Sec. 3616. Revisions related to unrealized receivables and inventory items
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(ii)of section 751(b)(1)(A) is amended by striking which have appreciated substantially in value . Section 751(b) is amended by striking paragraph (3). The amendments made by this subsection shall apply to distributions after December 31, 2014. The Secretary of the Treasury shall revise regulations issued under section 751(b) of the Internal Revenue Code of 1986 to take into account the partner’s share of income and gain rather than the partner’s share of partnership assets. Section 751(c) is amended by striking all that follows paragraph
(2)and inserting the following: For purposes of this section and sections 731, 732, 734, and 741, such term also includes any property other than inventory items, but only to the extent of the amount which would be treated as ordinary income if (at the time of the transaction described in the applicable section) such property had been sold by the partnership for its fair market value. . The amendment made by this subsection shall apply to partnership taxable years beginning after December 31, 2014.