Final regulations on partnership contributions and distributions will snare the unsuspecting

Article Abstract:

Congress and the Treasury Dept. have demonstrated their concern over taxpayers entering abusive contribution and distribution transactions to bring about nontaxable sale transactions by coming up with tax rules governing partnerships. The Section 704(c)(1)(B) Final Regulations which will significantly control abusive partnership tax schemes will entrap innocent business partnerships. A detailed analysis of these regulations and several examples on how they operate are presented.

Interpretation and construction, Partnership, Partnerships

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The anti-abuse rule and the basis rules of the final Section 737 regulations

Article Abstract:

The striking distinction between the anti-abuse rule and the basis rules of the final Section 737 tax guidelines is presented. The anti-abuse rule is ambiguous while the basis rules are clear and automatic. A majority of tax practitioners are worried that the anti-abuse policy will be misused by the IRS in unwarranted circumstances. Hence, the anti-abuse policy holds the possibility of becoming a lightning pole for future dispute if the policy is used intensively by the IRS.

Tax Law, Public Finance Activities, Tax Management, Tax accounting, United States. Internal Revenue Service

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The Anti-Abuse Rule and the Basis Rules of the Final Section 737 Regulations

Article Abstract:

This paper analyses the anti-abuse rule whereby the IRS may, basing on all the facts and circumstances, recast any transaction for federal tax purpose as appropriate to achieve tax results consistent with the purpose of Section 737 of the Internal Revenue Code.

United States, Statistical Data Included, Tax revenue estimating

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