The taxable income of an electing large partnership shall be computed in the same manner as in the case of an individual except that—
(A)the items described in section
772(a) shall be separately stated, and
(B)the modifications of subsection (b) shall apply.
All elections affecting the computation of the taxable income of an electing large partnership or the computation of any credit of an electing large partnership shall be made by the partnership; except that the election under section
901, and any election under section
108, shall be made by each partner separately.
(3) Limitations, etc.
(A) In general
Except as provided in subparagraph (B), all limitations and other provisions affecting the computation of the taxable income of an electing large partnership or the computation of any credit of an electing large partnership shall be applied at the partnership level (and not at the partner level).
(B) Certain limitations applied at partner level
The following provisions shall be applied at the partner level (and not at the partnership level):
68 (relating to overall limitation on itemized deductions).
465 (relating to at risk limitations).
469 (relating to limitation on passive activity losses and credits).
(iv)Any other provision specified in regulations.
(4) Coordination with other provisions
Paragraphs (2) and (3) shall apply notwithstanding any other provision of this chapter other than this part.
(b) Modifications to determination of taxable income
In determining the taxable income of an electing large partnership—
(1) Certain deductions not allowed
The following deductions shall not be allowed:
(A)The deduction for personal exemptions provided in section
(B)The net operating loss deduction provided in section
(C)The additional itemized deductions for individuals provided in part VII of subchapter B (other than section
(2) Charitable deductions
In determining the amount allowable under section
170, the limitation of section
170(b)(2) shall apply.
(3) Coordination with section
In lieu of applying section
70 percent of the amount of the miscellaneous itemized deductions shall be disallowed.
(c) Special rules for income from discharge of indebtedness
If an electing large partnership has income from the discharge of any indebtedness—
(1)such income shall be excluded in determining the amounts referred to in section
(2)in determining the income tax of any partner of such partnership—
(A)such income shall be treated as an item required to be separately taken into account under section
(B)the provisions of section
108 shall be applied without regard to this part.
The table below lists the classification updates, since Jan. 3, 2012, for this section. Updates to a broader range of sections may be found at the update page for containing chapter, title, etc.
The most recent Classification Table update that we have noticed was Tuesday, August 13, 2013
An empty table indicates that we see no relevant changes listed in the classification tables. If you suspect that our system may be missing something, please double-check with the Office of the Law Revision Counsel.
Description of Change
Statutes at Large
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