Partnerships.

About Partnerships.:

A partnership's nonrecourse financing may increase a general or limited partner's (see Limited Partnership) amount at risk provided that the financing is qualified nonrecourse for both the partner and the partnership. However, the amount treated as at risk cannot be more than the total qualified nonrecourse financing at the partnership level.

U.S. and other Developed Countries International Tax Meaning

Some countries treat a partnership as a separate taxpayer and may subject it to tax on its income and losses as a corporation. Other countries do not consider a partnership to be a separate legal entity and the partnership is treated as tax transparent, with each individual partner being taxed on his share of the profits according to his interest in the partnership. Taxation of partnerships is addressed in the Commentary to Article 1 of the OECD Model.