section 754 election
- Streamlining the Section 754 Election Statement
128 T.C. 192 (T.C. 2007), 21330-04, Holdings v. Commissioner of Internal Revenue
...Because the item which R adjusted was an affected item under section 6231(a)(5), I.R.C., R also issued a notice of final partnership ... 12 ] Since both Holdings 1 and Holdings 2 attached a section 754 election to their 1999 tax returns, Holdings 2 adjusted the inside basis of its ...
- 26 CFR 1.743-1 - Optional adjustment to basis of partnership property
558 U.S. 310 (2010), 08-205, Citizens United v. Federal Election Commission
...Section 311 disclaimers provide information to the electorate, McConnell, supra, at 196, 124 S.Ct. 619, 157 L.Ed.2d 491, and "insure that the voters are ...
- 26 CFR 1.708-1 - Continuation of partnership
570 U.S. 744 (2013), 12-307, United States v. Windsor
...2419. DOMA contains two. operative sections: Section 2, which has not been challenged. here, allows States to ... 2821. . . 6 North Carolina State Board of Elections,. Official Results: Primary Election of May 8, 2012,. ...
IRS Eliminates Signatures on Section 754 Elections, Offering Tax Regulatory Reform Preview (and its Complexity?)
In a notice of proposed rulemaking issued on October 11, 2017 (the “NPRM”), the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) proposed an amendment to existing regulations (the “Proposed Regulation”) under Section 754 of the Internal Revenue Code of 1986, as amended (the “Code”). The Proposed Regulation eliminates the requirement under current Treasury...
- 26 CFR 1.754-1 - Time and manner of making election to adjust basis of partnership property
Now You See It – Now You Don’t. Like Magic, the City of Portland Disallows Depreciation Deductions Otherwise Allowable as a Result of Code Section 754
Earlier this week, a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as amended (the “Code”), for purposes of computing tax under the City of Portland Business License Tax (“BLT”) and the Multnomah County Business Income Tax (“BIT”). The answer...
..., a local tax practitioner asked us whether it was true that the City of Portland no longer allows depreciation deductions resulting from an election under Section 754 of the Internal Revenue Code of 1986, as amended (the “Code”), for purposes of computing tax under the City of Portland ...
369 U.S. 186 (1962), 6, Baker v. Carr
... restraining certain state officers from conducting any further elections under it. The District Court dismissed the complaint on the grounds that ...§ 2); or is not a "case or controversy" within the meaning of that section; or the cause is not one described by any jurisdictional statute. Our ...
- 26 C.F.R. 1.755-1 - Rules for allocation of basis
561 U.S. 742 (2010), 08-1521, McDonald v. City of Chicago, Illinois
... i.e., the Equal Protection Clause, it can hardly be said that the section does no more than prohibit discrimination. If what municipal respondents ... and that it was widely distributed as a campaign document in the election of 1866). In addition, newspaper coverage suggests that the wider public ...
- IRS Eliminates Signatures On Section 754 Elections, Offering Tax Regulatory Reform Preview (And Its Complexity?)
Basis: inside out or just right?
... inside and outside basis is preserved through the mechanics of Section 704 and Section 705. Section 704 governs the determination of each ... agreement a requirement that the partnership make a Section 754 election. A Section 754 election will permit the partnership to adjust the inside ...
Acquisition planning for a tax basis step-up.
.... Acquisition of Interests in a Single-Member LLC . Absent an election to the contrary, a single-member limited liability company (LLC) is ...(11) On the other hand, if a partnership has a [section] 754 election in place, an acquisition of interests in such partnership ...
Tax Talk: Volume 10, Issue 3
... Temporary Treasury Regulation section 1.7874-8T,1 which was published on April 8, 2016 applied to domestic ... PROPOSED REGULATIONS WOULD STREAMLINE 754 ELECTION PROCESS. On October 11, 2017, the U.S. Department of the Treasury and ...
- 26 CFR 1.705-2 - Basis adjustments coordinating sections 705 and 1032
Final Opportunity Zone Regulations Provide Some Much-Needed Clarity
Section 1400Z-2, added by Public Law 115-97 (the Tax Cuts and Jobs Act), provides ... Fourth, the final regulations modify the election for choosing a 180-day investment period for a partner's distributive ...
383 U.S. 745 (1966), 65, United States v. Guest
...Pp. 753-757. (a) Section 241 includes within its coverage Fourteenth Amendment rights whether ... right of citizens to be free of private interference in federal elections. United States v. Classic , 313 U.S. 299, extended this coverage to ...
458 U.S. 747 (1982), 81-55, New York v. Ferber
...N.Y.Penal Law, Art. 263 (McKinney 1980). Section 263.05 criminalizes as a class C felony the use of a child in a sexual ... as it is to activities, such as picketing or participation in election campaigns, which have previously been categorized as involving conduct ...
Disallowance of Partnership Loss Transfers, Mandatory Basis Adjustments, Basis Reduction in Stock of a Corporate Partner, Modification of Basis Allocation Rules for Substituted Basis Transactions, Miscellaneous Provisions
... and tax return information are confidential, as required by section 6103. Background. 1. Contributions of Built-in Loss Property. Under ... of partnership property unless the partnership had a section 754 election in effect. If the partnership had a section 754 election in effect at the ...
564 U.S. 721 (2011), 10-238, Arizona Free Enter. Club's Freedom Club PAC v. Bennett
...2808] The Arizona Citizens Clean. Elections Act created a public financing system to fund the. primary and ... declarations" section of the statute; and it is the. interest universally understood ...
410 U.S. 752 (1973), 71-1371, Rosario v. Rockefeller
...Election Law § 186, which requires a voter to enroll in the party of his choice at ...Pp. 756-762. (a) Section 186 did not absolutely prohibit petitioners from voting in the 1972 ...