Avoiding minimum gain recapture under the final Section 704(b) regulations

Article Abstract:

The IRS has issued the final regulations under IRC 704(b) dealing with how to allocate deductions from partnership nonrecourse debt. These regulations tried to conform IRC 704(b) with the IRC 752 rules on the allocation of partnership liabilities, but they were less detailed than the 1988 temporary rules. As a result, the mandatory minimum chargeback rules can make partners' income subject to premature recognition for common partnership financial transactions. Revenue rulings and possibly amended regulations should eventually remedy this situation.

Finance, Partnership, Partnerships

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Big relief and little grief for real estate under TRA '97

Article Abstract:

Provisions of the Taxpayer Relief Act of 1997 which affect the real estate industry are generally favorable. Beneficial new treatments in the areas of capital gains and the alternative minimum tax are provided for those who own real estate directly or through pass-through entities. Many other areas of the industry are affected including principal residences, real estate investment trusts, partnerships, and involuntary conversions.

United States, House selling, Home selling, Capital gains tax

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The disguised sale question under the Service's final regulations

Article Abstract:

The IRS has issued the final disguised sale regulations according to IRC 707. The purpose of these regulations is to keep taxpayers from evading or inappropriately deferring the taxation of a real estate sale. They cover transfers listed in IRC 707(a)(2)(B) and distributions and contributions listed in IRC 707(a)(2)(A). The regulations deal with real property transactions between partnerships and partners.

Transfer (Law)

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