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Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners; Correction

tax-irs · IRS · Rule · Published 2017-09-05 · Effective 2017-09-05 · 82 FR 41885

Document

Document number
2017-18691
Federal Register citation
82 FR 41885
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations; correcting amendment.
Category
tax-irs
Sub-agency
IRS
Publication date
2017-09-05
Effective date
2017-09-05
Treasury docket
TD 9814

Abstract

This document contains corrections to the temporary regulations (T.D. 9814) that were published in the Federal Register on Thursday, January 19, 2017 (82 FR 7582). The regulations address transfers of appreciated property by United States 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.

Source

Authoritative
Federal Register document
Machine
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