Question
Form 926 Question
A domestic partnership contributed $24 million of cash to its wholly owned Canadian corporation in a §351 transaction. The individual partner's K-1 shows a 0.31% ending capital interest, and the partner has no other direct, indirect, or family-related ownership or transfers involving the Canadian corporation. The partnership instructed the partner to determine his pro-rata share for Form 926 purposes. Is it appropriate to use the 0.31% K-1 capital percentage to calculate the partner's pro-rata share ($74,400), resulting in no Form 926 filing requirement because the amount is below $100,000?
