In the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under sections 197, 704, 721(c), and 6038B of the Internal Revenue Code (Code) that address transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. The temporary regulations affect U.S. partners in domestic or foreign partnerships. The text of the temporary regulations also serves as the text of these proposed regulations.
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Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners
In the Rules and Regulations section of this issue of the Federal Register, temporary regulations are being issued under sections 197, 704, 721(c), and 6038B of the Internal Rev...
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82 FR 6368
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“Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners,” thefederalregister.org (January 19, 2017), https://thefederalregister.org/documents/2017-01048/transfers-of-certain-property-by-u-s-persons-to-partnerships-with-related-foreign-partners.