Under regulations prescribed by the Secretary, rules similar to the rules of paragraph (1) shall apply to contributions by a partner (using the cash receipts and disbursements method of accounting) of accounts payable and other accrued but unpaid items.

I.R.C. § 704(a) Effect Of Partnership Agreement — 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.

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.

2024年1月1日 · --A partner's distributive share of income, gain, loss, deduction, or credit (or item thereof) shall be determined in accordance with the partner's interest in the partnership (determined by taking into account all facts and circumstances), if--

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.

The TCJA adds new § 704(d)(3)(A). That section provides that charitable contributions and foreign taxes are taken into account under the basis limitation rules, thereby putting those items on par with other losses and, as a result, limiting the benefit of such items by a …

2025年1月29日 · Explore how Section 704 influences a partner's distributive share through allocation rules, special allocations, and reporting obligations. Section 704 of the Internal Revenue Code determines how income, deductions, and other tax attributes are allocated among partners in a partnership.

Under regulations prescribed by the Secretary, rules similar to the rules of paragraph (1) shall apply to contributions by a partner (using the cash receipts and disbursements method of accounting) of accounts payable and other accrued but unpaid items.

Under regulations prescribed by the Secretary, rules similar to the rules of paragraph (1) shall apply to contributions by a partner (using the cash receipts and disbursements method of accounting) of accounts payable and other accrued but unpaid items.

Official Publications from the U.S. Government Publishing Office.