Contributions of property to a partnership: the proposed Section 704(c) regulations

Article Abstract:

The Internal Revenue Service's planned regulations under Section 704(c) covering precontribution gain or loss on property made part of a partnership have a number of advantages and disadvantages. They are not yet mandatory, and give guidance only under Section 704(c)(1)(A), not addressing the other subsections of Section 704(c). They are based on the principle that a reasonable method must be consistently applied when allocating any precontribution gain or loss from property made part of a partnership to the contributing partner. The main advantage is that the proposed regulations are quite easy to administer and comply with.

---

Partnership capital interests were received for services, rules CA-8 in Mark IV Pictures

Article Abstract:

The Eighth Circuit appeals court has ruled in the Mark IV Pictures v Comm'r that the promoters of newly-formed partnerships could be taxed once they had received the partnership interests. The case has wide-reaching implications, covering any situation where services are contributed to a partnership and a partnership interest received in return. It means that a service partner must be able to give details of the value of the property contributed to the partnership, and that if he cannot do so, the nonrecognition treatment of Section 721 will not be enforceable.

---

Proposed Regulations Give Some Guidance on partnership Mixing Bowl Transactions

Article Abstract:

Rules issued by the Internal Revenue Service regulating disposition of partnership assets are analyzed and asked to be further clarified.

United States, Partnerships, Statistical Data Included, Laws, regulations and rules, Economic policy, Tax evasion, United States. Internal Revenue Service, Partnership distributions

Similar abstracts:

• Abstracts: The role of competitive alternatives in the postchoice satisfaction formation process. A note on marketing and the corporate annual report: 1930-1950
• Abstracts: Trade or business property. New S corporation shareholder rules
• Abstracts: More balm for the beleaguered in latest 382 proposed regulations. New 382(1)(5) and (1)(6) regulations provide relief in certain corporate bankruptcy restructurings
• Abstracts: Policy implications of trade liberalization: the case of meat products in Taiwan and South Korea. International dry onion trade: factors affecting import demands for US dry onions
• Abstracts: Straight talk: insights from focus group leaders. Top strategic priority for the '90s: product development. Marketers' leadership skills need polishing

This website is not affiliated with document authors or copyright owners. This page is provided for informational purposes only. Unintentional errors are possible.