§ 6046A. Returns as to interests in foreign partnerships

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

1. 1982

   Pub. L. 97–248 title IV § 405(a) · 96 Stat. 324

   Enacted · 26 U.S.C. § 6046A

   Added Pub. L. 97–248, title IV, § 405(a), Sept. 3, 1982, 96 Stat. 669

   Source evidence

   Code source credit
   Added Pub. L. 97–248, title IV, § 405(a), Sept. 3, 1982, 96 Stat. 669

   Enacted provision · exact public law section
   (a) In General.— Subpart B of part III of subchapter A of chapter 61 (relating to information concerning transactions with other persons) is amended by inserting after section 6046 the following new section: “SEC. 6046A. RETURNS AS TO INTERESTS IN FOREIGN PARTNERSHIPS. “(a) Requirement of Return.— Any United States person, except to the extent otherwise provided by regulations— “(1) who acquires any interest in a foreign partnership, “(2) who disposes of any portion of his interest in a foreign partnership, or “(3) whose proportional interest in a foreign partnership changes substantially, shall file a return. “(b) Form and Contents of Return.— Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe. “(c) Time for Filing Return.— Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return. “(d) Cross Reference.— “For provisions relating to penalties for violations of this section, see sections 6679 and 7203.”

2. 1997

   Pub. L. 105–34 § 1143(a)(1) · 111 Stat. 788

   Inserted · 26 U.S.C. § 6046A(a)

   Pub. L. 105–34, § 1143(a)(1), inserted at end “Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.”

   Source evidence

   Code amendment note
   Subsec. (a). Pub. L. 105–34, § 1143(a)(1), inserted at end “Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.”

   Enacted provision · exact public law section
   (1) In general.— Subsection (a) of section 6046A (relating to returns as to interests in foreign partnerships) is amended by adding at the end the following new sentence: “Paragraphs Applicability. (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.”.

   Effective date note
   Pub. L. 105–34, title XI, § 1143(c), Aug. 5, 1997, 111 Stat. 984, provided that: “The amendments made by this section [amending this section and section 6679 of this title] shall apply to transfers and changes after the date of the enactment of this Act [Aug. 5, 1997].”

3. 1997

   Pub. L. 105–34 § 1143(a)(2) · 111 Stat. 788

   1. Added · 26 U.S.C. § 6046A(d); 26 U.S.C. § 6046A(e)

      Pub. L. 105–34, § 1143(a)(2), added subsec. (d)

   2. Redesignated · 26 U.S.C. § 6046A(d); 26 U.S.C. § 6046A(e)

      Pub. L. 105–34, § 1143(a)(2), redesignated former subsec. (d) as (e)

   Source evidence

   Code amendment note
   Subsecs. (d), (e). Pub. L. 105–34, § 1143(a)(2), added subsec. (d) and redesignated former subsec. (d) as (e).

   Enacted provision · exact public law section
   (2) 10-percent interest.— Section 6046A is amended by redesignating subsection (d) as subsection (e) and by inserting after subsection (c) the following new subsection: “(d) 10-Percent Interest.— For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section 6038(e)(3)(C)”.

   Effective date note
   Pub. L. 105–34, title XI, § 1143(c), Aug. 5, 1997, 111 Stat. 984, provided that: “The amendments made by this section [amending this section and section 6679 of this title] shall apply to transfers and changes after the date of the enactment of this Act [Aug. 5, 1997].”

4 of 4 references resolved to an enrolled provision