SECTION 4. AUTOMATIC

PERMISSION FOR QUALIFIED MASTER-FEEDER STRUCTURES TO AGGREGATE CONTRIBUTED PROPERTIES

.01 In general . Permission is hereby granted for any QMFS, as defined in section 4.02 of this revenue procedure, to aggregate built-in gains and losses from contributed qualified financial assets for purposes of making § 704(c) and reverse § 704(c) allocations.

.02 Qualified Master-Feeder Structure . A QMFS is created where two or more investors contribute cash or qualified financial assets to a Master Portfolio in exchange for beneficial interests in the Master Portfolio. To qualify as a QMFS, the following requirements must be met:

(1) Each partner in the Master Portfolio is a Feeder Fund, or an investment advisor, principal underwriter, or manager of the Master Portfolio;

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability. (Also Part I, sections 704; 1.704–1, 1.704–3.)

Rev. Proc. 2001–36