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Tax Planning for Contributions of Property To Partnerships
Under the general rules of sections 721 and 731 of the Internal Revenue Code of 1986, as amended (the "Code"), contributions of property to and distributions of property from a partnership are not generally taxable to either the partnership or its partners. However, as part of the Deficit Reduction Act of 1984, Congress enacted section 707(a)(2)(B).
United States
10 Jun 2004
Revenue Ruling 98-27 and New Spin-off Control Provision in IRS Restructuring Bill
In Rev. Rul. 96-30,a subsidiary was spun off tax-free pursuant to section 355 of the Internal Revenue Code and then was acquired by an unrelated corporation in a tax-free reorganization in which the subsidiary's former shareholders received 25% of the acquirer's stock.
United States
7 Apr 2004
New Temporary Section 355(e) Regulations – A Vast Improvement
In 1997, Congress enacted the Taxpayer Relief Act of 1997, which added section 355(e) to the Internal Revenue Code. Under section 355(e), the so-called anti-Morris Trust provision, a distributing corporation will recognize gain if one or more persons acquire, directly or indirectly, 50 percent or more of the stock (measured by vote or value) of the distributing or any controlled corporation as "part of a plan (or series of related transactions)" (referred to herein as a "plan&quo
United States
19 Mar 2004
Current Developments in Tax-Free And Taxable Acquisitions And Separations
Step Transaction and COBE Issues are discussed in this article.
United States
16 Mar 2004
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