PTP cost basis

units have been purchased on more than one occasion.

PTP, my question is simply:

adjusted cost basis of the second purchase?

adjustments and the cost basis for the sale is 50/300 of the total adjusted cost basis?

Unless you specify otherwise at sale, the default is FIFO. Using your example of 300 units: Let's say there is a distribution of $600 which is treated as a return of capital. $600 / 300 = $2 per unit reduction in basis. You sell 100 units. You paid $50 unit for those first 100 units, less $2 cost adjustment makes your basis $48 in those 100 units. Gain or loss is computed by deducting $4800 from the proceeds.

On Tuesday, April 23, 2013 6:46:39 PM UTC-4, Alan wrote:

units have been purchased on more than one occasion.

PTP, my question is simply:

adjusted cost basis of the second purchase?

• adjustments and the cost basis for the sale is 50/300 of the total adjusted cost basis?

Do you have a citation for FIFO treatment in this circumstance? The reason I ask is that I ran across the following in the prospectus for the spinoff of Brookfield Property Partners from Brookfield Asset Management:

168): (Emphasis added) Basis. You will have an initial tax basis in your units equal to their fair market value on the date you receive them pursuant to the spin-off, increased by your share of our company?s liabilities, if any. That basis will be increased by your share of our company?s income and by increases in your share of our company?s liabilities, if any. That basis will be decreased, but not below zero, by distributions you receive from our company, by your share of our company?s losses, and by any decrease in your share of our company?s liabilities. ***Under applicable U.S. federal income tax rules, a partner in a partnership has a single, or ?unitary?, tax basis in his or her partnership interest, unlike a shareholder of a corporation. As a result, any amount you pay to acquire additional units (including through the distribution reinvestment plan, if available) will be averaged with the adjusted tax basis of units owned by you prior to the acquisition of such additional units.*** The BPY General Partner expresses no opinion regarding the appropriate methodology to be used in making this determination.

Ira Smilovitz

units have been purchased on more than one occasion.

PTP, my question is simply:

adjusted cost basis of the second purchase?

• adjustments and the cost basis for the sale is 50/300 of the total adjusted cost basis?

ask is that I ran across the following in the prospectus for the spinoff of Brookfield Property Partners from Brookfield Asset Management:

168): (Emphasis added) >

market value on the date you receive them pursuant to the spin-off, increased by your share of our company?s liabilities, if any. That basis will be increased by

company?s liabilities, if any. That basis will be decreased, but not below zero, by distributions you receive from our company, by your share of our company?s

***Under applicable U.S. federal income tax rules, a partner in a partnership has a single, or ?unitary?, tax basis in his or her partnership interest, unlike a shareholder of a corporation. As a result, any amount you pay to acquire additional units (including through the distribution reinvestment plan, if available) will be averaged with the adjusted tax basis of units owned by you prior to the acquisition of such additional units.*** The BPY General Partner expresses no opinion regarding the appropriate methodology to be used in making this determination.

I believe you are right. However, I also believe that you can elect to use specific identification as that is the only way to identify the actual holding period for the units you sell. If you don't use specific ID, I think you have to use the normal partnership rules for split holding periods.