Foreign company has ownership in two domestic LLCs which are taxed as partnerships. One partnership has FDAP income for 2018 on K-1. 1042 withholding was done on this. Foreign company has NOL carryforward so no income tax. So, is it correct that I calculate the change via income method reg sec 1.884-1(d)(3)(iii)? Box 1 from both partnerships was negative and FDAP was positive. The investment in the partnerships on their books increased from the prior year. I'm guessing this will result in no BPT.
Thank you in advance for your insight.