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King Washington Form 8594: What You Should Know

The information statement provides information on the value of the exchanged assets, and is included with the other documents filed in the tax return of the purchaser/seller. The information is required when the purchaser or seller sells (or exchanges for) its ownership in the acquired property to a purchaser/seller who did not acquire it from a U.S.-owned limited partnership or S corp. A taxpayer may not acquire an asset through the issuance of a U.S. government note or bond, or through a swap with an entity treated as a U.S.-owned limited partnership or S corp. Section 717(r)(3) of the Foreign Extender Statute applies and the acquirer/issuer of the exchanged asset may be subject to a special reporting requirement with respect to the exchange event. Fiduciary Requirements — S Corp. Washington, D.C. A taxpayer must report the property acquisition on Form 8594 to avoid a special reporting requirement that the acquirer/issuer of a transferred asset will then be required to file a Form 8594 with the Office of the Comptroller of the Currency.  Special Reporting (for a Form 8594 Exchange Event) A taxpayer that acquires an asset that constitutes an Exchange Transaction may be subject to Form 8594 reporting. This is due to a special rule which allows a tax-exempt organization to acquire an exempt asset, or to enter into a transaction with a tax-free entity which the organization does not control. As an exception to this rule, an organization must also include a Form 1069 in the tax return in connection with the acquisition or exchange. (1) Organization or entity acquired property (e.g. trade or business). For purposes of this reportable event section 717(r)(3) the entity is defined as: 1) “A U.S. person” (i.e. an individual, trust, estate, partnership or corporation) 2) “A non-U.S. person” (i.e. corporation, partnership, trust, estate, or similar organization) 3) “A foreign person” (i.e. trust, estate, partnership or entity owned by the decedent's estate or estate of the decedent) — (g)  5 Fiduciary Requirements. A qualified organization must report the acquisition to avoid paying a penalty.

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