Our Videos

FAQ / For purposes of completing its 2008 Form 1065 Schedule B, questions 3 and 4, what percentage interest in profit, loss, or capital should Partnership P report for individual partners A and B, and corpo


A and B each directly owns 50% of Pís profit, loss, and capital.
A and B also each owns directly 50% of the stock in corporation Y.

Do the attribution rules of section 267(c) and A and Bís common control of both partnership P and corporation Y result in P being deemed to indirectly own corporation Y? What must partnership P report as its percentage ownership of corporation Y on Schedule B question 4a?

A12: For purposes of Schedule B, questions 3 and 4, partnership P reports that A and B each own, directly or indirectly, 50 percent of the profit, loss, or capital of partnership P in answering Schedule B, question 3b.

Because corporation Y is not a partner in partnership P, P does not report an ownership interest in Y in response to question 3a. Y is neither a direct nor an indirect partner in P.

Partnership P does not report an interest in corporation Y in answering question 4a. P is not considered to indirectly own an interest in Y under section 267(c), even though A and B control both P and Y.

Keywords: corporation,
 




Testimonials

AnnaMaria Realbuto
Thank you for all your assistance and efficiency...
Read More »
Kateryna Melnychenko
Thanks a lot Anton!...
Read More »
Rani Payne
Thank you so much! Iím sure I will be in touch again with something else that will need to be apost...
Read More »
Serge Bauer Law
Thank you again for your help with this case!...
Read More »



FAQ

Do I need a permit or license for my business?
Read More »
Since when does the Wassenaar Arrangement exist?
Read More »
Is there a waiting period? Can we get married right away?
Read More »
If a student was not in an authorized period of OPT on the eligibility date, can the student work during the cap gap extension?
Read More »






News

April 11, 23
Fleetwood Mac keyboardist and vocalist Christine McVie died of stroke and cancer-death certificate
Read More »
March 27, 23
China joins Apostille Convention
Read More »
March 18, 23
California to permanently seal old convictions on criminal records
Read More »
March 3, 23
Saudi Arabia issues guidance on apostille procedure
Read More »