INCOME TAX

T.D. 9869, page 438. The final regulations clarify that where a partnership is the owner of an entity that is disregarded as separate from its owner for any purpose under section 301.7701-2, the entity is not treated as a corporation for purposes of employing direct or indirect partners of the partnership that owns the entity, but instead the partners in the partnership are subject to the same self-employment rules as partners of a partnership that does not own an entity that is disregarded as an entity separate from its owner for any purpose under section 301.7701-2.