Washington tax watch: Treasury revises liability allocation rules

Article Abstract:

The Department of the Treasury has revised Section 752 of regulations concerning liability allocation in partnerships. The first notice of proposed rulemaking issued simplifies and revises current regulations. The second notice adopts temporary regulations amending effective dates, giving taxpayers more leeway in determining which regulations will cover partnership liabilities. Major revisions in the following rules are taken up: anti-abuse rules, interest guarantees, pledged property, de minimis rule and residual nonrecourse debt. The Proposed and Temporary Regulations' effective dates are also discussed.

Liabilities (Accounting)

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Partnership classification: recent developments

Article Abstract:

The IRS published two revenue procedures which provide classification guidelines for an organization to be considered a partnership. Revenue procedure 92-33 regulates the free transferability of interests for partnerships which limit transfers exceeding 20% of total interests. Revenue procedure 92-35 sets conditions for a limited partnership's continuity of life. The new regulations amend revenue procedure 89-12, which presents conditions needed for an organization to be considered for partnership taxation.

United States. Internal Revenue Service

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Proposed regulations on basis allocation under subchapter K provide needed guidance

Article Abstract:

The United States Department of Treasury's proposed regulations regarding the exchange or sale of partnership interests are reviewed and issues are examined.

United States, Public Finance Activities, Government regulation (cont), Regulation, Licensing, and Inspection of Miscellaneous Commercial Sectors, Treasury Department, Financial Regulatn NEC, Statistical Data Included, Financial services, Commercial law, Liquidity (Finance)

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