This is a Canadian partnership return. At a high level, you would report that as partnership income.
You still need to ask more questions as these could trigger additional reporting and filing requirements. Substantial penalties are imposed on failure to comply with these requirements:
- Does the partnership have any US-source gross income or US-ECI?
- Would the type of income and assets held by partnership cause it to be considered a PFIC?
- Is this a controlled foreign partnership and is your client a 10% partner by attribution?
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Still an AllStar
