Irc Section 734

734 d 1 in general.

Irc section 734. Adjustment to basis of undistributed partnership property where section 754 election or substantial basis reduction. 108 357 to which such amendment relates see section 403 nn of pub. 95 600 applicable to transfers beginning after oct.

A complete liquidation of a publicly traded partnership as defined in section 7704 b of the internal revenue code of 1986 which is an existing partnership as defined in section 10211 c 2 of the revenue act of 1987 pub. 9 1975 and to sales exchanges and distributions taking place after oct. 100 203 set out as an effective date note under section 7704 of this title and.

734 d 2 regulations. However that electivity also provided planning opportunities that congress came to consider abusive. Adjustment to basis of undistributed partnership property where section 754 election or substantial basis reduction on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system.

Generally a section 734 b basis adjustment positive or negative is made only if there is a section 754 election in place for the year in which the distribution is made a downwardsection 734 b basis adjustment is mandatory if there is a substantial basis reduction a substantial basis reduction exists if the amount of the downward adjustment exceeds 250 000. Irc section 734 b click here to return to the home page. Internal revenue code 734.

109 135 set out as a note under section 26 of this title. The basis of partnership property shall not be adjusted as the result of a distribution of property to a partner unless the election provided in section 754 relating to optional adjustment to basis of partnership property is in effect with respect to such. For purposes of this section there is a substantial basis reduction with respect to a distribution if the sum of the amounts described in subparagraphs a and b of subsection b 2 exceeds 250 000.

Section 734 b adjustments can have a significant impact when a partnership has a 754 election in effect and makes a distribution to a partner or when a partner has a substantial basis reduction in connection with distribution at a time when the partnership does not have a section 754 election in effect. Effective date of 2004 amendment. 9 1975 see section 701 u 13 c of pub.