INCOME TAX

REG-101552-24, page 741. The proposed regulations would provide certain exceptions to the existing regulations regarding elections by certain unincorporated organizations to be excluded from the application of otherwise applicable partnership tax rules. These exceptions would apply to certain unincorporated organizations owned, in full or in part, by one or more tax-exempt organizations, the District of Columbia, State and local governments, Indian Tribal governments, Alaska Native Corporations, the Tennessee Valley Authority, rural electric cooperatives or certain agencies or instrumentalities. Such owners would be permitted to make elective payment elections under section 6417(a) with respect to certain property held by the unincorporated organization, provided that certain requirements are met.