Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Passive Income For Less Than 10% Limited Partner (Chart)

2024-10-13

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Today we published a chart of the example in Treas. Reg. §1.904-4(n)(4). The example shows that a less than 10% limited partner in a partnership has passive category income, even if the income earned through the partnership was general category income.

Tags: 901 Foreign Tax Credits, Charts - Situational Charts