Interaction of the Final Regs. on partnership technical terminations with TRA '97

Article Abstract:

The new Final Regulations ease the procedures of evaluating a technical termination of a partnership by redefining the rules of asset allocation. The amendment of Section 732(c) by the Taxpayer Relief Act of 1997 can still restrict basis shifting opportunities regardless of the changes applied to section 708(b)(1)(B) in the Final Regulations. The final regulations derived some beneficial opportunities by removing deemed asset distributions and contributions.

Tax Law, Public Finance Activities, Interpretation and construction

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Final disguised sales regs. add clarification but leave some issues unaddressed

Article Abstract:

A study was conducted to examine the impact of final disguised sales regulations on partnership property sales. Results show that despite the issuance of final regulations, some fundamental questions regarding property sales remain unanswered. These rules, which were proposed in 1991, were accepted as final regulations in Sep 1992. Section 1. 707-9 of the rules will apply to those transaction which are considered property sales after Apr 24, 1991.

Property

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Interaction of the Final Regs. on Partnership Technical Terminations with TRA '97

Article Abstract:

This paper discusses the termination of partnerships under the Final Regulations and as affected by the passage of the Taxpayer Relief Act of 1997 which the author suggests has foreclosed or eliminated some beneficial opportunities.

United States, Partnerships, Partnership distributions

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