26 U. S. Code § 704 - Partner’s distributive share A partner’s distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this chapter, be determined by the partnership agreement
§704 (c), Contributed Property - Income Taxes - Partners and . . . Except as provided in regulations, in determining the amount of items allocated to other partners, the basis of the contributed property in the hands of the partnership shall be treated as being equal to its fair market value at the time of contribution
Distributions of Sec. 704(c) property by an LLC - The Tax Adviser Under Sec 704 (c) (1) (B), a distribution of Sec 704 (c) property within seven years of the date of contribution requires the contributing member to recognize any remaining precontribution gain or loss on the date of such distribution
26 USC 704: Partners distributive share - House Partner's distributive share A partner's distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this chapter, be determined by the partnership agreement
IRC 704 (c) Allocations and Partnership Built-In Gains IRC Section 704 (c) governs how partnerships must allocate tax items related to property contributed by a partner This rule applies when the property’s adjusted tax basis differs from its fair market value at the time of contribution
eCFR :: 26 CFR 1. 704-4 -- Distribution of contributed property. Gain or loss recognized by the contributing partner under section 704 (c) (1) (B) and this section has the same character as the gain or loss that would have resulted if the distributed property had been sold by the partnership to the distributee partner at the time of the distribution
Part I - Internal Revenue Service Section 1 704-4(d)(2) provides that the transferee of all or a portion of the partnership interest of a contributing partner is treated as the contributing partner for purposes of § 704(c)(1)(B) and § 1 704-4 to the extent of the share of built-in gain or loss allocated to the transferee partner
Rolling Over and Section 704(c); What #8217;s the Big Deal? #x2014 . . . In other words, if a partner contributes property to a partnership where the fair market value of that property is different from the partner’s tax basis in that property, the partnership allocations made to that partner must consider that difference — the pre-contribution gain or loss