Extract to table

202 billion of aggregate built-in gain that must be properly addressed under Section 704(c) of the Code and the Treasury Regulations promulgated thereunder

Second, the new investors — principally Garrison Secondaries Fund IV LP, which is committing $380 million of new capital to the CV — must not bear the tax burden of pre-contribution built-in gain that accrued before they entered the partnership

A partnership is not required to use the same method for all contributed properties, but the partnership agreement must specify which method is used with respect to each item of contributed property, and the chosen method must be applied consistently for that item

The curative allocations must involve tax items of the "same type" or "same character" as the item that was limited by the ceiling rule

For example, if the ceiling rule limitation relates to capital gain on the sale of a contributed asset, the curative allocation must be made using other capital gain or capital loss items

The remedial items must be of the same character and must have the same tax effect as the items to which they relate