Treasury Regulations (26 C.F.R.)
26 CFR § 301.6221(a)-1
Determination at partnership level.
# (a) In general.
Except as otherwise provided under subchapter C of chapter 63 of the Internal Revenue Code (subchapter C of chapter 63) and the regulations in this part, any adjustment to a partnership-related item (as defined in § 301.6241-1(a)(6)(ii)) is determined, any tax imposed by chapter 1 of the Internal Revenue Code (Code) attributable thereto is assessed and collected, and the applicability of any penalty, addition to tax, or additional amount that relates to an adjustment to any partnership-related item is determined at the partnership level under subchapter C of chapter 63.
# (b) Legal and factual determinations at the partnership level.
Except as otherwise provided under subchapter C of chapter 63, any legal or factual determinations underlying any adjustment or determination made in accordance with paragraph (a) of this section are also determined at the partnership level under subchapter C of chapter 63. For instance, determinations under this paragraph (b) include any determinations necessary to calculate the imputed underpayment or any modification of the imputed underpayment under section 6225 and the period of limitations on making adjustments under subchapter C of chapter 63.
# (c)
Applicability date—(1) In general. Except as provided in paragraph (c)(2) of this section, this section applies to partnership taxable years beginning after December 31, 2017, and ending after August 12, 2018.
(2) Election under § 301.9100-22 in effect. This section applies to any partnership taxable year beginning after November 2, 2015, and before January 1, 2018, for which a valid election under § 301.9100-22 is in effect.
[T.D. 9844, 84 FR 6531, Feb. 27, 2019]
Source: view the official text
In this part (40 sections)
- 301.6155-1 · Payment on notice and demand.
- 301.6159-0 · Table of contents.
- 301.6159-1 · Agreements for payment of tax liabilities in installments.
- 301.6161-1 · Extension of time for paying tax.
- 301.6162-1 · Extension of time for payment of tax on gain attributable…
- 301.6163-1 · Extension of time for payment of estate tax on value of…
- 301.6164-1 · Extension of time for payment of taxes by corporations…
- 301.6165-1 · Bonds where time to pay the tax or deficiency has been…
- 301.6166-1 · Extension of time for payment of estate tax where estate…
- 301.6201-1 · Assessment authority.
- 301.6203-1 · Method of assessment.
- 301.6204-1 · Supplemental assessments.
- 301.6205-1 · Special rules applicable to certain employment taxes.
- 301.6211-1 · Deficiency defined.
- 301.6212-1 · Notice of deficiency.
- 301.6212-2 · Definition of last known address.
- 301.6213-1 · Restrictions applicable to deficiencies; petition to Tax…
- 301.6213-2 · Omission of correct vehicle identification number.
- 301.6215-1 · Assessment of deficiency found by Tax Court.
- 301.6221-1 · Tax treatment determined at partnership level.
- 301.6221(a)-1 · Determination at partnership level.
- 301.6221(b)-1 · Election out for certain partnerships with 100 or fewer…
- 301.6222-1 · Partner's return must be consistent with partnership…
- 301.6222(a)-1 · Consistent treatment of partnership items.
- 301.6222(a)-2 · Application of consistent reporting and notification…
- 301.6222(b)-1 · Notification to the Internal Revenue Service when…
- 301.6222(b)-2 · Effect of notification of inconsistent treatment.
- 301.6222(b)-3 · Partner receiving incorrect schedule.
- 301.6223-1 · Partnership representative.
- 301.6223-2 · Binding effect of actions of the partnership and…
- 301.6223(a)-1 · Notice sent to tax matters partner.
- 301.6223(a)-2 · Withdrawal of notice of the beginning of an…
- 301.6223(b)-1 · Notice group.
- 301.6223(c)-1 · Additional information regarding partners furnished to…
- 301.6223(e)-1 · Effect of Internal Revenue Service's failure to provide…
- 301.6223(e)-2 · Elections if Internal Revenue Service fails to provide…
- 301.6223(f)-1 · Duplicate copy of final partnership administrative…
- 301.6223(g)-1 · Responsibilities of the tax matters partner.
- 301.6223(h)-1 · Responsibilities of pass-thru partner.
- 301.6224(a)-1 · Participation in administrative proceedings.