EYUS IRS concludes anti-abuse rule under Section 704(c) triggered in asset contribution to foreign partnership
|Tax Alerts, National/Federal Taxation, L ...|United States
In a United States (US) Internal Revenue Service (IRS) Office of Chief Counsel Memorandum (FAA 20204201F), the IRS has advised that the Internal Revenue Code1 Section 704(c) anti-abuse rule applies to contributions that a US corporate taxpayer made of high-value, low-basis assets to a partnership formed with a related foreign entity. The partnership used the “traditional method,” with curativ…
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