=>

=C2 please note

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