The IRS has issued proposed regulations (REG-119305-11) under section 707 on disguised sales of property to or by a partnership, and under section 752 on the treatment of partnership liabilities. The proposed regulations address deficiencies and technical ambiguities in the current regulations and provide additional rules on tiered partnerships, qualified liabilities, and the anticipated reduction rule. Comments and hearing requests are due by April 30.
documents/EFTA01154589.pdf
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