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Thisdistribution can, but need not, be in complete liquidation of thedistributee partners interests in the partnership. An "assets-up" transaction is the distribution ofassets from a partnership to a partner and then the contribution ofthose assets by the distributee to a new partnership. This iscalled an "interests over" transfer, and the proposedregulations provide that such a transaction will be recast inthe form of an assets-over transaction. If, though, AB is treated as thecontinuation, then the transaction is treated as if the assetsof AB remained in AB and the assets of CD weretransferred from CD to AB in an assets-over transfer. As part of the same transaction, ABC transfers Whiteacre to D in exchange for interests in D,interests which are then distributed to A and B inliquidation of ABC.
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In view of individual nature of tax consequences, each investor is advised to consult his/ her own professional tax advisor.

The information provided under this section ‘Investor Education’ is solely for creating awareness and educating investors / potential investors about Mutual Fund Schemes and for their general understanding.

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