TaxGuyBill
Level 15

I'm not sure of the answer, but wouldn't it just be a suspended expense/loss, just like if the K-1 had a loss that was limited due to Basis? 

I understand your thought about a deemed capital contribution.  I haven't seen anything that allows an option/election to treat UPE as a capital contribution, but maybe I just haven't heard of it.

0 Cheers