Partner X has an abundant amount of foreign tax credits. Which of the following
ID: 2547831 • Letter: P
Question
Partner X has an abundant amount of foreign tax credits. Which of the following would not be considered as an example of a shifting allocation?
A. Allocations of all business credits to X and all foreign credits to the remaining partners B. Allocations of all capital gains to X and an equal amount of capital losses to the remaining partners C. Allocations of all foreign income to X and all capital gains to the remaining partners D. Allocations of all foreign income to X and an equal amount of ordinary income to the remaining partnersExplanation / Answer
Answer : B) Allocations of all capital gains to X and an equal amount of capital losses to the remaining partners is not considered as an example of a shifting allocation.