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Regulation PS 2-95 - Distribution Of Marketable Securities By A Partnership. Notice Of Proposed
Get Regulation PS 2-95 - Distribution Of Marketable Securities By A Partnership. Notice Of Proposed
F Proposed Rulemaking and Notice of Public Hearing Distribution of Marketable Securities by a Partnership tions (26 CFR part 1) under section 731(c) of the Code. Section 731(c) was amended by section 741(a) of the Uruguay Round Agreements Act of 1994 (Public Law 103 465). securities. Finally, marketable securities contributed by a partner are treated as property other than money for purposes of determining the partner s net precontribution gain under section 737(b). PS 2 95 Backgroun.
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PS295 FAQ
Partnership distributions are the profits or losses of the partnership that are allocated to the partners ing to the terms of the partnership agreement.
Marketable securities are financial assets that can be easily bought and sold on a public market, such as stocks, bonds, and mutual funds. These securities are listed as assets on a company's balance sheet because they can be easily converted into cash.
A distribution of marketable securities is treated as a distribution of property other than money for purposes of section 737 to the extent that the marketable securities are not treated as money under section 731(c).
3. Cash Equivalents and Marketable Securities. Cash equivalents are highly liquid investments that are readily convertible into cash with original maturities of three months or less when purchased. Marketable securities consist of securities with original maturities greater than 90 days when purchased.
The term “marketable securities” means financial instruments and foreign currencies which are, as of the date of the distribution, actively traded (within the meaning of section 1092(d)(1)). 731(c)(2)(B)Other Property. Such term includes— 731(c)(2)(B)(i) Any interest in—
ingly, a partner receiving a distribution of marketable securities generally will have to recognize taxable gain equal to the excess, if any, of the fair market value of the securities over the partner's basis in the partnership interest.
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