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The IRS should exclude partnerships that have limited opportunities for abuse from rules that will crack down on transferring appreciated assets to foreign partners to escape U.S. tax, the New York State Bar Association Tax Section said.
Exclusions should apply to “partnerships where all or substantially all of the income is effectively connected income or where there is a relatively small interest held by related foreign partners and there is also a sufficient economic interest of an unrelated party with an adverse tax interest to prevent a shifting of built-in gain,” the tax section said in a Dec. 22 letter to the Internal Revenue Service.
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