DRS: 12-715(b)-1, Character of partnership items

DRS has reproduced this regulation. This is an unofficial copy. Official copies of regulations ONLY are available from the Commission on Official Legal Publications. 111 Phoenix Avenue. Enfield, CT 06082. colp@jud.state.ct.us  Copies of DRS forms and publications are available at http://www.ct.gov/drs

Conn. Agencies Regs. 12-715(b)-1.  Character of partnership items.

(a) In order that the modifications described in 12-715(a)-1 of this Part, and the passive activity loss and capital loss limitations described in 12-711(b)-6 of Part II, may be properly applied to partnership items of income, gain, loss or deduction, each of such partnership items shall have the same character for a partner for Connecticut income tax purposes as for federal income tax purposes. Where an item is not characterized for federal income tax purposes, the item shall have the same character for a partner as if realized directly from the source from which realized by the partnership or incurred in the same manner as incurred by the partnership. If a partnership item is not required to be taken into account for federal income tax purposes (such as interest on bonds of another state), the character of the item for a partner for Connecticut income tax purposes is the same as if the partner, as an individual, had realized or incurred the item directly.

(b) While this section pertains to Section 12-715(b) of the general statutes, for purposes of supplementary interpretation, as the phrase is used in Section 12-2 of the general statutes, the adoption of this section is authorized by Section 12-740(a) of the general statutes.

(Effective November 18, 1994.)