federal_register: E8-11174

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document_number title type abstract publication_date pub_year pub_month html_url pdf_url agency_names agency_ids excerpts regulation_id_numbers
E8-11174 Contributed Property Proposed Rule These proposed regulations under section 704(c) of the Internal Revenue Code (Code) provide that the section 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of such partners. The proposed regulations further provide that a section 704(c) allocation method cannot be used to achieve tax results inconsistent with the intent of subchapter K of the Code. The proposed regulations affect partnerships and their partners. 2008-05-19 2008 5 https://www.federalregister.gov/documents/2008/05/19/E8-11174/contributed-property https://www.govinfo.gov/content/pkg/FR-2008-05-19/pdf/E8-11174.pdf Treasury Department; Internal Revenue Service 497,254 These proposed regulations under section 704(c) of the Internal Revenue Code (Code) provide that the section 704(c) anti-abuse rule takes into account the tax liabilities of both the partners in a partnership and certain direct and indirect owners of... 1545-BF28

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