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