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Proposed regulations highlight differences between outright asset purchases, Section 743 step-ups upon the purchase of partnership interests, and special allocations of depreciation benefits under Section 704 c upon the contribution of cash or property to an existing partnership The proposed regulations highlight and magnify the distinction between the bonus depreciation benefits of an outright asset purchase, the bonus depreciation benefits of the purchase of an interest giving rise to a stepped-up inside basis for the purchasing partner under Section 743, and a contribution of money or property to a partnership -- which may give rise only to an increased allocation of otherwise existing partnership depreciation benefits under Section 704 c.
This formulation presented the question of whether the partnership would be able to assume 100 percent bonus depreciation in making this allocation of existing depreciation benefits to the contributing partner, giving a cash investor, for example, a large initial year deduction.
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Certain corporate stock purchases treated as asset acquisitions will be eligible for first-year expensing Certain taxpayers can elect for federal income tax purposes to treat corporate stock purchases and sales as if they were asset acquisitions or dispositions.
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