Tax Matters Partner

ID:
UILC:
CCA_2017060816131043
6231.07-00
Number: 201725028
Release Date: 6/23/2017
From:
Sent: Thursday, June 08, 2017 4:13:10 PM
To:
Cc:
Bcc:
Subject: RE: TEFRA/TMP Question
There is no prohibition on a foreign partner being TMP if they are eligible. The only prohibition is if there is a U.S. partner that is eligible to be TMP. In that case, the foreign partner cannot be named as TMP without the IRS consent. 301.6231(a)(7)-1(b)(2).
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