The Problem
The client held an interest in a U.S. investment partnership that owned a foreign controlled corporation. The entity and foreign company returns were prepared by separate advisers, and the personal filings had never been reconciled to them. Eight-figure international inclusions had flowed to the individual return across several years, foreign distributions raised questions the personal filings had to answer, and a voluntary disclosure matter was open with outside tax counsel. Beneath all of it, no partner-level basis record existed. The partnership reporting delivered each year does not establish a partner's basis on its own, and without that record a large distribution would be reported as taxable gain against income already taxed once.
What We Did
Our role was the client's personal filings, interpreting the third-party entity reporting and integrating it into the individual returns. We reviewed the historical returns against the partnership and international reporting, coordinated positions with outside tax counsel through the voluntary disclosure process, and prepared multi-year amended returns. When the next cycle brought an eight-figure dividend allocation and a larger distribution, the question was whether the distribution exceeded the client's basis and produced taxable gain, and no record existed to answer it. We reconstructed five years of outside basis from the filed returns, the annual partnership and international reporting packages, distributions, liability allocations, and ownership changes, testing the result against the alternative treatments available.
The Outcome
Historical filings were corrected and aligned with the entity reporting and the voluntary disclosure record. An eight-figure opening outside basis was established, and under the adopted position the distribution did not produce taxable gain. The client holds a permanent file of basis workbooks, technical memoranda, audit defense documentation, and written criteria for when the position should be reopened. Camuso CPA serves as ongoing tax adviser to the client, maintaining the basis record annually, integrating the entity reporting as it arrives each year, and coordinating with the client's other advisers as the structure develops.