SECTION 1. OVERVIEW This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue regulations under section 721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain
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Publication 721 explains how the federal income tax rules apply to civil service retirement benefits received by retired federal employees (including those disabled) or their survivors. These benefits are paid primarily under the Civil Service Retirement System (CSRS) or the Federal Employees' Retirement System (FERS).
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Generally, no gain or loss is recognized when money or unencumbered property is contributed to a partnership (Sec. 721), but this nonrecognition rule does not apply if the transaction is a sale. Disguised sale issues usually arise in the context of a property transfer from a partner to a partnership followed by a cash distribution from the ...
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