Prop. Treas. Reg. § 1.743-1 Optional adjustment to basis of partnership property.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 743 · Would amend § 1.743-1

Par. 6. Section 1.743-1 is amended by adding paragraphs (d)(4) and (j)(7) to read as follows:

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(d) * * *

(4) Coordination with derived basis. See § 1.961-5(d) for a rule coordinating the application of this paragraph (d) with derived basis that transfers to a transferee.

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(j) * * *

(7) Covered distributions treated as previously taxed earnings and profits. See § 1.961-4(c)(2)(iii) for rules regarding the use of a positive basis adjustment under section 743(b) upon the receipt of a covered distribution that is treated as previously taxed earnings and profits with respect to certain direct or indirect partners of the partnership.

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