These documents contain corrections to final regulations (T.D. 9398, 2008-24 I.R.B. 1143) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) of the Code where partners are look-through entities or members of a consolidated group. The regulations clarify the application of section 704(b) to partnerships the interests of which are owned by look-through entities and members of consolidated groups and, through an example, reiterate the effect of other provisions of the Code on partnership allocations.

These documents contain corrections to final regulations (T.D. 9398, 2008-24 I.R.B. 1143) providing rules for testing whether the economic effect of an allocation is substantial within the meaning of section 704(b) of the Code where partners are look-through entities or members of a consolidated group. The regulations clarify the application of section 704(b) to partnerships the interests of which are owned by look-through entities and members of consolidated groups and, through an example, reiterate the effect of other provisions of the Code on partnership allocations.