Proposed Guidance Under Internal Revenue Code Section 707 Relating to Disguised Sales of Property

Michael P. Burns wrote an article for the Spring 2014 edition of California Tax Lawyer relating to disguised sales of property.  Mr. Burns states that the Internal Revenue Code (the “Code”) provides generally that partners are entitled to contribute property to a partnership tax free and are entitled to receive a tax-free return of previously taxed profits through distributions.   This result does not apply, however, where the transaction is characterized as a disguised sale of property.  Read more of the article here: California Tax Lawyer