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On July 31, 2024--after the five-year anniversary had been reached and A, B, and C have each increased their basis (and reduced their deferred gain) by 10%--A sells 50% of its qualifying QQF partnership interest in Q to B for $400 cash.
The sale of 50% of A's qualifying QQF partnership interest to B requires A to recognize $90 of eligible gain, the lesser of:
(69) The use of the wore "investment" in the statute implies that to benefit from the exclusion, a taxpayer must sell the equity interest in the QQF Presumably, if the QOF were to instead sell its assets, any gain realized inside the QQF would be recognized.
162 trade or business; (105) as a result, if a QQF or subsidiary constructs a building that is rented, for example, to Walmart on a triple-net basis, (106) the IRS may take the position that the building is not used in a trade or business and should not count toward the 90% or 70% test.
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- QQ (disambiguation)
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