704(c) gain in partnership mergers

Article Abstract:

The application of Sections 704(c)(1)(A), 704(c)(1)(B) and 737 in the guidance of partnership mergers mimicking corporate 'C' reorganizations are discussed. Section 704(c)(1)(B) does not provide a partnership to partnership exception, and the regulations promulgated under Section 704(c)(1)(A) do not reach a sensible result.

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Compliance challenges faced by pass-through entities and tax administrators: the search for uniformity continues

Article Abstract:

Pass-through entities are considered as a source of revenue for the taxing jurisdictions during periods of recession and budget crisis. Tax administrators expressed concerns about the possibility that such entities are being used for one time structure deals and one time distribution of profits.

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Temporary regulations issued for mergers involving disregarded entities

Article Abstract:

Treasury and Internal Revenue Service (IRS) has issued a set of temporary regulations regarding merger involving disregarded entities. The new temporary regulations are framed by canceling the earlier proposed regulation, which are considered more complicated.

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