Our Videos

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,
 




Testimonials

John Beacleay

Just wanted to say thanks again for all your help Anton. I mean it's really amazing to me that yo...
Read More »
Niranjan Sujay
I recently used LOGOS INTERNATIONAL for the translation of my bachelor’s certificate, and I couldn’t...
Read More »
Katia Nagata

As a foreigner, I needed a certified translation, so I called the DOE to give me a list of the ce...
Read More »
AnnaMaria Realbuto
Thank you for all your assistance and efficiency...
Read More »




FAQ

Is It Okay For Me To Purchase and Consume Chilean Sea Bass?
Read More »
How much tax do we pay on a gallon of gasoline?
Read More »
What if the post-completion OPT expired before April 1? It appears that F-1 status would be extended, but would OPT also be extended?
Read More »
What is the E-Verify program?
Read More »






News

December 19, 25
Jamaican man convicted of using fake birth certificate to apply for US passport
Read More »
December 16, 25
US Supreme Court to examine birth certificates as proof of citizenship
Read More »
December 10, 25
Body of Cheerleader who died aboard Carnival cruise cremated – death certificate
Read More »
December 5, 25
IRS agents to watch OnlyFans content to determine if income qualifies for “No Tax on Tips” Deduction
Read More »