Common use of Partnership RBIG Clause in Contracts

Partnership RBIG. An S corporation’s partnership RBIG for any taxable year may not exceed the excess (if any) of the S corpora- tion’s RBIG limitation over its part- nership RBIG for prior taxable years. The preceding sentence does not apply if a corporation forms or avails of a partnership with a principal purpose of avoiding the tax imposed under section 1374.