Page 55 - Large Business IRS Training Guides

Partnerships (cont’d)
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partner includes a share of partnership
• Gross receipts:

receipts in proportion to the partner’s distributive
gross
share of items of partnership gross income

• Foreign corporation – only with regard to gross receipts that

produce income that is
effective connected with a U.S.
trade or business
(or, if a treaty applies, only with regard to

gross receipts taken into account in determining net taxable

income)

– If partnership or
• Registered securities dealer
partnership branch is
a registered securities dealer, each

a registered securities dealer
partner is treated as

exception
• Small partner

determined at partner level
• Foreign related party

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