Finance et marchés · 23/01/20201 min de lecture
Transfers of Certain Property by U.S. Persons to Partnerships With Related Foreign Partners
Traduction automatique locale · Langue originale de la source
Résumé
This document contains final regulations that provide guidance applicable to transfers of appreciated property by U.S. persons to partnerships with foreign partners related to the transferor. Specifically, when a U.S. person transfers appreciated property to a partnership with a foreign partner related to the transferor, the regulations override the general nonrecognition rule unless the partnership adopts the remedial allocation method and certain other requirements are satisfied. The regulations affect U.S. partners in domestic or foreign partnerships.