CCA 200913047: Partnership assets were not generally attributed to a partner

Plain-English summary

Chief Counsel considered attribution of a partnership's production activity and assets to a partner. It advised that those items were attributed only in determining the partner's distributive share of partnership income, which the email linked to a redacted cost-plus amount. Partnership assets otherwise were not attributed to the partner. That remained the conclusion even if the taxpayer was treated as a manufacturer under the referenced new Subpart F principles.

Ruling snapshot

• Question: Were a partnership's assets generally attributed to a partner under the referenced Subpart F manufacturing principles?
• Outcome: Advice given: no, attribution was limited to determining the partner's distributive share of partnership income.
• Key authorities: IRC § 863; referenced Subpart F principles.

Full text (IRS public release)

ID: CCA-111213-08 Number: 200913047
Release Date: 3/27/2009
Office: ------------------
UILC: 863.02-01

From: -------------------
Sent: 11/12/2008 1:52 PM
To: -----------------
Cc: ----------------------------
Subject: [------]

ok--interesting. I looked at the partnership rules--only the activity of a partnership--i.e., production activity-
-and assets of a partnership are attributed to a partner in determining the partner's distributive share of partnership income--so that would just be the cost plus --% amount you mentioned....so partnership assets would not otherwise be attributed even if the taxpayer were to be considered to be a manufacturer under these new Sub F principles. Thanks--I will get back to you!