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FAQ / What is the percentage interest in the partnership that should be reported on Form 1065 Schedule B question 3a and 3b under the following facts?


Corporation X owns 1 percent of the profit, loss, and capital of partnership A. The remaining 99 percent is owned by trust T. Jane owns 50 percent of the beneficial interest in trust T. Bill, her brother owns the other 50% of trust T.

A10: Report Trust T as owning, directly or indirectly, 99 percent of the partnership in response to question 3a.

Report Jane and Bill as each owning, directly or indirectly, 99 percent of the partnership in response to question 3b. Jane and Bill each own, indirectly through attribution from Trust T, 49.5 percent of Partnership A’s profit, loss, and capital. This is computed by multiplying Trust T’s 99 percent direct ownership in P by the 50 percent in Trust T owned by Jane and owned by Bill. In addition, Jane and Bill, as brother and sister, each own an additional 49.5 percent indirectly by family attribution from the other.

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