WebFor purposes of section 7704 (b) and this section, a redemption or repurchase agreement means a plan of redemption or repurchase maintained by a partnership whereby the partners may tender their partnership interests for purchase by the partnership, another partner, or a person related to another partner (within the meaning of section 267 (b) or … WebFor purposes of section 7704 (b) and this section, the transfer of an interest in a partnership through a qualified matching service is disregarded in determining whether interests in …
Taxation of Publicly Traded Partnerships Practical Law
Web76 (3) (i) an association, within the meaning of IRC section 7701(a)(3), a joint stock 77 company or association, a publicly traded partnership treated as a corporation pursuant to IRC 78 section 7704 and any business conducted by a trustee or trustees wherein interest or ownership 79 is evidenced by certificate or other written instrument. WebPass-through entity (PTE) tax is an elective tax on partnerships (other than a publicly traded partnership under Internal Revenue Code (IRC) Section 7704) and Subchapter S corporations effective for tax years ending on or after December 31, 2024, and beginning before January 1, 2026. Tax rate simonmed 3rd st
Sec. 7704. Certain Publicly Traded Partnerships Treated As Corpor…
Web§7704 TITLE 26—INTERNAL REVENUE CODE Page 3706 EFFECTIVE DATE Section applicable to bonds issued after Aug. 15, 1986, except as otherwise provided, see sections 1311 to 1318 of Pub. L. 99–514, set out as an Effective Date; Transi-tional Rules note under section 141 of this title. §7704. Certain publicly traded partnerships WebOct 1, 2024 · For purposes of Sec. 280G, the regulations define a corporation to include: A publicly traded partnership treated as a corporation under Sec. 7704 (a); An entity described in Regs. Sec. 301.7701-3 (c) (1) (v) (A); A real estate investment trust under Sec. 856 (a); WebThe use of property or capital (including rents, royalties, interest, and dividends) in a transaction that produces business income, in which the income, gain, or loss is recognized (or would be recognized if the transaction were in the United States) under the IRC. simonmed 4219