Today the IRS released Notice 2015-54, which announces that the Treasury Department and the IRS intend to issue regulations under section 721(c) to ensure that, when a U.S. person transfers certain property to a partnership that has foreign partners related to the transferor, income or gain attributable to the property will be taken into account by the transferor either immediately or periodically. The notice also announces that the Treasury Department and the IRS intend to issue regulations under sections 482 and 6662 applicable to controlled transactions involving partnerships to ensure the appropriate valuation of such transactions. Such regulations will apply to transfers occurring on or after August 6, 2015, and to transfers occurring before August 6, 2015, resulting from entity classification elections made under Treas. Reg. § 301.7701-3 that are filed on or after August 6, 2015, and that are effective on or before August 6, 2015.
Notice 2015-54 will be published in Internal Revenue Bulletin 2015-34 on Aug. 24, 2015.