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These final regulations remove outdated portions of § 301.6402–2 that provided rules for claims filed prior to April 15, 1968 and § 301.6402–3 that provided special rules for claims for credit or refund of income taxes filed before July 1, 1976, and revises the reference in § 301.6402–4 to reflect the threshold for referral to the Joint Committee on Taxation pursuant to section 6405.
These final regulations do not affect § 301.6402–3T as promulgated in Treasury Decision 9658 (79 FR 12880) (March 6, 2014).
Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).
This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.
This document contains final regulations for filing a claim for credit or refund.
To the extent that electronic filing is or becomes available for filing a claim for credit or refund, it will be described elsewhere – for example, in forms, form instructions, publications, or the IRS website. The legislative history to section 707(a)(2)(A) includes the following examples of factors that could bear on this determination: (i) whether the partner status of the recipient is transitory; (ii) whether the allocation and distribution that are made to the partner are close in time to the partner’s performance of services; (iii) whether the facts and circumstances indicate that the recipient became a partner primarily to obtain tax benefits for itself or the partnership that would not otherwise have been available; and (iv) whether the value of the recipient’s interest in general and in continuing partnership profits is small in relation to the allocation in question.These proposed regulations provide guidance to partnerships and their partners regarding when an arrangement will be treated as a disguised payment for services under section 707(a)(2)(A) of the Internal Revenue Code.This document also proposes conforming modifications to the regulations governing guaranteed payments under section 707(c).Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases.In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same.
Additionally, this document provides notice of proposed modifications to Rev. 93––43 relating to the issuance of interests in partnership profits to service providers.