26 CFR 301.6223(c)-1 - Additional information regarding partners furnished to the Internal Revenue Service.

§ 301.6223(c)-1 Additional information regarding partners furnished to the Internal Revenue Service.

(a)In general. In addition to the names, addresses, and profits interests as shown on the partnership return, the Internal Revenue Service will use additional information as provided in this section for purposes of administering subchapter C of chapter 63 of the Internal Revenue Code.

(b)Procedure for furnishing additional information -

(1)In general. Any person may furnish additional information at any time by filing a written statement with the Internal Revenue Service. However, the information contained in the statement will be considered for purposes of determining whether a partner is entitled to a notice described in section 6223(a) only if the Internal Revenue Service receives the statement at least 30 days before the date on which the Internal Revenue Service mails the notice to the tax matters partner. Similarly, information contained in the statement generally will not be taken into account for other purposes by the Internal Revenue Service until 30 days after the statement is received.

(2)Where statement must be filed. A statement furnished under this section generally must be filed with the service center where the partnership return is filed. However, if the person filing the statement knows that the notice described in section 6223(a)(1) (beginning of an administrative proceeding) has already been mailed to the tax matters partner, the statement should be filed with the Internal Revenue Service office that mailed such notice.

(3)Contents of statement. The statement shall -

(i) Identify the partnership, each partner for whom information is supplied, and the person supplying the information by name, address, and taxpayer identification number;

(ii) Explain that the statement is furnished to correct or supplement earlier information with respect to the partners in the partnership;

(iii) Specify the taxable year to which the information relates;

(iv) Set out the corrected or additional information; and

(v) Be signed by the person supplying the information.

(c)No incorporation by reference to previously furnished documents. Incorporation by reference of information contained in another document previously furnished to the Internal Revenue Service will not be given effect for purposes of section 6223(c) or 6229(e). For example, reference to a return filed by a pass-thru partner which contains identifying information with respect to the indirect partners of that pass-thru partner is not sufficient to identify the indirect partners unless a copy of the document referred to is attached to the statement. Furthermore, reference to a prior general notification to the Internal Revenue Service that a partner who would otherwise be the tax matters partner is a debtor in a bankruptcy proceeding or has had a receiver appointed for the partner in a receivership proceeding is not sufficient unless a copy of the notification document referred to is attached to the statement.

(d)Information supplied by a person other than the tax matters partner. The Internal Revenue Service may require appropriate verification in the case of information furnished by a person other than the tax matters partner. The 30-day period referred to in paragraph (b)(1) of this section shall not begin until that verification is supplied.

(e)Power of attorney -

(1)In general. This paragraph (e) applies to powers of attorney with respect to proceedings under subchapter C of chapter 63 of the Internal Revenue Code (chapter 63C) that begin on or after January 2, 2002.

(2)Specifically for purposes of subchapter C of chapter 63 of the Internal Revenue Code. A power of attorney specifically for purposes of subchapter C of chapter 63 of the Internal Revenue Code shall be furnished in accordance with paragraph (b)(2) of this section.

(3)Existing power of attorney. A power of attorney granted to another person by a partner for other tax purposes shall not be given effect for purposes of subchapter C of chapter 63 unless the partner specifically requests that the power be given such effect in a statement furnished to the Internal Revenue Service in accordance with paragraph (b) of this section.

(f)Internal Revenue Service may use other information. In addition to the information on the partnership return and that supplied on statements filed under this section, the Internal Revenue Service may use other information in its possession (for example, a change in address reflected on a partner's return) in administering subchapter C of chapter 63 of the Internal Revenue Code. However, the Internal Revenue Service is not obligated to search its records for information not expressly furnished under this section.

(g)Effective date. Except as provided in paragraph (e)(1) of this section, this section is applicable to partnership taxable years beginning on or after October 4, 2001. For years beginning prior to October 4, 2001, see § 301.6223(c)-1T contained in 26 CFR part 1, revised April 1, 2001.

[T.D. 8965, 66 FR 50548, Oct. 4, 2001]

This is a list of United States Code sections, Statutes at Large, Public Laws, and Presidential Documents, which provide rulemaking authority for this CFR Part.

This list is taken from the Parallel Table of Authorities and Rules provided by GPO [Government Printing Office].

It is not guaranteed to be accurate or up-to-date, though we do refresh the database weekly. More limitations on accuracy are described at the GPO site.

