On Friday, December 22, President Trump signed sweeping tax reform (the “Act”) into law. The Act provides the most comprehensive update to the tax code since 1986, and includes a number of provisions of particular interest to partnerships and their partners. This alert addresses the following provisions:

  • Recharacterization of Certain Long-Term Capital Gains
  • Taxation of Gain on the Sale of Partnership Interest by a Foreign Person
  • Repeal of Technical Termination Rules under Section 708(b)(1)(B)
  • Modification of the Definition of Substantial Built-in Loss in the Case of a Transfer of a Partnership Interest under Section 743(d)
  • Charitable Contributions and Foreign Taxes Taken into Account in Determining Basis Limitation under Section 704(d)
  • Like-Kind Exchange Transactions under Section 1031

To download the complete bulletin please click here. To learn how it affects you, please contact your Pivot tax professional.