Extract to table

The transferee must withhold 15% (or, in certain cases, 10%) of the amount realized on the disposition and remit the withheld amount to the IRS

If any such real property interests exist, their fair market value must be included in the numerator of the USRPHC asset ratio test

" First, the allocation must have "economic effect," meaning that the allocation is consistent with the underlying economic arrangement of the partners

704-1(b)(2)(ii) requires that the partnership agreement satisfy three conditions: (1) the partnership must maintain capital accounts in accordance with the rules of § 1

1 of the draft LPA provides that the general partner shall maintain capital accounts for each partner in accordance with the principles of Treasury Regulation § 1

704-1(b)(2)(ii)(d), providing that if a limited partner unexpectedly receives an adjustment, allocation, or distribution that causes or increases a deficit balance in its capital account, items of partnership income and gain shall be specially allocated to such partner in an amount sufficient to eliminate the deficit as quickly as possible