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 P’s 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 B’s 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,