- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
Best Answer Click here
- Mark as New
- Bookmark
- Subscribe
- Permalink
- Report Inappropriate Content
It is exactly as the reg defines it. Questions are whether the partnership has any built-in gain property other than excepted properties that were transferred, whether there is a related foreign partner by directly or indirect ownership, and whether the 80% threshold is met.
(A) A related foreign person with respect to the U.S. transferor is a direct or indirect partner in the partnership; and
(B) The U.S. transferor and related persons own 80 percent or more of the interests in partnership capital, profits, deductions, or losses.
(ii)Special rule for tiered partnerships.— A partnership described in §1.721(c)-3T(d)(1) or (2) is deemed to be a section 721(c)partnership for purposes of the gain deferral method.
(ii)Special rule for tiered partnerships.—Property described in §1.721(c)-3T(d)(1)(ii) and an interest in a partnership described in§1.721(c)-3T(d)(2)(ii) is deemed to be section 721(c) property.
Still an AllStar