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Tax-Free Transfers Foreign Affiliates

Goulston & Storrs PC

New Restrictions on Transferring Appreciated Property to Partnerships With Related Foreign Partners

Goulston & Storrs PC on

The IRS issued Notice 2015-54 stating that it plans to issue regulations under Section 721(c) to ensure that U.S. taxpayers do not use partnerships to shift built-in gains to non-U.S. affiliates. In 1997 Congress authorized...more

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