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- 26 CFR § 1. 707-3 - LII Legal Information Institute
This section and §§ 1 707-4 through 1 707-9 apply to contributions and distributions of property described in section 707 (a) (2) (A) and transfers described in section 707 (a) (2) (B) of the Internal Revenue Code
- Internal Revenue Service, Treasury §1. 707 - GovInfo
A lating guaranteed payment for capital made to a partner is not treated as part of a sale of property under §1 707–3(a) (re-lating to treatment of transfers as a to transfers made within two years of each other), a transfer of money to a partner that is character-ized by the parties as a preferred re-turn and that is reasonable (within the
- eCFR :: 26 CFR Part 1 - Partners and Partnerships
Disguised sales of property to partnership; special rules applicable to guaranteed payments, preferred returns, operating cash flow distributions, and reimbursements of preformation expenditures Disguised sales of property to partnership; special rules relating to liabilities Disguised sales of property by partnership to partner; general rules
- Exempt organizations Treasury regulations - Internal Revenue Service
These final and temporary regulations amend current regulations to allow the Commissioner of Internal Revenue to adopt a streamlined application process that eligible organizations may use to apply for recognition of tax-exempt status under section 501 (c) (3)
- eCFR :: 26 CFR 1. 707-3 -- Disguised sales of property to partnership . . .
This section and §§ 1 707-4 through 1 707-9 apply to contributions and distributions of property described in section 707 (a) (2) (A) and transfers described in section 707 (a) (2) (B) of the Internal Revenue Code
- eCFR :: 26 CFR 1. 703-1 -- Partnership computations.
§ 1 703-1 Partnership computations (a) Income and deductions (1) The taxable income of a partnership shall be computed in the same manner as the taxable income of an individual, except as otherwise provided in this section
- 26 CFR § 1. 704-3 - LII Legal Information Institute
§ 1 704-3 Contributed property (a) In general — (1) General principles The purpose of section 704 (c) is to prevent the shifting of tax consequences among partners with respect to precontribution gain or loss
- Section 707 Regarding Disguised Sales, Generally - Federal Register
For any transaction with respect to which all transfers that are part of a sale of an item of property occur after April 24, 1991, but before October 5, 2016, §§ 1 707-3 through 1 707-6 as contained in 26 CFR part 1 revised as of April 1, 2016, apply
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