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TREAS/IRS

RIN: 1545-BG56

Publication ID: Fall 2008

Title: Recharacterization of Certain Qualifying Income of Publicly Traded Partnerships
Abstract: The proposed regulations under section 7704 of the Internal Revenue Code will apply to publicly traded partnerships (PTPs) that own controlling interests in corporations that earn non-qualifying income. The regulations will provide a characterization rule for certain gross income received by a PTP from a controlled corporation that would otherwise be qualifying income under section 7704(d) and that is deductible by the corporation. The income would be characterized as non-qualifying income if the effect of the arrangement is to permit the PTP to receive income that is not subject to a corporate-level tax and that would be non-qualifying income if earned directly by the PTP.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 7704 26 USC 7805

Legal Deadline: None

Timetable:

Action	Date	FR Cite
NPRM	12/00/2008

Additional Information: REG-114703-07 Drafting attorneys: Joy C. Spies (202) 622-3998 Jason T. Smyczek (202) 622-3050 Reviewing attorney: Dianna K. Miosi (202) 622-3050 Treasury attorney: William Bowers (202) 622-5721 CC: PSI
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Joy C. Spies Senior Technician Reviewer Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 5311, Washington, DC 20224 Phone:202 622-3998 Fax:202 622-3308 Email: joy.c.spies@irscounsel.treas.gov Jason T. Smyczek Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3860 Email: jason.t.smyczek@irscounsel.treas.gov