For purposes of subparagraph (C), the term “built-in loss” means the excess of the adjusted basis of the property (determined without regard to subparagraph (C)(ii)) over its fair market value at the time of contribution.

Sec. 704(c) aims to prevent the shifting of gain, loss, or other tax attributes among partners by mandating certain adjustments to partners' capital accounts.

2017年8月15日 · Tax Geek Tuesday is back, this time with an in-depth look at applying the principles of Section 704(c) when a partner contributes appreciated property to a partnership.

2025年1月24日 · Allocating net unrecognized Section 704(c) gain or loss among partners requires careful adherence to the partnership agreement, which specifies allocation methods. These methods must comply with Section 704(c) rules to align tax consequences with economic realities.

2020年2月3日 · The issuance of additional equity by an entity taxed as a partnership can lead to complex, and often surprising, tax results. The starting point for the analysis of an additional investment is an understanding of tax capital and 704(c) attributes of a partnership.

Pursuant to §1. 704-4(c)(4)(ii)(B), section 704(c)(1)(B) applies to the new section 704(c) gain. As the transferees of PRS2’s partnership interest in PRS1, C, D and E each succeed to $150 of new section 704(c) gain.

2021年2月1日 · Under Sec. 704 (c), a partnership must allocate income, gain, loss, and deduction with respect to property contributed by a partner in a manner that takes into account any built-in gain or loss at the time of the contribution.

2023年10月11日 · Explore the significance of the Section 704(c) allocation method in partnership agreements, its impact on a private equity firm's share of income and deductions, and its role in helping rollover sellers avoid unexpected tax bills.

2022年12月5日 · Phillip W. DeSalvo and Corey Dalton examine the core principles of section 704(c) and how the ceiling rule may result in unanticipated consequences for taxpayers; they also provide a numerical illustration of the application of the …

2024年12月30日 · Key differences between 704(c) methods. The Section 704(c) regulations provide three methods of addressing tax allocations: traditional, traditional with curative allocations, and remedial.