TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Thursday, August 2, 2012

Kahn: Contribution of a Built-in Loss to a Partnership

Tax AnalystsDouglas A. Kahn (Michigan), Contribution of a Built-in Loss to a Partnership, 136 Tax Notes 571 (July 30, 2012):

In 2004 Congress amended the code to prevent the use of a partnership contribution as a means of transferring a deduction for a built-in loss from one person to another. That amendment has undermined the application of the remedial method (and the traditional method with curative allocations) that the regulations provide for the allocation of a contributed built-in gain or loss, Kahn argues. He also asserts that the 2004 amendment distorts income reporting.

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