JD Supra

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the ...
JD Supra

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As ...