US SB2095

Amends Internal Revenue Code partnership rules to require certain "covered partnerships" (where controlled group members own 50%+ of capital/profits) to use a "consistent percentage method" for allocating income, gain, loss, deduction, and credit among covered partners based on net equity

Mandates use of the "remedial method" for allocating built-in gains on contributed property and extends similar rules to revalued property, while eliminating the 7-year time limitation on taxing precontribution gain

Repeals Section 736 rules for payments to retiring or deceased partners, requires mandatory basis adjustments under Section 743 for partnership interest transfers (except for qualified small business partnerships), and simplifies partnership debt allocation rules under Section 752

Expands the 3.8% Net Investment Income Tax to apply to trade or business income for individuals with modified adjusted gross income exceeding $400,000 ($500,000 for joint filers), and includes amounts from controlled foreign corporations and passive foreign investment companies

Requires gain recognition on transfers to "swap funds" (partnerships or corporations allowing investors to diversify appreciated marketable securities), codifies Treasury's partnership anti-abuse rule in statute, and modifies treatment of worthless partnership interests and capital assets