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26 U.S.C. § 6221

Determination at partnership level

United States · Title 26 — INTERNAL REVENUE CODE · Status: effective

Business & Commerce
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26 U.S.C. § 6221, Determination at partnership level, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/464085
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Any adjustment to a partnership-related item shall be determined, and any tax attributable thereto shall be assessed and collected, and the applicability of any penalty, addition to tax, or additional amount which relates to an adjustment to any such item shall be determined, at the partnership level, except to the extent otherwise provided in this subchapter. This subchapter shall not apply with respect to any partnership for any taxable year if— the election— In the case of a partner that is an S corporation— For purposes of paragraph (1)(D)(ii), the Secretary may provide for alternative identification of any foreign partners. The Secretary may by regulation or other guidance prescribe rules similar to the rules of subparagraph (A) with respect to any partners not described in such subparagraph or paragraph (1)(C).

Legislative history

The public laws that enacted or amended this section. Tallies are for the whole bill as it passed each chamber — often an omnibus covering far more than this provision — not a vote on this section alone.