INCOME TAX

Notice 2015–54, page 210. This notice 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. This 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.