United States Code

§ 1 - Tax imposed

§ 41 - Credit for increasing research activities

§ 42 - Low-income housing credit

§ 48 - Energy credit

§ 56 - Adjustments in computing alternative minimum taxable income

§ 82 - Reimbursement for expenses of moving

§ 108 - Income from discharge of indebtedness

§ 121 - Exclusion of gain from sale of principal residence

§ 141 - Private activity bond; qualified bond

§ 142 - Exempt facility bond

§ 143 - Mortgage revenue bonds: qualified mortgage bond and qualified veterans’ mortgage bond

§ 145 - Qualified 501(c)(3) bond

§ 147 - Other requirements applicable to certain private activity bonds

§ 165 - Losses

§ 168 - Accelerated cost recovery system

§ 216 - Deduction of taxes, interest, and business depreciation by cooperative housing corporation tenant-stockholder

§ 219 - Retirement savings

§ 245 - Dividends received from certain foreign corporations

§ 263 - Capital expenditures

§ 263A - Capitalization and inclusion in inventory costs of certain expenses

§ 448 - Limitation on use of cash method of accounting

§ 453C - Repealed. Pub. L. 100–203, title X, § 10202(a)(1), Dec. 22, 1987, 101 Stat. 1330–388]

§ 460 - Special rules for long-term contracts

§ 463 - Repealed. Pub. L. 100–203, title X, § 10201(a), Dec. 22, 1987, 101 Stat. 1330–387]

§ 468B - Special rules for designated settlement funds

§ 469 - Passive activity losses and credits limited

§ 474 - Simplified dollar-value LIFO method for certain small businesses

§ 585 - Reserves for losses on loans of banks

§ 597 - Treatment of transactions in which Federal financial assistance provided

§ 616 - Development expenditures

§ 617 - Deduction and recapture of certain mining exploration expenditures

§ 643 - Definitions applicable to subparts A, B, C, and D

§ 831 - Tax on insurance companies other than life insurance companies

§ 835 - Election by reciprocal

§ 865 - Source rules for personal property sales

§ 904 - Limitation on credit

§ 1059 - Corporate shareholder’s basis in stock reduced by nontaxed portion of extraordinary dividends

§ 1103

§ 1474 - Special rules

§ 2056 - Bequests, etc., to surviving spouse

§ 2056A - Qualified domestic trust

§ 2523 - Gift to spouse

§ 2632 - Special rules for allocation of GST exemption

§ 2652 - Other definitions

§ 3121 - Definitions

§ 3127 - Exemption for employers and their employees where both are members of religious faiths opposed to participation in Social Security Act programs

§ 4982 - Excise tax on undistributed income of regulated investment companies

§ 6011 - General requirement of return, statement, or list

§ 6033 - Returns by exempt organizations

§ 6036 - Notice of qualification as executor or receiver

§ 6037 - Return of S corporation

§ 6050M - Returns relating to persons receiving contracts from Federal executive agencies

§ 6061 - Signing of returns and other documents

§ 6081 - Extension of time for filing returns

§ 6103 - Confidentiality and disclosure of returns and return information

§ 6104

§ 6109 - Identifying numbers

§ 6111 - Disclosure of reportable transactions

§ 6112 - Material advisors of reportable transactions must keep lists of advisees, etc.

§ 6114 - Treaty-based return positions

§ 6158 - Repealed. Pub. L. 101–508, title XI, § 11801(a)(44), Nov. 5, 1990, 104 Stat. 1388–521]

§ 6223 - Partners bound by actions of partnership

§ 6230 - Additional administrative provisions

§ 6231 - Notice of proceedings and adjustment

§ 6233 - Interest and penalties

§ 6241 - Definitions and special rules

§ 6245 - Secretarial authority

§ 6311 - Payment of tax by commercially acceptable means

§ 6323 - Validity and priority against certain persons

§ 6326 - Administrative appeal of liens

§ 6343 - Authority to release levy and return property

§ 6402 - Authority to make credits or refunds

§ 6404 - Abatements

§ 6411 - Tentative carryback and refund adjustments

§ 6689 - Failure to file notice of redetermination of foreign tax

§ 7216 - Disclosure or use of information by preparers of returns

§ 7502 - Timely mailing treated as timely filing and paying

§ 7508 - Time for performing certain acts postponed by reason of service in combat zone or contingency operation

§ 7520 - Valuation tables

§ 7624 - Reimbursement to State and local law enforcement agencies

§ 7701 - Definitions

§ 7804 - Other personnel

§ 7805 - Rules and regulations

Statutes at Large

Title 26 published on 06-Feb-2018 03:56

The following are ALL rules, proposed rules, and notices (chronologically) published in the Federal Register relating to 26 CFR Part 301 after this date.

  • 2018-02-02; vol. 83 # 23 - Friday, February 2, 2018
    1. 83 FR 4868 - Centralized Partnership Audit Regime: Adjusting Tax Attributes
      GPO FDSys XML | Text
      DEPARTMENT OF THE TREASURY, Internal Revenue Service
      Notice of proposed rulemaking.
      Written or electronic comments and requests for a public hearing must be received by May 3, 2018.
      26 CFR Parts 1 and 301