Partner-Level Tax Elections

§ 703. Partnership computations(a) Income and deductionsThe taxable income of a partnership shall be computed in the same manner as in the case of an individual except that—(1) the items described in section 702(a) shall be separately stated, and (2) the following deductions shall not be allowed to the partnership:(A) the deductions for personal exemptions provided in section 151, (B) the deduction for taxes provided in section 164(a) with respect to taxes, described in section 901, paid or accrued to foreign countries and to possessions of the United States, (C) the deduction for charitable contributions provided in section 170, (D) the net operating loss deduction provided in section 172, (E) the additional itemized deductions for individuals provided in part VII of subchapter B (sec. 211 and following), and (F) the deduction for depletion under section 611 with respect to oil and gas wells. (b) Elections of the partnershipAny election affecting the computation of taxable income derived from a partnership shall be made by the partnership, except that any election under—(1) subsection (b)(5) or (c)(3) of section 108 (relating to income from discharge of indebtedness), (2) section 617 (relating to deduction and recapture of certain mining exploration expenditures), or (3) section 901 (relating to taxes of foreign countries and possessions of the United States), shall be made by each partner separately. (Aug. 16, 1954, ch. 736, 68A Stat. 240; Pub. L. 89–570, § 2(b), Sept. 12, 1966, 80 Stat. 764; Pub. L. 91–172, title V, § 504(c)(3), Dec. 30, 1969, 83 Stat. 633; Pub. L. 92–178, title III, § 304(c), Dec. 10, 1971, 85 Stat. 523; Pub. L. 94–12, title V, § 501(b)(3), Mar. 29, 1975, 89 Stat. 53; Pub. L. 94–455, title XIX, § 1901(b)(21)(F), title XXI, § 2115(c)(2), Oct. 4, 1976, 90 Stat. 1798, 1909; Pub. L. 95–30, title I, § 101(d)(10), May 23, 1977, 91 Stat. 134; Pub. L. 96–589, § 2(e)(1), Dec. 24, 1980, 94 Stat. 3396; Pub. L. 99–514, title V, § 511(d)(2)(B), title VII, § 701(e)(4)(E), Oct. 22, 1986, 100 Stat. 2249, 2343; Pub. L. 100–647, title I, § 1008(i), Nov. 10, 1988, 102 Stat. 3445; Pub. L. 103–66, title XIII, § 13150(c)(9), Aug. 10, 1993, 107 Stat. 448.)