19 November 2024 IRS issues final regulations on excluding certain organizations from subchapter K rules for purposes of making IRC Section 6417 direct pay elections The Treasury Department and IRS on November 19, 2024, issued final regulations (TD 10012) concerning the ability of unincorporated organizations owned by applicable entities to be excluded from subchapter K restrictions, thus allowing one or more members of the organization to make elective payment elections under IRC Section 6417. The final regulations adopt the proposed regulations with some modifications. Treasury and IRS also issued proposed regulations (REG-116017-24) with administrative requirements for unincorporated organizations seeking to make an election to be excluded from application of the partnership tax rules in subchapter K, as well as procedures for revoking such an election. A Tax Alert is forthcoming.
Document ID: 2024-2115 | ||
