1704007 Informal Interpretation

From: Storm, Evan

Sent: Friday, April 28, 2017 4:17 PM

To: [Redacted]

Cc: Walsh, Kathryn E.; Whitehead, Nora

Subject: RE: Size-of-person for natural person

[Redacted]

1. If the controlled entity has a regularly prepared balance sheet, include the personal, non‐income‐producing property (such as residences)

2. If the controlled entity does not have a regularly prepared balance sheet, exclude the personal, non‐incomeproducing property (such as residences)

Regards

Evan

From: [Redacted]

Sent: Friday, April 28, 2017 3:16 PM

To: Walsh, Kathryn E.; Whitehead, Nora; Storm, Evan

Subject: Size-of-person for natural person

In determining the size-of-person for a natural person UPE, can you confirm that the value of personal, non-incomeproducing property (such as residences) may be excluded even if held through a controlled entity (instead of directly)? Is the result the same whether or not the controlled entity has a regularly-prepared balance sheet?

Thanks,

[Redacted]