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Publication 541 (12/2024), Partnerships
Section 1061 recharacterizes certain long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains.
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Foreign Partners Information Statement of Section 1446
8a Check if the partnership identified on line 5a owns an interest in one or more partnerships . Partnerships ECTI allocable to partner for the tax year (see
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26 U.S. Code 707 - Transactions between partner and
two partnerships in which the same persons own, directly or indirectly, more than 50 percent of the capital interests or profits interests. In the case of a
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