These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX T.D. 9398, page 1143. Final regulations under section 704 of the Code clarify that where certain look-through entities (or members of a consolidated group) are partners in a partnership, the tax attributes of the owners of the look-through entities must be taken into account when testing whether the economic effect of an allocation is substantial within the meaning of section 704(b). Through an example, the final regulations also reiterate the effect of other provisions, such as section 482, upon the tax treatment of a partner with respect to the partner’s distributive share under section 704(b)
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