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TREAS/IRS RIN: 1545-BG56 Publication ID: Fall 2010 
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: Completed Actions 
Major: No  Unfunded Mandates: No 
CFR Citation: 26 CFR 1   
Legal Authority: 26 USC 7704    26 USC 7805   
Legal Deadline:  None
Timetable:
Action Date FR Cite
Withdrawn  07/19/2010    
Additional Information: REG-114703-07 Drafting attorney: Joy C. Spies (202) 622-3998 Reviewing attorney: Dianna K. Miosi (202) 622-3000 Treasury attorney: Robert Crnkovich (202) 622-0843 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