Internal Revenue Service November 18, 2005 – Federal Register Recent Federal Regulation Documents

Partner's Distributive Share
Document Number: 05-22281
Type: Proposed Rule
Date: 2005-11-18
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
The proposed regulations provide rules for testing the substantiality of an allocation under section 704(b) where the partners are look-through entities or members of a consolidated group, provide additional guidance on the effect of other provisions, such as section 482, upon the tax treatment of a partner with respect to the partner's distributive share under section 704(b), and revise the existing rules for determining the partners' interests in a partnership. The proposed regulations affect partnerships and their partners. This document also provides notice of a public hearing on these proposed regulations.
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