Internal Revenue Bulletin: 2004-51 |
December 20, 2004 |
Table of Contents
- REG-145535-02
- REG-149519-03
- AGENCY:
- ACTION:
- SUMMARY:
- DATES:
- ADDRESSES:
- FOR FURTHER INFORMATION CONTACT:
- SUPPLEMENTARY INFORMATION:
- Paperwork Reduction Act
- Background
- Explanation of Provisions
- 1. Framework of Rules
- 2. General Rule
- 3. Facts and Circumstances
- 4. Presumptions and Safe Harbors
- a. In General
- b. Timing of Transfers, Liquidations, and Service Partnerships
- c. Guaranteed Payments, Preferred Returns, Operating Cash Flow Distributions, and Qualified Reimbursements
- d. Certain Presumptions Not Included
- 5. Liabilities
- 6. Treatment of Transfers as a Sale
- 7. Disclosure
- 8. Review of Existing Regulations
- Proposed Effective Date
- Special Analyses
- Comments and Public Hearing
- Proposed Amendments to the Regulations
- Drafting Information
- Announcement 2004-100
- Announcement 2004-101
- Announcement 2004-102
| More Internal Revenue Bulletins |