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@eeyore wrote:

I have an individual taxpayer who has invested in partnerships that either are foreign partnerships or have transferred property to a foreign corporation.

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You need to be very clear about the relationships, structures, and entity type of these organizations.  That would be part of your due d.  As you already mentioned, the exposures for getting these wrong are very high.

As we discussed in the various threads, Treas. Reg. on the classification of foreign entities are very different from those applicable to domestic entities and how the country of the entity's formation classifies the organization for legal and tax purposes is not relevant when it comes to US tax filing and reporting.  The reporting requirements and tax implications would not be the same, depending on whether those are foreign corporations, partnerships, or FDE.