Tax News Update    Email this document    Print this document  

November 19, 2024
2024-2115

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.

* * * * * * * * * *
Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor
 

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

Copyright © 1996 – 2024, Ernst & Young LLP

 

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

 

EY US Tax News Update Master Agreement | EY Privacy Statement