| Field | Value |
|---|---|
| From | [REDACTED] on behalf of [REDACTED] |
| Sent | Tuesday, August 25, 2015 9:51 PM |
| To | [REDACTED EMAIL] |
| Cc | [REDACTED]; [REDACTED]; [REDACTED] |
| Subject | Boat |

Je=frey,

Ju=t to be clear:

1. The boat is owned by a foreign corporation.

3. We intend to change that status to a foreign corpor=tion for US tax purposes.

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

6. If there are issues to discuss, particularly with r=spect to the 2014 taxes and the 14-day issue, lees do it quickly wi=h Rich Joslin, Rick Bronstein and Glenn Stankee (maritime tax).=/p>