1. Act limits ability to transfer �built-in� losses Changes are made to Section 704(c) �Built-in� loss is only for account of contributing partner Basis of property is otherwise limited to fair market value On transfer of partnership interest, �built-in� loss is lost

3. New definition � �Electing Investment Partnership� Investment company � no trade or business All assets held for investment 95% of contributions in money 24 month raise 15 year term Also see � Securitization Partnership

4. Basis of stock of a partner which is a corporation Rev. Rul. 99-57 dealt with gain aspect of stock of corporate partner On liquidating distribution, Section 755 will not permit loss to be allocated to corporate stock Allocate to other property When out of property, partnership recognizes gain

5. Effective Dates Generally effective for contributions after date of enactment For E.I.P. in effect on 6/4/04, no restriction on redemptions and 20 year term instead of 15 years Corporate stock rule effective for distributions after date of enactment