I made the following purchases and sales of the publicly traded partnership (PTP) Blackstone (BX). You'll note the sales are of partial interests in the partnership with holding periods of more than a year (i.e. LT gains) for each interest.=====>>>>>>>>>>Correct ; please read below on hilding time of the PTP shares.
However, I don't know how to report the sales in order to meet both the"unified basis" requirement of Rev. Rul. 84-53 and the holding period reporting requirement of Reg. 1.223-3(c)(2)(i). Do I report them each as separate transactions on the Schedule D in order to identify the holding periods as the Reg. suggests? =======>>>>>>>>>> as a unified sale;In this case, the units sold are NOT treated like a block of stock . The IRS considers that you, as a partner of the PTP, have a unified basis in the total partnership interest, and that a partial sale of the total interest represents a partial sale of each portion of the interest acquired in separate transactions up to that point. To determine the adjusted basis of the sold units, the total original basis from all purchases would be pro-rated, per the percentage of the total holding sold, to get the original purchase basis of the sold units. Then, the cumulative adjustments to basis value supplied by the PTP would be used to determine the adjusted basis of the sold units. From that point, the sales proceeds and the ordinary gain as reported by the partnership would be used as described preceding. Since the adjusted basis of the sold units was determined and used to calculate the gain or loss, the remaining basis going forward would begin with the total basis as rigorously calculated, including the year the units were sold, and then would be reduced by the adjusted basis of the sold units. you ‘d receive a K-1 from the publicly traded partnership. A publicly traded partnership is any partnership( a limited partnership the interests in which (known as "units") are traded on public exchanges, just like corporate stock.)an interest in which is regularly traded on an established securities market regardless of the number of its partners. This does not include a publicly traded partnership treated as a corp;
Or do I aggregate them as one sale so they can have a "unified basis" as the Rev. Rul. requires? ===>>>>>>>>> If the total position was partially short-term and partially long-term, you need to determine the percentage applicable to each holding time, and pro-rate all values accordingly. A PTP holding is considered to have one unified basis, and all basis adjustments are applied pro-rata. The costs of the individual blocks of units are disregarded, as far as weighting is concerned Whenever any units of a PTP are sold, the PTP will include a sales schedule with instructions for reporting the sale. The sales proceeds must be determined independently by you, using brokerage statements or confirmations;
I am really struggling to make sense of this. Any help you can offer is much appreciated. The transactions were as follows: ======>>>>>>>>>>>>>>>>>..In general, thePTP is not responsible for keeping the information needed to figure the basis of your partnership interest. Although the PTP does provide an analysis of the changes to your capital account in item L of Sch K-1 of 1065, that information is based on thePTP’s books and records and cannot be used to figure your basis. You can figure the adjusted basis of your partnership interest by adding items that increase your basis and then subtracting items that decrease your basis."