Capital gains treatment on partner reconstitution transfers, with excess receipts taxed to the entity and revaluation-linked attribution rules applied.

Transfer of money, capital assets, or both by a specified entity to a specified person in connection with reconstitution is taxed in the hands of the entity on the excess over the partner's capital account balance, computed as money received plus fair market value of capital assets less the capital account balance, with negative amounts taken as zero. Revaluation reserves, self-generated goodwill, and other self-generated assets are ignored in computing the capital account balance. The taxable amount is allocated to remaining assets only where it arises from revaluation or valuation, and the entity must file the prescribed form within the due date.

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