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IRS Mulls Expanding Application of Aggregate Partnership Rules

Jan. 14, 2021, 5:38 PM

Partnerships could be required to use a certain method of calculating taxable income in final IRS rules as an effort to harmonize international and domestic tax rules, an agency official said.

Proposed aggregate partnership rules (REG-101828-19, RIN: 1545-BP15) released in 2019 treat partnerships as an aggregate of their partners, rather than as entities, when tallying types of offshore income like global intangible low-taxed income or Subpart F income. But partnerships without offshore income can rely on the entity approach to calculate their taxable income.

The IRS may change that flexibility and apply the aggregate approach to domestic partnerships ...