### Question
How is the term qualifying partnership defined?


### Answer
The term **qualifying partnership** is defined in *26 U.S.C. § 512* as the following:

> a partnership which—


(I) has a partnership agreement which satisfies the requirements of section 514(c)(9)(B)(vi) at all times beginning on the date of the first certification received by the partnership under subparagraph (C)(i),


(II) satisfies the requirements of subparagraphs (B)(i), (C), (D), and (E), if "qualified partnership" is substituted for "eligible taxpayer" each place it appears therein (except subparagraph (D)(iii)), and


(III) is not an organization which would be prevented from constituting an eligible taxpayer by reason of subparagraph (B)(ii)

#### Citation:
  - *26 U.S.C. § 512*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter F-Exempt Organizations > PART III-TAXATION OF BUSINESS INCOME OF CERTAIN EXEMPT ORGANIZATIONS**

