TREATMENT OF PASSTHROUGH PARTNERS IN TIERED STRUCTURES.

SEC. 204. TREATMENT OF PASSTHROUGH PARTNERS IN TIERED STRUCTURES. (a) In General.—Section 6226(b) is amended by adding at the end the following new paragraph: “(4) Treatment of partnerships and s corporations in tiered structures.— “(A) In general.—If a partner which receives a statement under subsection (a)(2) is a partnership or an S corporation, such partner shall, with respect to the partner’s share of the adjustment— “(i) file with the Secretary a partnership adjustment tracking report which includes such information as the Secretary may require, and “(ii)(I) furnish statements under rules similar to the rules of subsection (a)(2), or “(II) if no such statements are furnished, compute and pay an imputed underpayment under rules similar to the rules of section 6225 (other than paragraphs (2), (7), and (9) of subsection (c) thereof). “(B) Due date.—For purposes of subparagraph (A), with respect to a partner’s share of the adjustment, the partnership adjustment tracking report shall be filed, and the imputed underpayment shall be paid or statements shall be furnished, not later than the due date for the return for the adjustment year of the audited partnership. “(C) Partnership payment of tax if elected out of subchapter.—In the case of a partnership which has elected the application of section 6221(b) with respect to the taxable year of the partnership which includes the end of the reviewed year of the audited partnership, this paragraph shall apply notwithstanding such election. “(D) Audited partnership.—For purposes of this paragraph, the term ‘audited partnership’ means, with respect to any partner described in subparagraph (A), the partnership in the chain of ownership originally electing the application of this section. “(E) Treatment of trusts.—The Secretary shall prescribe such rules as may be necessary with respect to trusts which receive a statement under subsection (a)(2).” . (b) Conforming Amendments.— (1) [26 U.S.C. 6226] Section 6226(b)(1)is amended by striking “Each partner’s” and inserting “Except as provided in paragraph (4), each partner’s”. (2) Section 6226(c)(2) is amended by inserting “or which is described in subsection (b)(4)(A)(ii)(I),” after “is elected,”.