U.S. Code, Title 26, Internal Revenue Code

Contents:
Author: "U.S. Congress, Office of the Law Revision Counsel"

Show Summary

§ 6046a. Returns as to Interests in Foreign Partnerships

(a) Requirement of return

     Any United States person, except to the extent otherwise provided by regulations—

     (1) who acquires any interest in a foreign partnership,

     (2) who disposes of any portion of his interest in a foreign partnership, or

     (3) whose proportional interest in a foreign partnership changes substantially,

shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.

(b) Form and contents of return

     Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.

(c) Time for filing return

     Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.

(d) 10-percent interest

     For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C).

(e) Cross reference

     For provisions relating to penalties for violations of this section, see sections 6679 and 7203.

(Added Pub. L. 97–248, title IV, § 405(a), Sept. 3, 1982, 96 Stat. 669; amended Pub. L. 105–34, title XI, § 1143(a), Aug. 5, 1997, 111 Stat. 983.)

Amendments

     1997—Subsec. (a). Pub. L. 105–34, § 1143(a)(1), inserted at end "Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership."

     Subsecs. (d), (e). Pub. L. 105–34, § 1143(a)(2), added subsec. (d) and redesignated former subsec. (d) as (e).

Effective Date of 1997 Amendment

     Section 1143(c) of Pub. L. 105–34 provided that: "The amendments made by this section [amending this section and section 6679 of this title] shall apply to transfers and changes after the date of the enactment of this Act [Aug. 5, 1997]."

Effective Date

     Section 407(b) of Pub. L. 97–248 provided that: "The amendments made by section 405 [enacting this section and amending section 6679 of this title] shall apply with respect to acquisitions or dispositions of, or substantial changes in, interests in foreign partnerships occurring after the date of the enactment of this Act [Sept. 3, 1982]."

Special Rule for Certain International Satellite Partnerships

     For provision that this section is not applicable to certain international satellite partnerships, see section 406 of Pub. L. 97–248, set out as a note under section 6231 of this title.

Section Referred to in Other Sections

     This section is referred to in sections 6038B, 6501, 6679 of this title.

Contents:

Related Resources

None available for this document.

Download Options


Title: U.S. Code, Title 26, Internal Revenue Code

Select an option:

*Note: A download may not start for up to 60 seconds.

Email Options


Title: U.S. Code, Title 26, Internal Revenue Code

Select an option:

Email addres:

*Note: It may take up to 60 seconds for for the email to be generated.

Chicago: "U.S. Congress, Office of the Law Revision Counsel", "§ 6046a. Returns as to Interests in Foreign Partnerships," U.S. Code, Title 26, Internal Revenue Code in U.S. Code, Title 26, Internal Revenue Code (Washington, D.C.: Government Printing Office, 2002), Original Sources, accessed April 25, 2018, http://www.originalsources.com/Document.aspx?DocID=CJV257R18JMTSIX.

MLA: "U.S. Congress, Office of the Law Revision Counsel". "§ 6046a. Returns as to Interests in Foreign Partnerships." U.S. Code, Title 26, Internal Revenue Code, in U.S. Code, Title 26, Internal Revenue Code, Washington, D.C., Government Printing Office, 2002, Original Sources. 25 Apr. 2018. www.originalsources.com/Document.aspx?DocID=CJV257R18JMTSIX.

Harvard: "U.S. Congress, Office of the Law Revision Counsel", '§ 6046a. Returns as to Interests in Foreign Partnerships' in U.S. Code, Title 26, Internal Revenue Code. cited in 2002, U.S. Code, Title 26, Internal Revenue Code, Government Printing Office, Washington, D.C.. Original Sources, retrieved 25 April 2018, from http://www.originalsources.com/Document.aspx?DocID=CJV257R18JMTSIX.