§ 465(c)(7)(D)(i)

clause (i) conditions met

UNDECIDED

0 of 2 settled

  1. 1

    § 465(c)(7)(D)(i)

    ALL OF

    In the case of an active business of a partnership, if—

    “In the case of an active business of a partnership,” Opening words
    “the taxpayer is a qualified corporate partner in the partnership, and” § 465(c)(7)(D)(i)(I) needs Step 2 a qualified corporate partner UNDECIDED
    “during the entire 12-month period ending on the last day of the partnership’s taxable year, there was at least 1 full-time employee of the partnership (or of a qualified corporate partner) substantially all the services of whom were in the active management of such business,” § 465(c)(7)(D)(i)(II)

    “Substantially” implies facts and circumstances. No regulation cites this provision (eCFR, Oct 19, 2026)

  2. 2

    § 465(c)(7)(D)(ii)

    a qualified corporate partner

    ALL OF

    For purposes of clause (i), the term “qualified corporate partner” means any corporation if—

    “any corporation” Opening words
    “such corporation is a general partner in the partnership,” § 465(c)(7)(D)(ii)(I)
    “such corporation has an interest of 10 percent or more in the profits and losses of the partnership, and” § 465(c)(7)(D)(ii)(II)
    “such corporation has contributed property to the partnership in an amount not less than the lesser of $500,000 or 10 percent of the net worth of the corporation.” § 465(c)(7)(D)(ii)(III)