section 754 election
Streamlining the Section 754 Election Statement
This document contains proposed amendments to the regulation relating to the requirements for making a valid election under section 754 of the Internal Revenue Code of 1986 (Code), as amended. The proposed regulation affects partnerships and their partners by removing a regulatory burden in making an election to adjust the basis of partnership property.
- 26 CFR 1.743-1 - Optional adjustment to basis of partnership property
- 26 CFR 1.708-1 - Continuation of partnership
497 U.S. 720 (1990), 88-2031, United States v. Kokinda
... Id. at 46. Pp. 725-727. . (b) Section 232.1(h)(1) must be analyzed under the standards applicable to nonpublic fora: it must be ... Soliciting alms and contributions, campaigning for election to any public office, collecting private debts, commercial soliciting and vending, and displaying ...
- 26 CFR 1.754-1 - Time and manner of making election to adjust basis of partnership property
- IRS Eliminates Signatures On Section 754 Elections, Offering Tax Regulatory Reform Preview (And Its Complexity?)
- 26 C.F.R. 1.755-1 - Rules for allocation of basis
Tax Talk: Volume 10, Issue 3
... Temporary Treasury Regulation section 1.7874-8T,1 which was published on April 8, 2016 applied to domestic entity acquisitions completed ... PROPOSED REGULATIONS WOULD STREAMLINE 754 ELECTION PROCESS. On October 11, 2017, the U.S. Department of the Treasury and the IRS published proposed ...
Basis: inside out or just right?
..., the correlation between inside and outside basis is preserved through the mechanics of Section 704 and Section 705. Section 704 governs the determination of each partner's distributive share of ... into its acquisition agreement a requirement that the partnership make a Section 754 election. A Section 754 election will permit the partnership to adjust the inside basis of its property ...
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 disregarded for federal income ...(11) On the other hand, if a partnership has a [section] 754 election in place, an acquisition of interests in such partnership results in an adjustment in ...
- 26 CFR 1.705-2 - Basis adjustments coordinating sections 705 and 1032
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
The proposed regulations provide guidance on certain provisions of the American Jobs Creation Act of 2004 and conform the regulations to statutory changes in the Taxpayer Relief Act of 1997. The proposed regulations also modify the basis allocation rules to prevent certain unintended consequences of the current basis allocation rules for substituted basis transactions. Finally, the proposed...
...Generally, tax returns and tax return information are confidential, as required by section 6103. Background. 1. Contributions of Built-in Loss Property. Under section 721(a) of the ... to adjust the basis 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 time of a transfer, ...
- 26 CFR 1.197-2 - Amortization of goodwill and certain other intangibles
487 U.S. 735 (1988), 86-637, Communications Workers of America v. Beck
... THE FOURTH CIRCUIT. Syllabus. Section 8(a)(3) of the National Labor Relations Act (NLRA) permits an employer and a union to enter into an ... fine, discipline, suspend, or expel members; the manner in which unions conduct certain elections or maintain financial records; and the extent to which they can compel contributions to insurance ...
- 26 CFR 1.701-2 - Anti-abuse rule
Uncovering the covered asset acquisition rules.
...(2) One of the most significant of these changes is the addition of new section 901(m) to the Code, which limits a taxpayer's ability to claim FTCs related to a "covered asset ... under section 338, an acquisition of an interest in a partnership for which a section 754 election is in effect, and any transaction treated as an asset acquisition under U.S. tax law and a stock ...
DTDV, LLC v. Commissioner of Internal Revenue, 032018 FEDTAX, 741-09
...P. claims further that, because D made a valid election under. I.R.C. sec. 754 with its 2000 return, it properly reduced its. reported gain ... the negligence and substantial understatement penalties. provided in section 6662. 1 In a petition postmarked January 2,. 2009 (and filed by the Court on January 8, ...
Lawyers: Give Your Clients A Business Entity Checkup
... inside basis attributable to the deceased owner will obtain a new basis if the entity has a Section 754 election in place. The election's deadline is the partnership income tax return that includes ...
Transfer Of Partnership Interest Recast Under Substance-Over-Form Doctrine
... a trust that was intended to be a qualified medical research organization described in Section 170(b)(1)(A)(iii). The partner claimed the trust owned all the shares of the corporation that were ...The latter agreement also provided that the partnership "shall make a section 754 election with respect to both the original purchase of the interest as well as for any additional amounts ...
Ending The Dreaded Basis Step-Up Addition Statute
... gross business profits whenever equity was sold in a business with an Internal Revenue Code Section 754 election, or when an IRC Section 338 election was made, to treat a stock sale as an asset sale. ...
Implications Of Recent Tax Law Developments On Private Equity Mergers And Acquisitions
... Section 754 elections - A partner's purchase of an interest in the partnership from another partner ...
- 26 CFR 1.737-1 - Recognition of precontribution gain
Key Tax Considerations For Private Equity Acquisitions
... Identifying Structuring Opportunities Through Tax Elections. 338(h)(10) Elections for Qualified Targets . An election under Section 338(h)(10) of the ...