TD 9891 (Jan. 17, 2020): Final Regs on Transfers of Appreciated Assets to Foreign Partners

The IRS has issued final regs providing guidance applicable to transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. Under the final regs, when a U.S. person transfers appreciated property to a partnership with a foreign partner related to the transferor, the regs override the general Code Sec. 721(a) nonrecognition rule unless the partnership adopts “the remedial allocation method” and certain other requirements are satisfied.

To see final regs, click TD 9891 (Jan. 17, 2020): Final Regs on Transfers of Appreciated Assets to Foreign Partners.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..

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