In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the ...
On August 6, 2015, the IRS issued Notice 2015-54 (the "Notice"), [1] which states that the IRS and Treasury Department intend to issue regulations under section 721(c) of the Internal Revenue Code of ...