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Code · BILL · 114th Congress · H.R. 6439 (Introduced in House) — To amend the Internal Revenue Code of 1986 to make technical corrections, and for other purposes. · Sec. 204

Sec. 204. Treatment of passthrough partners in tiered structures

289 words·~1 min read·/bill/114/hr/6439/ih/section-204·

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Section 6226(b) is amended by adding at the end the following new paragraph: If a partner which receives a statement under subsection (a)(2) is a partnership or an S corporation, such partner shall, with respect to the partner’s share of the adjustment— file with the Secretary a partnership adjustment tracking report which includes such information as the Secretary may require, and either— pay the imputed underpayment under rules similar to the rules of section 6225 (other than paragraphs (2)(A), (6), (7), and
(9)of subsection
(c)thereof), or furnish statements under rules similar to the rules of subsection (a)(2). For purposes of subparagraph (A), with respect to a partner’s share of the adjustment, the partnership adjustment tracking report shall be filed, and the imputed underpayment shall be paid or statements shall be furnished, not later than the due date for the return for the taxable year of the audited partnership which includes the date the final determination was made with respect to such partnership. In the case of a partnership which has elected the application of section 6221(b) with respect to the taxable year of the partnership which includes the end of the reviewed year of the audited partnership, this paragraph shall apply notwithstanding such election, except that subparagraph
(A)shall be applied without regard to clause (ii)(I) thereof. For purposes of this paragraph, the term audited partnership means, with respect to any partner described in subparagraph (A), the partnership in the chain of ownership originally electing the application of this section. . Section 6226(b)(1) is amended by striking Each partner’s and inserting Except as provided in paragraph (4), each partner’s . Section 6226(c)(2) is amended by inserting or which is described in subsection (b)(4)(A)(ii)(I), after is elected, .
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