What percentage of distribution is considered foreign sourced income for a partnership with 65% foreign source ordinary income?

To determine the percentage of distribution that is considered foreign sourced income for a partnership with 65% foreign source ordinary income, we look directly at the proportion of the total ordinary income. In this case, since the partnership has 65% of its ordinary income classified as foreign sourced, this directly indicates that 65% of any distribution made by the partnership will also be considered foreign sourced income.

It’s important to identify that the sources of income within a partnership affect how distributions are viewed for tax purposes. Since the partnership's income is specifically delineated as 65% foreign sourced, it follows that this same percentage applies when considering distributions to partners. Thus, the percentage of the distribution considered foreign sourced income corresponds directly to the percentage of ordinary income classified as foreign sourced.

This concept reflects the flow-through nature of partnership taxation, wherein the income classifications of the partnership pass through to the partners in the same relative proportions as they exist at the partnership level. Therefore, since 65% of the partnership's ordinary income is foreign sourced, 65% of the distributions to partners will also be recognized as foreign sourced income.