related to P or S within the meaning of sec- treatment of S stock as property under Section 704.—Partner’s
tion 267(b) or 707(b) (unrelated person), paragraph (a)(2)(ii) of this section applies Distributive Share
occurring on or after May 31, 2007. to triangular reorganizations described in
26 CFR 1.704–1: Partner’s distributive share.
(ii) Binding commitment exception. paragraph (a)(1) of this section occurring
This section shall not apply to triangular