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TREAS/IRS | RIN: 1545-BM95 | Publication ID: Fall 2016 |
Title: Transfers of Property to Partnerships With Related Foreign Partners | |
Abstract:
The proposed regulations will implement Notice 2015-54, which requires partners contributing appreciated property to partnerships with related foreign partners to comply with certain requirements in order to not recognize gain on the contribution under section 721(a). |
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Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Proposed Rule Stage |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1 | |
Legal Authority: 26 U.S.C. 721(c) 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-127203-15 Drafting Attorney: Ryan Bowen (202) 317-6937 Reviewing Attorney: Jason T. Smyczek (202) 317-6937 Treasury Attorney: Brenda Zent (202) 622-6894 and Elena Virgadamo (202) 622-2008 CC:INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Agency Contact: Ryan Bowen Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6937 Fax:202 317-4922 Email: ryan.bowen@irscounsel.treas.gov |