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Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners (US Internal Revenue Service Regulation) (IRS) (2018 Edition)

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eBook details

  • Title: Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners (US Internal Revenue Service Regulation) (IRS) (2018 Edition)
  • Author : The Law Library
  • Release Date : January 09, 2018
  • Genre: Law,Books,Professional & Technical,
  • Pages : * pages
  • Size : 358 KB

Description

The Law Library presents the complete text of the Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners (US Internal Revenue Service Regulation) (IRS) (2018 Edition).
Updated as of May 29, 2018

This document contains temporary regulations that address transfers of appreciated property by United States persons (U.S. persons) to partnerships with foreign partners related to the transferor. The regulations override the rules providing for nonrecognition of gain on a contribution of property to a partnership in exchange for an interest in the partnership under section 721(a) of the Internal Revenue Code (Code) pursuant to section 721(c) unless the partnership adopts the remedial method and certain other requirements are satisfied. The document also contains regulations under sections 197, 704, and 6038B that apply to certain transfers described in section 721. The regulations affect U.S. partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking on this subject in the Proposed Rules section of this issue of the Federal Register. The final regulations revise and add cross-references to coordinate the application of the temporary regulations.

This ebook contains:
- The complete text of the Transfers of Certain Property by U.S. Persons to Partnerships with Related Foreign Partners (US Internal Revenue Service Regulation) (IRS) (2018 Edition)
- A dynamic table of content linking to each section
- A table of contents in introduction presenting a general overview of the structure


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