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.

The partnership can use any reasonable method in reporting net unrecognized section 704(c) built-in gain or loss to you. You'll be allocated unrecognized section 704(c) gain or loss if: You contributed property with FMV in excess of adjusted tax basis (built-in gain property);

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.

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...

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 …

2020年2月3日 · New Schedules K-1 dramatically change the way partner capital and other items must be reported. Many partnerships will need to compute and report “tax basis capital” and “unrecognized section 704(c) gain or loss” in 2019.

the effect of a deemed distribution under § 752(b); whether § 704(c)(1)(B) or § 737 applied to the contribution; and whether the contribution and potential distributions could result in a disguised sale under § 707(a)(2)(B). The Second Tax Opinion Letter addresses the following issues in …

Under § 704(c), a partnership must allocate income, gain, loss, and deduction with respect to property contributed by a partner to the partnership so as to take into account any variation between the adjusted tax basis of the property and its fair market

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.

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. the partnership agreement does not provide as to the partner’s distributive share of income, gain, loss, deduction, or credit (or item thereof), or.