Final regulations regarding partnership allocations to look-through entities or members of consolidated group

The US Treasury Department and Internal Revenue Service (IRS) have published final regulations and adopted existing temporary regulations providing rules for testing whether the economic effect of a partnership allocation is substantial where the partners are look-through entities or members of a consolidated group. The regulations are issued under Section 704 of the US Internal Revenue Code (IRC), which provides rules for testing whether the economic effect of an allocation is substantial, whic…