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of <h1>Deemed transfer on firm dissolution or reconstitution: assets distributed to partners taxed to entity at fair market value</h1> Where a partner or member receives a capital asset or stock-in-trade from a firm or other association of persons on its dissolution or reconstitution, the firm/AOP/BOI is deemed to have transferred the asset to that person in the year of receipt; resulting profits or gains are treated as the entity's income for that year and taxed under business income or capital gains. Fair market value on the date of receipt is deemed the full value of consideration. The Board may issue, with government approval, binding guidelines to resolve implementation difficulties. Definitions clarify 'reconstitution,' 'specified entity,' and 'specified person.'
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