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- 26 USC §1366Pass-thru of items to shareholdersFederal (EE. UU.)Sección de códigoVigencia: 2024-12-31
subparagraph (A) shall include amounts described in paragraph (4) or (6) of section 702(a). (2) Nonseparately computed income or loss defined For purposes of this subchapter, the term "nonseparately
- 26 CFR §1.404(e)-1AContributions on behalf of a self-employed individual to or under a qualified pension, annuity, or profit-sharing plan.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
Partner's distributive share of contributions and deductions. (1) For purposes of sections 702(a)(8) and 704 in the case of a defined contribution plan, a partner's distributive ... within which the partnership's taxable year ends, as an item described in section 702(a)(8). (2) In the case of a defined benefit plan, a partner's distributive
- 26 CFR §1.468B-2Taxation of qualified settlement funds and related administrative requirements.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
share of that partnership's items of loss, deduction, or credit described in section 702(a) that would be deductible in determining the taxable income (or in the case ... distributive share of that partnership's items of income and gain described in section 702(a) for the same taxable year. For purposes of this paragraph (c)(1), a distributive
- 26 USC §1402DefinitionsFederal (EE. UU.)Sección de códigoVigencia: 2024-12-31
distributive share (whether or not distributed) of income or loss described in section 702(a)(8) from any trade or business carried on by a partnership of which ... more than the upper limit, his distributive share of income described in section 702(a)(8) derived from such trade or business may, at his option, be deemed
- 26 CFR §1.50B-4Partnerships.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
partnership (that is, the taxable income of the partnership as described in section 702 (a)(9)) regardless of whether the partnership has a profit or a loss for the taxable
- 26 USC §706Taxable years of partner and partnershipFederal (EE. UU.)Sección de códigoVigencia: 2024-12-31
taxable income of a partner for a taxable year, the inclusions required by section 702 and section 707(c) with respect to a partnership shall be based on the income
- 26 CFR §1.737-1Recognition of precontribution gain.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
that would have been taken into account separately by the contributing partner under section 702(a) and § 1.702-1(a). (e) Examples. The following examples illustrate the provisions of this ... would have been required to take such gains into account separately under section 702. As a result, A's net precontribution gain of $3,000 consists
- 26 USC §7519Required payments for entities electing not to have required taxable yearFederal (EE. UU.)Sección de códigoVigencia: 2024-12-31
taking into account the aggregate amount of the partnership's items described in section 702(a) (other than credits and tax-exempt income). (B) S corporations In the case
- 26 CFR §1.707-1Transactions between partner and partnership.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
payment. Since the items of partnership income or loss must be segregated under section 702(a), the partnership has a $10,000 ordinary loss and $30,000 in capital gains
- 26 CFR §301.6225-1Partnership adjustment by the Internal Revenue Service.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
adjustment would be required to be taken into account separately under section 702(a) or any other provision of the Code, regulations, forms, instructions, or other guidance prescribed ... partners of the partnership as a single partnership-related item for purposes of section 702(a), other provision of the Code, regulations, forms, instructions, or other guidance prescribed
- 26 CFR §1.706-1Taxable years of partner and partnership.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
include the partner's distributive share of partnership items set forth in section 702 and the regulations thereunder for any partnership taxable year ending within or with the partner ... together with A's distributive share of partnership items set forth in section 702 for the partnership taxable year ending May 31, 2002). (3) If a partner receives distributions under
- 26 CFR §1.6654-2Exceptions to imposition of the addition to the tax in the case of individuals.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
account: (A) The partner's distributive share of partnership items set forth under section 702, (B) The amount of any guaranteed payments under section 707(c), and (C) Gains ... account: (A) The partner's distributive share of income or loss, described in section 702(a)(9), subject to the special rules set forth in section
- 26 CFR §1.7519-1TRequired payments for entities electing not to have required year (temporary).Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
taking into account the aggregate amount of the partnership's items described in section 702(a), except for— ( 1 ) Credits, ( 2 ) Tax-exempt income, and ( 3 ) Guaranteed payments under section ... deductions and losses are treated as negative income. Thus, for example, if under section 702(a) a partnership has $1,000 of ordinary taxable income, $500 of specially allocated deductions
- 26 CFR §1.852-4Method of taxation of shareholders of regulated investment companies.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
beginning before 1977; 9 months for taxable years beginning in 1977) pursuant to section 702(a)(2) and paragraph (a)(2) of § 1.702-1. The tax with respect ... such tax shall be taken into account by the partners in accordance with section 702(a)(8) and paragraph (a)(8)(ii) of § 1.702-1 and paragraph
- 26 USC §6225Partnership adjustment by SecretaryFederal (EE. UU.)Sección de códigoVigencia: 2024-12-31
category of items that are required to be taken into account separately under section 702(a) or other provision of this title. (4) Limitation on adjustments that may be taken
- 26 CFR §1.706-4Determination of distributive share when a partner's interest varies.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
Allocation of items subject to this section. In determining the distributive share under section 702(a) of partnership items subject to this section, the partnership shall follow the steps described ... segment. (x) Tenth, determine the partners' distributive shares of partnership items under section 702(a) by taking into account the partners' interests in such items during each segment and proration
- 26 CFR §301.6114-1Treaty-based return positions.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
Procedure 2003-64, (2003-2 C.B. 306); Revenue Procedure 2004-21 (2004-1 C.B. 702); Revenue Procedure 2005-77 (2005-51 I.R.B. 1176) (see § 601.601(b)(2) of this chapter ... amended by Revenue Procedure 2004-21 (2004-1 C.B. 702); Revenue Procedure 2005-77 (2005-51 I.R.B. 1176); (see § 601.601(b)(2) of this chapter). (iv) Paragraph
- 26 CFR §1.6655-1Addition to the tax in the case of a corporation.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
period 6-16-09 through 12-15-09), computed as 183/365 × $17,500 × 8% = $702 (C) Third installment (underpayment period 9-16-09 through 12-15-09), computed as 91/365
- 26 CFR §1.444-2TTiered structure (temporary).Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
gross income for the testing period (“2 percent gross income test”). See section 702 (c) for rules relating to the determination of gross income of a partner in a partnership ... Aggregate amount of the partnership items described in section 702(a) (other than credits and tax-exempt income), ( 2 ) Applicable payments defined in section 7519(d)(3) that are deducted
- 26 CFR §1.179-2Limitations on amount subject to section 179 election.Federal (EE. UU.)ReglamentoVigencia: 2026-07-17
taking into account the aggregate amount of the partnership's items described in section 702(a) (other than credits, tax-exempt income, and guaranteed payments under section 707(c)) derived ... negative income. Any limitation on the amount of a partnership item described in section 702(a) which may be taken into account for purposes of computing the taxable income