For purposes of subparagraph (C), the term “built-in loss” means the excess of the adjusted basis of the property (determined without regard to subparagraph (C)(ii)) over its fair market value at …

2014年1月31日 · 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.

2025年1月24日 · Allocating net unrecognized Section 704(c) gain or loss among partners requires careful adherence to the partnership agreement, which specifies allocation methods. These …

2017年8月15日 · Tax Geek Tuesday is back, this time with an in-depth look at applying the principles of Section 704(c) when a partner contributes appreciated property to a partnership.

2020年2月3日 · The issuance of additional equity by an entity taxed as a partnership can lead to complex, and often surprising, tax results. The starting point for the analysis of an additional …

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 …

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.

Pursuant to §1. 704-4(c)(4)(ii)(B), section 704(c)(1)(B) applies to the new section 704(c) gain. As the transferees of PRS2’s partnership interest in PRS1, C, D and E each succeed to $150 of …

2024年12月30日 · Key differences between 704(c) methods. The Section 704(c) regulations provide three methods of addressing tax allocations: traditional, traditional with curative …

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 …