Page 56 - Large Business IRS Training Guides

Partnerships (cont’d)
2

relevant items:

• Other subject to the small partner
each partner is treated as owning its share
exception,

partnership items determined under section 704,
of
the partnership
including the assets of

• For items allocated to partners (including deductions
and
BETBs) = distributive share

• For items not allocated to partners = proportionate with

partner’s distributive share of partnership income

apply rules iteratively until
• Tiered partnerships:

partner is not
a partnership

exception only applied at level where
• Small partner
partner
is not a partnership

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