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 …

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 …

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 …

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 …

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 …

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.

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 …

2024年12月30日 · The purpose of Section 704 (c) is to prevent the shifting of tax burdens among partners when property is contributed to a partnership with a fair market value that differs from …

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 …

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 …