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Article: REG-100798-06
- Article from:
- United States. Internal Revenue Bulletin
- Article date:
- June 9, 2008
- Author:
CopyrightCopyright Superintendent of Documents Jun 9, 2008. Provided by ProQuest LLC. (Hide copyright information)
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Notice of Proposed Rulemaking
Contributed Property
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Notice of Proposed Rulemaking.
SUMMARY: These proposed regulations under section 704(c) of the Internal Revenue Code (Code) provide that the section 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners. The proposed regulations further provide that a section 704(c) allocation method cannot be used to achieve tax results inconsistent with the intent of subchapter K of the Code. The proposed regulations affect partnerships and their partners.
DATES: Written or electronic comments and ...