Regulations on allocations relating to contributed property affect securities partnerships.

• Jurisdiction: United States
• Author: Dance, Glenn E.
• Date: 01 November 1995

On Dec. 21, 1993, proposed and temporary regulations were issued under Sec. 704(c), providing guidance on two issues not addressed in simultaneously issued final regulations that covered other aspects of the partnership-contributed property allocation rules. These two topics were the introduction of a new method of performing Sec. 704(c) allocations, called the remedial allocation method, and the creation of an exception to the normal property by property allocation rules that could be applied by certain securities partnerships.

Modification to proposed regulations made by final regulations

Remedial allocation mothod: Regs. Sec. 1.704-3(d) clarifies several ambiguities that existed in the proposed regulations with...