For section 704(c) property subject to amortization, depletion, depreciation, or other cost recovery, the allocation of deductions attributable to these items takes .

The rules of sections 704(c)(1)(B), 731, 737, and 751 apply before the rules .

Apr 1, 2004 – 704(c) property." Certain tax items (e.g., taxable gain or .

by L Cunningham - 1996 - Cited by 21 - Related articles

Definition of tax depreciation in the Financial Dictionary - by Free online English . What is tax depreciation? . 704(c) by Williams, Elizabeth S. / The Tax Adviser .

On December 27, 1994, the Treasury issued final §704(c) regulations for the .

Final regulations under §704(c), which apply to partnerships, were released December 20, 1993. These regulations apply to appreciated or depreciated .

Mar 18, 2011 – When a partner contributes appreciated or depreciated .

704(c),(3) the statute generally required only that precontribution gains or .

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Depreciation Allocation Under § 704(c). Regulations require that all partners ( other than the contributing partner) be allocated depreciation based upon the fair .

Sep 5, 2008 – "The goal of IRC section 704(c) is to prevent the shifting of tax . loss, and deductions) with respect to appreciated or depreciated property .

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If a partnership has multiple section 704(c) layers, how should tax depreciation, depletion, amortization and gain or loss be allocated between the layers? .

Aug 18, 2006 – L.108-357, amended Sec.704(c)(1) added a new subparagraph (C). . distributive share of items described in section 702(a), depreciation, .

May 1, 1997 – 704(c) allocation. The general rule for depreciation of contributed property by a partnership is that the partnership continues the contributing .

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Jump to Issue: IRC section 704(c) and Depreciable Property‎: Note: Without IRC section 704(c), Al and Betty, . would share the tax depreciation equally. .

3 posts - 2 authors - Last post: Jun 28, 2006Allocation of depreciation to Partner B = $30000. Is that correct? Thanks for your . is correct. The 704(c) allocation would continue for 5 years. .

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Aug 1, 2011 – Section 704(c) sets forth rules which govern the allocation of the tax . depreciation, or gain or loss allocated to the partners cannot exceed the .

. taxpayers would be precluded from deducting depreciation , for example .

704(c) variation") by means of certain (1) special allocations of depreciation away from the property-contributing partner to the non-property contributing partner .

Mar 4, 2009 – Section 704(c) gain after Year 1 depreciation is reduced to $540000 (book basis of $900000 less tax basis of $360000). Assuming no debt .

Apr 15, 1999 – Pursuant to Section 704(c), income, gain, loss and deduction attributable to appreciated or depreciated property that is contributed to a .

ABC uses the traditional method of making section 704(c) allocations described in § 1.704-3(b) with respect to Property A. (ii) Property A is depreciated using the .

May 1, 1997 – Because there is no S corporation equivalent to Sec. 704(c), the results from contributing appreciated or depreciated Depreciated may refer to: .

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Feb 1, 1999 – straight-line method of depreciation . GMP has made Sec. 704 .

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Second, for property subject to depreciation or other cost recovery, the .

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May 1, 1997 – 704(c), the results from contributing appreciated or .

See §1.704–4(e)(1) for a rule in the context of section 704(c)(1)(B). . . has book depreciation of $3000 per year (10 percent of the $30000 book basis in Property .

Section 704(c) applies any time a partner contributes appreciated or depreciated property to a partnership or when a new partner is admitted to a partnership. .

by GJ MARICH - 1986 - Cited by 48 - Related articles

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At the end of year 1, the LLC had $200 of depreciation which was all allocated to . Section 704(c) dictates that income, gain, loss, or deduction attributable to .

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Jump to Issue: IRC section 704(c) and Depreciable Property‎: Note: Without IRC section 704(c), Al and Betty, . would share the tax depreciation equally. .

704(c)(2) to allocate the depreciation and the built-in gain or loss to take account of the variation between the partnership's basis in the property and its FMV at .

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704c allocations causes tax depreciation or amortization attributable to such property to be specially allocated between the contributing and .

For section 704(c) property subject to amortization, depletion, depreciation .

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