EYUS: Final regulations on US partner contributions to partnerships with related foreign partners have few changes from prior temporary regulations
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Executive summary
The United States (US) Internal Revenue Service (IRS) released final regulations (TD 9891) under Internal Revenue Code (IRC) Section 721(c) that continue to deny nonrecognition treatment to certain contributions of appreciated property by US persons to partnerships with related foreign partners unless the partnership satisfies specific requirements. To avoid gain recogni…
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