We have a partnership that is owned by two partnerships. All entities are domestic and all revenues/expenses are domestic. The way that I'm reading the instructions is that we don't qualify for the domestic filing exception since we don't meet requirement #2, and it is also highly likely that at least one of the partners will not qualify under the 1116 Exemption. Do I just complete Parts II and III with all data in the US Source column and call it a day?
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Yes. My software has a checkbox to do that.
"and it is also highly likely that at least one of the partners will not qualify under the 1116 Exemption."
I'm not sure what you are referring to, but why would the partnership be required to know anything about whether or not a partner files Form 1116?"You said it, they'll never know the difference. Come on, we'll paint our way out!" - Moe Howard
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