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.