Capital Interest Allocations

Capital Interest Allocations means, with respect to a partnership, allocations of long-term capital gain or loss made under the partnership agreement to an API Holder and to Unrelated Non-Service Partners based on such partners' capital contributed with respect to the partnership to the extent such allocations otherwise meet the requirements of 1.1061-3. With respect to other Passthrough Entities, the principles of this definition apply.


26 CFR § 1.1061-1

Scoping language

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