Most CRCs decide with more than one member to be taxed as partnerships and are therefore subject to federal partnership tax laws and partnership tax rules adopted by the IRS. Many enterprise agreements contain provisions for special allowances and other tax issues. These issues can be extremely complex and, in some situations, neither the members of the LLC nor their lawyers have sufficient knowledge of these issues. 32 The term “special allocation” does not appear in the code or in the cash settlement. However, that term is part of corporate law. See Willis at 10.01[2] n. 16 and 10.01. The term generally refers to a sharing of the company`s income, profits, losses, deductions or credits in a way that is not proportional to the respective interests of the partners in the partnership (as a rule, with respect to the capital contributions of the partners). To the extent that an allocation to a member under the enterprise agreement has no significant economic impact and is not in accordance with the members` interest in the LLC, this tax case is redirected to the interests of the LLC member. 11 see Regs. ABS. 1.704-1, point b) (2) (2) (h) (definition of “partnership agreement” within the meaning of Directive 704, which contains “all agreements between partners or between one or more partners and the partnership on partnership issues and responsible responsibilities of partners, whether orally or in writing, and whether they are contained in a document called partnership agreement by the partners” added to the appendix). that at the end of the company`s fiscal year, a member has a capital-deficit account greater than (i) the amount, which that member is required to recover in accordance with a provision of this agreement, and (ii) the amount that that member is considered obliged to recover, in accordance with the penultimate sets of the sections of the treasury 1.704-2 (g) (1) and 1.704-2 (5) , the items of corporate income and profit at this level are allocated as quickly as possible to each of these Member States.