Contributions of property to a partnership: the proposed Section 704(c) regulations
Article Abstract:
The Internal Revenue Service's planned regulations under Section 704(c) covering precontribution gain or loss on property made part of a partnership have a number of advantages and disadvantages. They are not yet mandatory, and give guidance only under Section 704(c)(1)(A), not addressing the other subsections of Section 704(c). They are based on the principle that a reasonable method must be consistently applied when allocating any precontribution gain or loss from property made part of a partnership to the contributing partner. The main advantage is that the proposed regulations are quite easy to administer and comply with.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1993
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Partnership capital interests were received for services, rules CA-8 in Mark IV Pictures
Article Abstract:
The Eighth Circuit appeals court has ruled in the Mark IV Pictures v Comm'r that the promoters of newly-formed partnerships could be taxed once they had received the partnership interests. The case has wide-reaching implications, covering any situation where services are contributed to a partnership and a partnership interest received in return. It means that a service partner must be able to give details of the value of the property contributed to the partnership, and that if he cannot do so, the nonrecognition treatment of Section 721 will not be enforceable.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1993
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Proposed Regulations Give Some Guidance on partnership Mixing Bowl Transactions
Article Abstract:
Rules issued by the Internal Revenue Service regulating disposition of partnership assets are analyzed and asked to be further clarified.
Publication Name: Journal of Partnership Taxation
Subject: Business
ISSN: 0749-4513
Year: 1995
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