Allocation of built-in-gains with respect to contributed property

(a) In general Subparagraph (A) of section 704(c)(1) is amended to read as follows: (A) income, gain, loss, and deduction (including notional items thereof) with respect to property contributed to the partnership by a partner shall be shared among the partners under the remedial method prescribed by the Secretary so as to take into account all of the variation between the basis of the property to the partnership and its fair market value at the time of contribution,. (b) Effective date The amendment made by this section shall apply to property contributed to a partnership after the date of the enactment of this Act.