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 Pís 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 Bís 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

AnnaMaria Realbuto
Thank you for all your assistance and efficiency...
Read More »
Kateryna Melnychenko
Thanks a lot Anton!...
Read More »
Rani Payne
Thank you so much! Iím sure I will be in touch again with something else that will need to be apost...
Read More »
Serge Bauer Law
Thank you again for your help with this case!...
Read More »



FAQ

Can I apply online for my business permit?
Read More »
What documents can an F-1 student with automatic employment authorization under the cap-gap provision show his or her employer when completing the Form I-9?
Read More »
Q. Are the methods described in section 1608(a)(4) exclusive? Can't I just serve the foreign embassy or mission to the United Nations?
Read More »
How to obtain the Form 6166?
Read More »






News

February 23, 24
Navalnyís death certificate reportedly states natural causes
Read More »
February 19, 24
Birth Certificate Woes: DC Family's Struggle Highlights Home Birth Challenges
Read More »
February 14, 24
Coroner Charged with Theft and Fraud, Faces Removal Amidst Controversy Over Death Certificates
Read More »
February 10, 24
Hungarian president under fire over pardon of man with child sex abuse-related criminal record
Read More »