Sec. 203. Alternative procedure to filing amended returns for purposes of modifying imputed underpayment
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/bill/114/hr/6439/ih/section-203·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Section 6225(c)(2) is amended to read as follows: Such procedures shall provide that if— one or more partners file returns for the taxable year of the partners which includes the end of the reviewed year of the partnership (and for any taxable year with respect to which any tax attribute is affected by reason of any adjustment referred to in clause (ii)), such returns take into account all adjustments under subsection
(a)properly allocable to such partners (and the effect of such adjustments on any tax attributes), and payment of any tax due is included with such returns, then the imputed underpayment amount shall be determined without regard to the portion of the adjustments so taken into account. Such procedures shall provide that, with respect to any partner referred to in subparagraph (A), the requirements of subparagraph
(A)shall be treated as satisfied with respect to adjustments properly allocable to such partner if, in lieu of filing the returns described in such subparagraph— the amounts described in subparagraph (A)(iii) are paid by the partner, the adjustments to the tax attributes of such partner referred to in subparagraph (A)(ii) are binding with respect to all subsequent taxable years of the partner, and such partner provides, in the form and manner specified by the Secretary (including, if the Secretary so specifies, in the same form as on an amended return), such information as the Secretary may require to carry out this subparagraph. In the case of any adjustment which reallocates the distributive share of any item from one partner to another, this paragraph shall apply with respect to any such partner only if the requirements of subparagraph
(A)or
(B)are satisfied with respect to all partners affected by such adjustment. Sections 6501 and 6511 shall not apply with respect to any return filed for purposes of subparagraph (A)(i) or any amount paid under subparagraph (A)(iii) or (B)(i), but only with respect to adjustments referred to in subparagraph (A)(ii). In the case of any partnership any partner of which is a partnership, except as otherwise provided by the Secretary, subparagraph
(B)shall apply with respect to any partner in the chain of ownership of such partnerships. For purposes of applying the preceding sentence, an S corporation and its shareholders shall be treated in the same manner as a partnership and its partners. . Section 6201(a)(1) is amended by inserting (or payments under section 6225(c)(2)(B)(i)) after returns or lists .