Treasury Regulations (26 C.F.R.)
26 CFR § 301.6241-4
Payments nondeductible.
# (a) Payments nondeductible.
No deduction is allowed under subtitle A of the Internal Revenue Code (Code) for any payment required to be made by a partnership under subchapter C of chapter 63 of the Code (subchapter C of chapter 63). Payment by a partnership of any amount required to be paid under subchapter C of chapter 63, including any imputed underpayment (as defined in § 301.6241-1(a)(3)), or interest, penalties, additions to tax, or additional amounts with respect to an imputed underpayment, is treated as an expenditure described in section 705(a)(2)(B).
# (b)
Applicability date—(1) In general. Except as provided in paragraph (b)(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 6571, Feb. 27, 2019]
Source: view the official text
In this part (40 sections)
- 301.6231(c)-2 · (c)-2 Special rules for certain refund claims based on…
- 301.6231(c)-3 · (c)-3 Limitation on applicability of §§ 301.6231(c)-4…
- 301.6231(c)-4 · (c)-4 Termination and jeopardy assessment.
- 301.6231(c)-5 · (c)-5 Criminal investigations.
- 301.6231(c)-6 · (c)-6 Indirect method of proof of income.
- 301.6231(c)-7 · (c)-7 Bankruptcy and receivership.
- 301.6231(c)-8 · (c)-8 Prompt assessment.
- 301.6231(d)-1 · (d)-1 Time for determining profits interest of partners…
- 301.6231(e)-1 · (e)-1 Effect of a determination with respect to a…
- 301.6231(e)-2 · (e)-2 Judicial decision not a bar to certain…
- 301.6231(f)-1 · (f)-1 Disallowance of losses and credits in certain…
- 301.6232-1 · Assessment, collection, and payment of imputed…
- 301.6233-1 · Extension to entities filing partnership returns.
- 301.6233(a)-1 · (a)-1 Interest and penalties determined from reviewed…
- 301.6233(b)-1 · (b)-1 Interest and penalties with respect to the…
- 301.6234-1 · Judicial review of partnership adjustment.
- 301.6235-1 · Period of limitations on making adjustments.
- 301.6241-1 · Definitions.
- 301.6241-2 · Bankruptcy of the partnership.
- 301.6241-3 · Treatment where a partnership ceases to exist.
- 301.6241-4 · Payments nondeductible.
- 301.6241-5 · Extension to entities filing partnership returns.
- 301.6241-6 · Coordination with other chapters of the Internal Revenue…
- 301.6241-7 · Treatment of special enforcement matters.
- 301.6301-1 · Collection authority.
- 301.6302-1 · Manner or time of collection of taxes.
- 301.6303-1 · Notice and demand for tax.
- 301.6305-1 · Assessment and collection of certain liability.
- 301.6311-1 · Payment by check or money order.
- 301.6311-2 · Payment by credit card and debit card.
- 301.6312-1 · Treasury certificates of indebtedness, Treasury notes, and…
- 301.6312-2 · Certain Treasury savings notes acceptable in payment of…
- 301.6313-1 · Fractional parts of a cent.
- 301.6314-1 · Receipt for taxes.
- 301.6315-1 · Payments of estimated income tax.
- 301.6316-1 · Payment of income tax in foreign currency.
- 301.6316-2 · Definitions.
- 301.6316-3 · Allocation of tax attributable to foreign currency.
- 301.6316-4 · Return requirements.
- 301.6316-5 · Manner of paying tax by foreign currency.