Posted by Todd Keator, Todd Lowther, and Jessica Kirk
The IRS has issued guidance on disguised sales of property within partnerships. Generally, partners may contribute property to, and receive distributions from, a partnership without recognizing a gain or loss. But in certain circumstances, the Sections 707 and 752 regulations will characterize a contribution and related distribution as a disguised sale or exchange requiring the “selling” partner to recognize a gain or loss.
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