Web(ii) For purposes of section 708(b)(1)(B), the date of the sale or exchange of a partnership interest which, of itself or together with sales or exchanges in the preceding 12 months, transfers an interest of 50 percent or more in both partnership capital and profits. Web19 Dec 2007 · Because assets held by Successor Entity include a greater than 50 percent interest in LLC, this distribution and deemed recontribution of the shares resulted in a Section 708(b)(1)(B) termination of LLC. In a Section 708(b)(1)(B) termination, LLC is deemed to have contributed its assets to a new partnership in exchange for an interest in …

26 U.S. Code § 708 - Continuation of partnership - Novoco

WebSee section 706 (c) (1) and paragraph (c) (1) of § 1.706-1. The date of termination is: ( i) For purposes of section 708 (b) (1) (A), the date on which the winding up of the partnership affairs is completed. ( ii) For purposes of section 708 (b) (1) (B), the date of the sale or exchange of a partnership interest which, of itself or together ... WebThe new language permits an IRC Section 721(c) partnership to use the interim closing method under IRC Section 706 without running afoul of the proportionate allocation rule for book allocations of items with respect to IRC Section 721(c) property (within the meaning of Treas. Reg. Section 1.721(c)-3(c)), even though the partnership might allocate IRC … challenger performance specs

United States: IRS Allows Continuation Of Partnership - Mondaq

Web9 Dec 2013 · Section 1.197-2(g)(2)(iv)(B) provides that in applying § 1.197-2(g)(2)(ii)(B) to a partnership that is terminated pursuant to section 708(b)(1)(B), the terminated partnership is treated as the transferor and the new partnership is treated as the transferee with respect to any section 197 intangible held by the terminated partnership immediately preceding … WebIf a partnership that has elected to amortize organizational costs under section 709(b) terminates in a transaction (or a series of transactions) described in section 708(b)(1)(B) or § 1.708-1(b)(2), the termination shall not be treated as resulting in a liquidation of the partnership for purposes of section 709(b)(2). See § 1.708-1(b)(6) for ... Webunder section 708(b)(1)(B). At the time of the sale, Property X had an adjusted tax basis of $16,000 and a book value of $16,000 (original $20,000 tax basis and book value reduced by $4,000 of depreciation). In addition, A and B each had a capital account balance of $8,000 happy holidays banner images