Internal Revenue Bulletin:  2008-26 

June 30, 2008 

ADMINISTRATIVE


Announcement 2008-58 Announcement 2008-58

These documents contain corrections to final regulations (T.D. 9398, 2008-24 I.R.B. 1143) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) of the Code where partners are look-through entities or members of a consolidated group. The regulations clarify the application of section 704(b) to partnerships the interests of which are owned by look-through entities and members of consolidated groups and, through an example, reiterate the effect of other provisions of the Code on partnership allocations.

Announcement 2008-59 Announcement 2008-59

These documents contain corrections to final regulations (T.D. 9398, 2008-24 I.R.B. 1143) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) of the Code where partners are look-through entities or members of a consolidated group. The regulations clarify the application of section 704(b) to partnerships the interests of which are owned by look-through entities and members of consolidated groups and, through an example, reiterate the effect of other provisions of the Code on partnership allocations.


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