JD Supra

IRS appears to walk back disregard of certain accounting method changes in proposed section 965 regulations–does it make a difference?

On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the ...
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 ...