Internal Revenue Service, Treasury § 1.1002–1Internal Revenue Service Regulations • July 1st, 2013
Internal Revenue Service, Treasury § 31.3121(a)(7)–1Internal Revenue Service Regulations • December 4th, 2023
Example 2. F, a private foundation, is a partner in P partnership. In addition, A and B, the only disqualified persons with respect to F, are partners in P. The partnership agreement of P contains no provisions re- garding the sharing of profits by,...Internal Revenue Service Regulations • August 27th, 2024
treated under section 4943(c)(4)(B) as held by disqualified persons for a cer- tain period of time (the ‘‘first phase’’). The effect of such treatment is to pre- vent a private foundation from being subject to the initial tax with respect to its May 26, 1969, interest during the first phase holding period and also to prevent the foundation from pur- chasing any additional business hold- ings in such business enterprise during such period (unless the combined hold- ings of the foundation and all disquali- fied persons fall below the 20 percent (or 35 percent, if applicable) figure pre- scribed by section 4943(c)(2)). Second, section 4943(c)(4)(A)(i) initially in- creases the percentage of permitted holdings of such a foundation to a per- centage equal to the difference be- tween:
Internal Revenue Service, Treasury § 301.6223(g)–1Internal Revenue Service Regulations • March 4th, 2021
decision, or a settlement agreement de- scribed in section 6224(c)(2) with re- spect to the partnership taxable year to which the adjustment relates apply to that partner. If the partner does not make an election in accordance with paragraph (d) of this section, the part- nership items of the partner for the partnership taxable year to which the proceeding relates shall be treated as having become nonpartnership items as of the day on which the Internal Rev- enue Service mails the partner the FPAA.
Internal Revenue Service, Treasury § 1.401(a)(26)–9Internal Revenue Service Regulations • July 10th, 2013
Collective bargaining agreement. Collec- tive bargaining agreement means an agreement that the Secretary of Labor finds to be a collective bargaining agreement between employee rep- resentatives and the employer that sat- isfies § 301.7701–17T. Employees de- scribed in section 413(b)(8) who are em- ployees of the union or the plan and are treated as employees of an em- ployer are not employees covered pur- suant to a collective bargaining agree- ment for purposes of section 401(a)(26) unless the employees are actually cov- ered pursuant to such an agreement.
Internal Revenue Service, Treasury § 301.6223(g)–1Internal Revenue Service Regulations • March 4th, 2021
decision, or a settlement agreement de- scribed in section 6224(c)(2) with re- spect to the partnership taxable year to which the adjustment relates apply to that partner. If the partner does not make an election in accordance with paragraph (d) of this section, the part- nership items of the partner for the partnership taxable year to which the proceeding relates shall be treated as having become nonpartnership items as of the day on which the Internal Rev- enue Service mails the partner the FPAA.
Internal Revenue Service, Treasury § 1.401(a)(26)–9Internal Revenue Service Regulations • July 10th, 2013
