Examples of Cooperative partner in a sentence
Without this reporting, the Specified Cooperative partner would not have the information necessary to calculate its section 199A(g) deduction from its activities with the partnership.The Schedule K-1 to the Form 1065 will be modified to include a mechanism to report the Specified Cooperative partner’s allocable share of gross receipts and related deductions.
A commenter also recommended that, to the extent a partnership conducts activities that result in gross receipts, a Specified Cooperative partner in that partnership should be permitted to treat those activities as conducted directed by the Specified Cooperative.
For purposes of determining whether gross receipts are DPGR, the MPGE activities of the Specified Cooperative partner may be attributed to the partnership, and the partnership’s MPGE activities may be attributed to the Specified Cooperative partner.(g) Recapture of section 199A(g)deduction.
The Treasury Department and IRS agree with the comment and § 1.199A–8(f) now allows for two-way attribution, meaning: (1) A partnership’s activities alone with respect to an agricultural or horticultural product can qualify thegross receipts for the Specified Cooperative partner, and (2) a partnership can be attributed the activities of the Specified Cooperative partner (including those activities that a specified partner is attributed from patrons) so that the gross receipts can be DPGR.
Without this reporting, the Specified Cooperative partner would not have the information necessary to calculate its section 199A(g) deduction from its activities with the partnership.
In the case described in section 199A(g)(5)(B), where a Specified Cooperative is a partner in a partnership, the partnership must separately identify and report on the Schedule K–1 of the Form 1065,U.S. Return of Partnership Income (or any successor form) issued to the Specified Cooperative partner the cooperative’s share of gross receipts and related deductions, unless otherwise provided by the instructions to the Form.
Under these regulations, the partnership must separately identify and report the allocable share of gross receipts and related deductions, W–2 wages, and cost of goods sold on or attached to the Schedule K–1 to the Form 1065 (or any successor form) issued to a Specified Cooperative partner, unless otherwise provided by the instructions to the Form.
Additionally, the final regulations allow for two-way attribution, meaning: (1) A partnership’s activities alone with respect to an agricultural or horticultural product can qualify as gross receipts for the Specified Cooperative partner and (2) a partnership can be attributed the activities of the Specified Cooperative partner.
The Specified Cooperative partner determines what gross receipts reported by the partnership qualify as DPGR and includes these gross receipts and related deductions, W–2 wages, and COGS to calculate one section 199A(g) deduction (in the case of a nonexempt Specified Cooperative) or two section 199A(g) deductions (in the case of an exempt Specified Cooperative) using the steps set forth in paragraphs (b) and (c) of this section.
Cooperative partner nodes selection criteria for cooperative routing in underwater WSNs. In Proceedings of the 5th National Symposium on Information Technology: Towards New Smart World (NSITNSW), Riyadh, Saudi Arabia, 17–19 February 2015; pp.