2014年2月1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.

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...

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 timely file your 2019 tax returns and Schedules K-1.

2021年2月1日 · Under Sec. 704 (c), a partnership must allocate income, gain, loss, and deduction with respect to property contributed by a partner in a manner that takes into account any built-in gain or loss at the time of the contribution.

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 …

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.

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.

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 its tax basis. This is achieved by allocating more tax gain to a contributing partner and/or less tax depreciation to the contributing partner.

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 …

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.