Gross receipts for section 59a e1/26/2024 The provisions of section 59A must be interpreted in a manner consistent with this approach. Except for purposes of determining a partner's base erosion tax benefits under paragraph (d)(1) of this section and whether a taxpayer is a registered securities dealer under paragraph (e)(3) of this section, section 59A determinations are made at the partner level in the manner described in this section. The purpose of this section is to provide a set of operating rules for the application of section 59A to partnerships and partners in a manner consistent with the purposes of section 59A. (b) Application of section 59A to partnerships. Paragraph (g) of this section provides examples that illustrate the application of the rules of this section. Paragraph (f) of this section provides a rule for determining whether a person is a foreign related party. Paragraph (e) of this section provides additional rules relating to the application of section 59A to partnerships. Paragraph (d) of this section provides rules for determining the base erosion tax benefits of a partner. Paragraph (c) of this section provides rules for determining whether there is a base erosion payment with respect to a payment to or from a partnership. Paragraph (b) of this section describes how the aggregate approach to partnerships applies for purposes of certain section 59A determinations. The aggregate principles provided in this section apply without regard to any tax avoidance purpose relating to a particular partnership. The aggregate principle described in this section does not override the treatment of partnership items under any Code section other than section 59A. This section applies to payments to a partnership and payments from a partnership as well as transfers of partnership interests (as defined in paragraph (c)(3)(iv) of this section). All references to partnerships in this section include domestic and foreign partnerships. This section provides rules regarding how partnerships and their partners are treated for purposes of making certain determinations under section 59A, including whether there is a base erosion payment or base erosion tax benefit. ยง 1.59A-7 Application of base erosion and anti-abuse tax to partnerships.
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