Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners
other · IRS · Rule · Published 2020-01-23 · Effective 2020-01-17 · 85 FR 3833
Document
Document number
2020-00383
Federal Register citation
85 FR 3833
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2020-01-23
Effective date
2020-01-17
Treasury docket
TD 9891
Abstract
This document contains final regulations that provide guidance applicable to transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. Specifically, when a U.S. person transfers appreciated property to a partnership with a foreign partner related to the transferor, the regulations override the general nonrecognition rule unless the partnership adopts the remedial allocation method and certain other requirements are satisfied. The regulations affect U.S. partners in domestic or foreign partnerships.