Irc Section 761
Internal revenue code section 761 terms defined a partnership.
Irc section 761. Internal revenue code 26 usca section 761. 1 the irc 761 a election. 94 455 set out as a note under section 709 of this title.
94 455 applicable in the case of partnership taxable years beginning after dec. B complete exclusion from subchapter k 1 time for making election for exclusion. Amendment by section 213 c 3 b of pub.
Any regulations issued with respect to the amendment made by subsection a shall apply to partnerships created or organized after the date determined under section 7805 b of the internal revenue code of 1986 without regard to paragraph 2 thereof with respect to such regulations. To qualify the partnership should be characterized as follows. 110 28 amended the internal revenue code code to add section 761 f to the code.
Any unincorporated organization described in subparagraph 1 and either 2 or 3 of paragraph a of this section which wishes to be excluded from all of subchapter k must make the election provided in section 761 a not later than the time prescribed by paragraph of 1 6031 1 including extensions. An irc 761 a election allows a partnership to avoid being categorized as a partnership. Method of making a section 761 election section 1 761 2 b 2 of the treasury regulations provides that an eligible unincorporated organization must make the election provided in section 761 a in a statement attached to or incorporated in a properly executed partnership return.
31 1975 see section 213 f 1 of pub. 31 1975 see section 213 f 1 of pub. 94 455 applicable in the case of partnership taxable years beginning after dec.
Section 761 f provides special rules for a qualified joint venture qjv effective for taxable years beginning after december 31 2006. For purposes of this subtitle the term partnership includes a syndicate group pool joint venture or other unincorporated organization through or by means of which any business financial operation or venture is carried on and which is not within the meaning of. 94 455 set out as a note under section 709 of this title.