Extract to table

Section 48(a)(11) requires that, with respect to the construction, alteration, or repair of any facility for which the 5× multiplier is sought, the taxpayer must ensure that not less than the applicable percentage of total labor hours are performed by qualified apprentices

Specifically, Section 48(a)(12) requires that any steel, iron, or manufactured product that is a component of the energy property must be produced in the United States, meeting the applicable percentage thresholds prescribed by the Secretary of the Treasury

General Framework Under Section 704(b) of the Code, a partner's distributive share of any item of income, gain, loss, deduction, or credit shall be determined by the partnership agreement, provided that the allocation has "substantial economic effect

" If an allocation under the partnership agreement does not have substantial economic effect, the partner's distributive share of such item shall be determined in accordance with the partner's interest in the partnership (determined by taking into account all facts and circumstances)

704-1(b)(2) provides a two-part test for determining whether an allocation has "substantial economic effect": first, the allocation must have "economic effect" (Treas

704-1(b)(2)(ii)); and second, the economic effect must be "substantial" (Treas