The US Treasury Department and Internal Revenue Service (IRS) have published final regulations and adopted existing temporary regulations providing rules for testing whether the economic effect of a partnership allocation is substantial where the partners are look-through entities or members of a consolidated group. The regulations are issued under Section 704 of the US Internal Revenue Code (IRC), which provides rules for testing whether the economic effect of an allocation is substantial, which is the test that must be met in order for the allocation to be respected for US income tax purposes. The types of look-through entities covered by...