Treasury Regulations · 26 CFR
§ 301.6221(a)-1. Determination at partnership level.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 6221(a)
Cite as 26 CFR § 301.6221(a)-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- February 27, 2019 by T.D. 9844
- Issued under
- 26 U.S.C. § 6221(a)
- Length
- 262 words · about 1 min to read
- Cross-references
- cites 1 Code section and 2 regulations; cited by 1
¶(a) In general. Except as otherwise provided under subchapter C of chapter 63 of the Internal Revenue Code (subchapter C of chapter 63) and the regulations in this part, any adjustment to a partnership-related item (as defined in § 301.6241-1(a)(6)(ii)) is determined, any tax imposed by chapter 1 of the Internal Revenue Code (Code) attributable thereto is assessed and collected, and the applicability of any penalty, addition to tax, or additional amount that relates to an adjustment to any partnership-related item is determined at the partnership level under subchapter C of chapter 63.
¶(b) Legal and factual determinations at the partnership level. Except as otherwise provided under subchapter C of chapter 63, any legal or factual determinations underlying any adjustment or determination made in accordance with paragraph (a) of this section are also determined at the partnership level under subchapter C of chapter 63. For instance, determinations under this paragraph (b) include any determinations necessary to calculate the imputed underpayment or any modification of the imputed underpayment under section 6225 and the period of limitations on making adjustments under subchapter C of chapter 63.
¶(c) Applicability date—
¶(1) In general. Except as provided in paragraph (c)(2) of this section, this section applies to partnership taxable years beginning after December 31, 2017, and ending after August 12, 2018.
¶(2) Election under § 301.9100-22 in effect. This section applies to any partnership taxable year beginning after November 2, 2015, and before January 1, 2018, for which a valid election under § 301.9100-22 is in effect.
[T.D. 9844, 84 FR 6531, Feb. 27, 2019]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 301.6241-1 Definitions.
- § 301.9100-22 Time, form, and manner of making the election under section 1101(g)(4) of the Bipartisan Budget Act of 2015 for returns filed for partnership taxable years beginning after November 2, 2015 and before January 1, 2018.
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9844 (84 FR 6531)
Where it sits in 26 CFR
- Subchapter F Procedure and administration
- Part 301 Procedure and administration
- Subpart ECFR01918753cdbe68b Assessment
- In General
Nearby sections
- § 301.6213-1 Restrictions applicable to deficiencies; petition to Tax Court.
- § 301.6213-2 Omission of correct vehicle identification number.
- § 301.6215-1 Assessment of deficiency found by Tax Court.
- § 301.6221-1 Tax treatment determined at partnership level.
- § 301.6221(a)-1 Determination at partnership level.
- § 301.6221(b)-1 Election out for certain partnerships with 100 or fewer partners.
- § 301.6222-1 Partner's return must be consistent with partnership return.
- § 301.6222(a)-1 Consistent treatment of partnership items.
- § 301.6222(a)-2 Application of consistent reporting and notification rules to indirect partners.