Allocations Under IRC 704(c)
From How Tax Works by Falcon Rappaport & Berkman LLP
January 5, 2026 · 19 min · Season 1 · Episode 43
About this episode
Matt Foreman discusses the allowable methods under IRC 704(c) and the Ceiling Rule problem.
In episode 43 of How Tax Works, Matt Foreman discusses the three allowable methods Traditional, Traditional with Curative Allocations, and Remedial; the Ceiling Rule problem and how each method creates or mitigates the Ceiling Rule problem; and whether Other Reasonable Methods are really a viable option. How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer unde...
People in this episode
Host: Matt Foreman
Topics covered
- IRC 704(c)
- taxation methods
- Ceiling Rule problem
- Traditional allocations
- Remedial allocations
Keywords
- IRC 704(c)
- Traditional allocations
- Curative Allocations
- Remedial
- Ceiling Rule
- taxation
Mentioned in this episode
Organizations: Falcon Rappaport & Berkman LLP
Books & works: How Tax Works
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