SECTION 3. DEFINITIONS
Internal Revenue Bulletin 2007-40 · 2026-10-03 edition · updated 2026-10-04 · United States
- Qualified Partnerships. For purposes of this revenue procedure, a partnership is a Qualified Partnership if it satisfies the following requirements: (1) the
October 1, 2007 746 2007–40 I.R.B.
materially participate in the management or operations of the lower-tier partnership; and (ii) less than 5 percent of the total book value of the upper-tier partnership’s assets (including cash) as of the first day of the taxable year.
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