A partner’s distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this chapter, be determined by the partnership agreement.

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.

2014年1月31日 · Sec. 704 (c) is intended to prevent the shifting of tax items among partners when a partner contributes property with a fair market value different from its tax basis to a partnership. Under Sec. 704 (c), the allocation of tax items for property contributed with a built-in gain or loss must be made using a reasonable method.

2025年1月24日 · Understanding a partner’s share of net unrecognized Section 704 (c) gain or loss is critical for tax compliance and strategic financial planning within partnerships. This …

2017年8月15日 · From a practical perspective, tax advisors must be aware that any time a partner contributes property that has a different tax basis and FMV -- as A has done in our example -- Section 704 (c) will...

2020年2月3日 · Many partnerships will need to compute and report “tax basis capital” and “unrecognized section 704 (c) gain or loss” in 2019. Calculating this information may require substantial time and effort, and this may affect your ability to …

Under section 704(c), a partnership must make tax allocations concerning property with a built-in gain (or loss) using a reasonable method that is consistent with the purpose of that section.

Section 704(c) requires the partnership to make allocations of income, gain, loss or expense so that the BIG/BIL in contributed property is borne by the contributing partner, and is not shifted to the non-contributing partner

3 天之前 · IRC section 704 is the heartbeat of the partnership rules. Under this section, a partner’s distributive share of items such as income, gain, loss, or deduction is determined by the partnership agreement.

2022年5月17日 · Very simply, 704 (c) is the difference between 704 (b) capital and tax capital. 704 (b) "book" capital is a partners economic interest in the partnership. Tax capital is a partners share of the underlying net tax basis of the assets in the partnership.