Regs forthcoming on domestic partnerships used to block subpart F income, IRS says
The Internal Revenue Service on May 14 announced in Notice 2010-41 that it will issue regulations classifying certain domestic partnerships as foreign for purposes of determining which U.S. shareholder must include in its gross income a pro rata share of a controlled foreign corporation’s (CFC’s) subpart F income. The regulations will apply to the taxable years of domestic partnerships ending after May 13, 2010.
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