2014年1月31日 · 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. The regulations identify three methods that are generally reasonable: the traditional method, the traditional method with curative allocations, and the remedial method.

2017年8月15日 · It's a provision with complex application but a simple goal: to prevent a partner from contributing appreciated property to a partnership and then shifting that pre-contribution gain to a...

Section 704(c) Layers relating to Partnership Mergers, Divisions and Tiered Partnerships . Notice 2009-70 . Section 1. PURPOSE . The Internal Revenue Service invites public comments on the proper application of the rules relating to the creation …

A forward section 704(c) layer arises as a result of the contribution of built-in gain or built-in loss property to a partnership, while a reverse section 704(c) layer may be created as a result of a revaluation event as

2022年12月5日 · There are three generally accepted reasonable methods identified in the regulations to account for section 704 (c) tax allocations 2: (1) the traditional method, (2) the traditional method with curative allocations, and (3) the remedial method.

2023年10月11日 · Section 704 (c) and the underlying regulations provide that if property is contributed by a partner to a partnership, the partners’ distributive shares of income, gain, loss, and deduction, as computed for tax purposes, with respect to the property are determined by taking account of the variation between the adjusted tax basis and fair market v...

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 …

2011年8月1日 · Section 704 (c) sets forth rules which govern the allocation of the tax items of a partnership with respect to contributed property. More specifically, section 704 (c) (1) (A) addresses the...

2023年4月25日 · In 2020, the IRS issued FAA 20204201F, advising that the section 704(c) anti-abuse rule applied to the use of the gain on sale method with respect to intangible property that a U.S. partner contributed to a partnership with a related foreign partner.

Approach 3: Allocate basis among AB's assets based on the relative asset bases, allocate value in a manner that forces $450 of BIG in Building to equal earlier depreciation allocation.