§ 6225(c)(5)(C)

a specified partner

UNDECIDED

0 of 4 settled

  1. 1

    § 6225(c)(5)(C)

    ALL OF

    For purposes of this paragraph, the term “specified partner” means any person if such person—

    “with respect to each taxable year of such person which is during the period beginning with the taxable year of such person in which or with which the reviewed year of such publicly traded partnership ends and ending with the taxable year of such person in which or with which the adjustment year of such publicly traded partnership ends.” Closing words
    “is a partner of the publicly traded partnership referred to in subparagraph (A),” § 6225(c)(5)(C)(i)
    “is described in section 469(a)(2), and” § 6225(c)(5)(C)(ii) needs Step 2 Taxpayer described in (a)(2) UNDECIDED
    “has a specified passive activity loss with respect to such publicly traded partnership,” § 6225(c)(5)(C)(iii)

    with respect to each taxable year of such person which is during the period beginning with the taxable year of such person in which or with which the reviewed year of such publicly traded partnership ends and ending with the taxable year of such person in which or with which the adjustment year of such publicly traded partnership ends.

  2. 2

    § 469(a)(2)

    Taxpayer described in (a)(2)

    ANY OF
    “any individual, estate, or trust”
    “any closely held C corporation” needs Step 3 Closely held C corporation UNDECIDED
    “any personal service corporation” needs Step 4 treated as personal service corporation UNDECIDED
    Research 1
  3. 3

    § 469(j)(1)

    Closely held C corporation

    ALL OF
    “any C corporation described in section 465(a)(1)(B)”
  4. 4

    § 469(j)(2)

    treated as personal service corporation

    ALL OF
    “has the meaning given such term by section 269A(b)(1)”
    “more than 10 percent of the stock (by value) in such corporation is held by employee-owners (within the meaning of section 269A(b)(2), as modified by the preceding sentence)”